IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.1

PROMESA Title III 

No. 17-BK-3283-LTS 

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO, 

as representative of 

THE PUERTO RICO ELECTRIC POWER AUTHORITY, 

Debtor. 

PROMESA Title III 

No. 17-BK-4780-LTS 

SUPPLEMENTAL OBJECTIONS OF THE AD HOC GROUP OF 

PREPA BONDHOLDERS TO THE DISCLOSURE STATEMENT FOR 

THE FIRST AMENDED TITLE III PLAN OF ADJUSTMENT OF THE 

PUERTO RICO ELECTRIC POWER AUTHORITY [ECF NO. 3201]

1

 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number and the 

last four (4) digits of each Debtor’s federal tax identification number, as applicable, are the 

(i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits of Federal 

Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation 

Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567-LTS) (Last Four Digits of Federal Tax ID: 3808); 

(iv) Employees Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) 

(Bankruptcy Case No. 17-BK-3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico 

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780-LTS) (Last Four Digits of 

Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy Case No. 

19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations). 

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TABLE OF CONTENTS 

INTRODUCTION ...........................................................................................................................1

I. The First Amended Plan Is Patently Unconfirmable For The Additional Reason 

That It Unfairly Discriminates Between National And Other PREPA Bondholders ..........3

A. The Different Base Settlement Treatment Between National And Both 

Settling and Non-Settling Bondholders Is Unjustifiable .........................................3

B. The Settlement Of National’s Postpetition Interest Claims Discriminates 

Against All Other Bondholders, Who Would Get Zero Postpetition 

Recovery ..................................................................................................................5

C. The National Fees Are Additional Compensation With No Economic Basis

..................................................................................................................................6

II. The Oversight Board’s Increase In Total Creditor Recoveries, To Facilitate Its 

National Deal, Confirms That PREPA Can Afford To Pay Creditors More Than 

Asserted By Its Artificial Affordability Cap ........................................................................7

III. The First Amended Disclosure Statement Remains Inadequate ..........................................9

CONCLUSION ..............................................................................................................................10

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TABLE OF AUTHORITIES 

 Page(s) 

Cases 

In re Acemla De P.R. Inc., 

No. 17-02021 ESL, 2019 WL 311008 (Bankr. D.P.R. Jan. 22, 2019) ....................................10 

In re Barney & Carey Co., 

170 B.R. 17 (Bankr. D. Mass. 1994) .........................................................................................3 

In re Hermanos Torres Perez Inc., 

No. 09-05585-EAG, 2011 WL 5854929 (Bankr. D.P.R. Nov. 21, 2011) .................................3 

Ins. Co. of N. Am. v. Puerto Rico Marine Mgmt., Inc., 

768 F.2d 470 (1st Cir. 1985) ......................................................................................................4 

In re LTC Holdings, Inc., 

No. 14-11111, 2020 WL 5576850 (D. Del. Sept. 17, 2020) ......................................................4 

New York Bd. of Fire Underwriters v. Trans Urb. Constr. Co., 

91 A.D.2d 115 (N.Y. App. Div. 1983) ......................................................................................4 

Small v. Yonkers Contracting Inc., 

242 A.D.2d 378 (N.Y. App. Div. 1997) ....................................................................................4 

Statutes 

PROMESA § 312(a) ........................................................................................................................9 

Other Authorities 

PREPA Bondholder Mediation Presentation, available at 

https://emma.msrb.org/P11641653-P11264323-P11690562.pdf...............................................8 

PREPA FOMB Proposal to Bondholder Group (Nov. 8, 2022) ......................................................8 

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Pursuant to Section 1125 of the Bankruptcy Code and Rule 3017 of the Federal Rules of 

Bankruptcy Procedure, made applicable to this proceeding by Sections 301 and 310 of the Puerto 

Rico Oversight, Management, and Economic Stability Act, and as authorized by the Court, ECF 

No. 3210, the Ad Hoc Group of PREPA Bondholders respectfully submits these supplemental 

objections to the Disclosure Statement for the First Amended Title III Plan of Adjustment of the 

Puerto Rico Electric Power Authority (“Feb. 9 DS”), ECF No. 3201, submitted by the Financial 

Oversight and Management Board for Puerto Rico.2

INTRODUCTION 

1. PREPA’s Plan and Disclosure Statement have gone from bad to worse. The First 

Amended Plan doesn’t correct the fundamental flaws that made its original version patently 

unconfirmable. Rather, the Oversight Board added to the Plan the terms of a National Settlement 

that could hardly be more brazen in its unfair discrimination against other Bondholders. The 

resulting First Amended Plan proposes to “settle” National’s bond claim for 83 cents on the dollar, 

but offers to pay the virtually identical claims of Settling Bondholders and Monolines only 50 

cents, and to pay even victorious Non-Settling Bondholders and Monolines only 56 cents. 

2. The Disclosure Statement provides no basis for these wide disparities in recoveries 

among holders of the same bonds, other than National’s agreement to vote for the Plan in exchange 

for wildly preferential treatment. To fund National’s “yes” vote, moreover, the Oversight Board 

simply adds more than $250 million to the total amount of creditor recoveries—thereby confirming 

that the Oversight Board’s asserted affordability cap is a made-up figure that it moves up or down 

at its whim. The Court should deny approval of the Disclosure Statement in support of this patently 

2

 Unless otherwise noted, capitalized terms have the same meaning as in the Ad Hoc Group’s Disclosure 

Statement Objection, ECF No. 3189, and in the First Amended Disclosure Statement. 

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unconfirmable Plan—which is built atop one-off preferential deals that do not pass legal muster, 

an improper and misleading pre-Disclosure Statement solicitation of plan treatment to 

bondholders, and arbitrary and unsupportable allegations about what can be paid to creditors. 

THE NATIONAL SETTLEMENT 

3. Under the First Amended Plan, National would receive more than 83 cents on every 

dollar of principal and prepetition interest on PREPA Bonds that National insures or owns. First, 

it would receive a 71.65 cent recovery on the bond claim itself. Feb. 9 DS at 258. Second, National 

would get another 5.86 cents in fees—3 cents for its efforts during this case, plus 2.86 cents for 

structuring payments to its own insureds. Id. Third, it would get 5.85 more cents in a 20% 

recovery on National’s post-petition payouts to its insured Bondholders. See id.

3

 The differences 

between National’s proposed settlements and Bondholders’ recoveries are illustrated here: 

National’s Recovery vs. Other Bondholders’ Recovery 

(assuming Bondholders have a right to payment—secured or unsecured4)

Base Fee & Expense Reimbursement TOTAL 

National 71.65% 5.86% 5.85% 83.36% 

Settling 

Bondholders 

50.00% 0 0 50.00% 

Non-Settling 

Bondholders* 

56.08% 0 0 56.08% 

4. National’s 83% recovery under the First Amended Plan would provide it a 

substantial—and indefensible—premium over what both Settling and Non-Settling Bondholders 

3

 The deal also provides that National can receive a contingent value instrument (a “CVI”) that could pay 

additional sums if a new CVI is offered to holders of other Bonds. Amounts are calculated as of July 2023. 

4

 Settling Bondholders can receive more than 50 cents only in certain remote scenarios in which (1) this 

Court holds that PREPA’s bondholders have no right to payment or security beyond the $16 million Sinking 

Fund, and (2) particular proportions of Settling versus Non-Settling Bondholders are achieved. Moreover, 

this chart and brief presents recoveries in terms of Series B Bond face value, which will not match their farlower actual value—further depressing all bondholder recoveries. See AHG Obj. ¶ 68. 

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would recover. Even assuming that Non-Settling Bondholders win on every issue in the Amended 

Lien and Recourse Litigation, they would still recover no more than 56%. Settling Bondholders—

who, like National, would also agree to resolve the Amended Lien and Recourse Litigation—are 

being offered a recovery capped at 50% in almost every plan scenario for settling the same claims. 

See Feb. 9 DS at 39. Accordingly, National’s 83% recovery is one and a half times greater than 

other Bondholders’ 50-56% recovery, even in the least discriminatory realistic scenario. 

SUPPLEMENTAL OBJECTIONS 

I. The First Amended Plan Is Patently Unconfirmable For The Additional Reason That 

It Unfairly Discriminates Between National And Other PREPA Bondholders 

5. The Oversight Board has no justification for its unequal treatment of PREPA Bonds 

insured by National versus those not insured by National, and so the Plan unfairly discriminates 

against other Bondholders. A plan unfairly discriminates against a class of creditors when 

“creditors and equity interest holders with similar legal rights . . . receiv[e] materially different 

treatment under a proposed plan without compelling justifications for doing so.” In re Hermanos 

Torres Perez Inc., No. 09-05585-EAG, 2011 WL 5854929, at *9 (Bankr. D.P.R. Nov. 21, 2011). 

“[D]ifferentiated treatment of similar classes intended merely to induce acceptance by one class 

fails.” In re Barney & Carey Co., 170 B.R. 17, 25 (Bankr. D. Mass. 1994). “The burden is on the 

Debtor to show that unequal treatment between classes having the same priority does not constitute 

unfair discrimination.” Id. The Oversight Board cannot possibly meet that burden here. 

A. The Different Base Settlement Treatment Between National And Both Settling And 

Non-Settling Bondholders Is Unjustifiable 

6. The Oversight Board cannot explain why National should receive 72 cents on the 

base settlement of its bond claims, while all other Settling Bondholders receive 50 cents for settling 

exactly the same claims. The National-insured PREPA Bonds were issued under the same Trust 

Agreement as uninsured PREPA Bonds. And the National-insured bonds were issued in the same 

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manner, for the same purpose, and largely at the same times as PREPA bonds insured by other 

monolines. National is simply asserting subrogation claims for the principal and interest that 

National had to pay insured Bondholders, under non-Debtor agreements, after PREPA defaulted 

on its obligation to make those payments. And those agreements make clear that, once National 

makes such payments, it steps into the insured Bondholders’ claims with no greater rights than the 

insured holders had. In other words, PREPA does not owe a penny more on a National-insured 

bond than it does on an uninsured bond.5

7. Neither the Oversight Board nor National has ever argued, nor does the Disclosure 

Statement even try to suggest, that National’s claims are in any way legally distinct from other 

PREPA bond claims. To the contrary, the Disclosure Statement is clear that the claims the 

Oversight Board is settling with National are the exact same claims that other Bondholders also 

have against PREPA. See Feb. 9 DS at 50-52 (listing exactly the same claims under “Settlement 

of Outstanding Disputes” for National and Settling Bondholders). 

8. There couldn’t be a clearer case of unfair discrimination. National would plainly 

receive a vastly better deal for identical claims. Nor can the Oversight Board justify such 

discrimination simply by contending that Settling Bondholders (if any) are agreeing to accept 

inferior terms in response to the Oversight Board’s unapproved solicitation made after the National 

settlement had been reached in principle, but without disclosing that settlement’s much more 

favorable terms. This adds to the myriad reasons, set forth in the Ad Hoc Group’s initial 

5

 It is well-settled that a subrogation claim has no more rights than those possessed by the underlying claim. 

See Ins. Co. of N. Am. v. Puerto Rico Marine Mgmt., Inc., 768 F.2d 470, 473 (1st Cir. 1985) (holding, that 

“plaintiff, an insurer, has no greater or lesser rights than those of its insured”); see also Small v. Yonkers 

Contracting Inc., 242 A.D.2d 378, 379 (N.Y. App. Div. 1997); New York Bd. of Fire Underwriters v. Trans 

Urb. Constr. Co., 91 A.D.2d 115, 119 (N.Y. App. Div. 1983); In re LTC Holdings, Inc., No. 14-11111, 

2020 WL 5576850, at *6 (D. Del. Sept. 17, 2020) (several federal jurisdictions hold “a surety cannot, by 

way of subrogation, assert any greater rights than the creditor in whose shoes it is substituted”).

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Objections (at ¶¶ 58-63), that the settlement solicitation is improper, misleading, and 

independently warrants denying approval of the Disclosure Statement. 

9. The unfairness of the First Amended Plan’s discrimination against Non-Settling 

Bondholders is similarly apparent. For instance, the most that Non-Settling Bondholders and 

Monolines can recover under the Plan is 56 cents on the dollar, even if they win on every issue in 

the Amended Lien and Recourse Litigation. See Feb. 9 DS at 28. And yet National would get 72 

cents on the dollar for settling the same claims (plus 12 cents in other payments). What kind of 

litigation “settlement” pays out substantially more than non-settling parties could achieve on the 

same claims by winning the case outright? This preferential treatment of identical claims can be 

understood only as an attempt to manufacture the illusion of meaningful creditor support for the 

plan by creating yet another questionable one-creditor accepting class. 

B. The Settlement Of National’s Postpetition Interest Claims Discriminates Against All 

Other Bondholders, Who Would Get Zero Postpetition Recovery 

10. Next, the National Settlement gives National roughly another 6 cents (calculated 

through July 2023) to settle its postpetition interest claims against PREPA, but offers Settling 

Bondholders and Non-Settling Bondholders nothing on these claims. 

11. The Ad Hoc Group agrees that all Bondholders are entitled to receive postpetition 

interest. As recently as early 2022, the Oversight Board appeared to see this the same way, when 

it reaffirmed a 2019 RSA under which PREPA would have paid Bondholders roughly 67 percent 

on postpetition interest claims that accrued during the case. There was never any suggestion then, 

or now, that National is somehow entitled to a better claim for postpetition interest than other 

PREPA Bondholders. To the contrary, National’s insurance contracts with PREPA provide only 

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that it steps into the shoes of Bondholders after PREPA fails to pay, and do not give National any 

greater claim to repayment of principal and interest from PREPA than the Bondholders possess.6

12. Even the Oversight Board appears to understand that this discrimination is illegal: 

It expressly acknowledges that its treatment of National’s so-called “reimbursement claim” for 

postpetition payments to its insureds might unfairly discriminate against other Bondholders and 

Monolines, which are being offered zero post-petition recovery. Feb. 9 DS at 33-34, 258-59.7

C. The National Fees Are Additional Compensation With No Economic Basis 

13. Finally, the “fees” the Oversight Board proposes to pay National—amounting to 

more than 5% of National’s prepetition claim (and nearly $50 million)—cannot be justified as 

reasonable compensation, and merely provide National a backdoor recovery on its claim. 

14. With respect to the “structuring fee,” as further set forth in the Trustee’s 

supplemental objection, National is receiving a 2.86% fee to pay its insured holders for structuring 

commutation elections that may very well be beneficial to National and detrimental to its insured 

holders. Whether or not National is using this bankruptcy process to benefit itself at the expense 

of its claimholders, one thing is clear—structuring the resolution of National’s insurance contracts 

is an issue between National and its policyholders, not one that should cause PREPA to pay 

National additional compensation at other creditors’ expense.8

6

 Certain National agreements (which can be provided to the Court on request) require PREPA to reimburse 

National for fees and expenses, but only those incurred to pursue remedies under the Trust Agreement and 

not for payments made under its policies. Payments made under the polices are covered in a separate 

section stating that National will be subrogated to underlying holders’ rights to payment from PREPA. 

7

 As further outlined in the supplemental objection by the Ad Hoc Committee of National Claim Assignees, 

which the Ad Hoc Group joins, the unfair discrimination is heightened by providing this settlement 

treatment to National alone, and not also to holders who purchased, from National, the same subrogation 

claims on certain National-wrapped bonds. See Feb. 9 Plan, art. I.A.148, I.A.153. 

8 See FOMB “Reply Chart,” ECF No. 3206-1, at A-28 to A-29 (“[T]he relative rights of an insured 

bondholder and its monoline insurer should otherwise be resolved between the parties in accordance with 

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15. National’s 3% RSA fee for its efforts in this case is likewise just a back-door way 

to increase National’s total recovery on its claim. The RSA fees approved in other Title III cases 

were intended to reimburse holders whose expenditure of significant time and resources, during 

years-long negotiations with Title III debtors, had resulted in settlements in which other, lessactive holders were able to participate. Here, by contrast, National has merely settled its own 

claims, bestowing no benefit on other creditors. 

16. In summary, the stark difference in recovery being offered to National (83 cents) 

versus other identically situated Bondholders (50-56 cents) is unheard of in Title III proceedings. 

The Oversight Board has never asked the Court to accept such substantially divergent plan 

treatment of insured and uninsured bond claims, nor such a dramatic difference between monoline 

insurers of the same bonds. This disparate treatment is patently unconfirmable. Rather than 

narrowing the many confirmation issues, the First Amended Plan presents yet another misguided 

attempt to manufacture an artificial impaired accepting class—creating only more issues to litigate 

at a protracted confirmation hearing. 

II. The Oversight Board’s Increase In Total Creditor Recoveries, To Facilitate Its 

National Deal, Confirms That PREPA Can Afford To Pay Creditors More Than 

Asserted By Its Artificial Affordability Cap 

17. The Oversight Board’s cap on total recoveries to creditors continues to move up or 

down depending on its negotiating positions at any given moment, and with no grounding in fact. 

Here is an updated chart of the Oversight Board’s varying positions on affordability (see AHG 

Obj. ¶ 67): 

their relevant insurance policies.”). While insurers received a “structuring fee” in PRIFA’s Title VI, that 

was a consensual restructuring with widespread creditor support, and no parties objected to those fees. 

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Proposal Amount 

2019 RSA 

(2018-2019) 

Over $8 billion for Bondholders 

FOMB Mediation Offer 

(Nov. 2022) 

$6.073 billion for bondholders; $7.8 

billion for all creditors9

Proposed Plan 

(Dec. 2022) 

No more than $4.411 billion for 

Bondholders; $5.4 billion for all creditors 

First Amended Plan 

(Feb. 2022) 

$5.68 billion for all creditors 

($280 million increase for National) 

18. The Oversight Board does not say where PREPA “found” the new $280 million 

over the past several weeks, because of course that sum (and more) has been available to fund 

creditor recoveries all along. The new $5.68 billion affordability cap is every bit as fictional as 

the $5.4 billion cap that came before it. After all, less than a month before the Oversight Board 

filed the Plan, it proposed $7.8 billion in total creditor recovery, and only twelve months ago it 

was still advocating for Bondholders alone to receive more than $8 billion. 

19. In its reply, the Oversight Board did not even try to explain the disappearance of 

billions of dollars of potential creditor payments. It merely suggests that its earlier affordability 

concessions (first over $8 billion for Bondholders, then $6.073 billion for Bondholders) will be 

inadmissible to show what PREPA can pay creditors now. The Oversight Board maintains that 

the only relevant number is what it now asserts to be the most PREPA can possibly pay (which 

itself changed from $5.4 billion to $5.68 billion over just a few weeks). But as set forth below, 

that figure continues to be an arbitrary, unsupportable, and utterly conclusory affordability cap—

and the lack of a discernible basis for that cap may explain why the Oversight Board fails to 

disclose enough information to allow even sophisticated creditors to understand it. The cap is also 

9

 This number can be derived from the publicly available information available here: PREPA FOMB 

Proposal to Bondholder Group at 6-7 (Nov. 8, 2022); PREPA Bondholder Mediation Presentation at 12, 

both available at https://emma.msrb.org/P11641653-P11264323-P11690562.pdf. 

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a moving target—shifting to facilitate the Oversight Board’s preferred deals only—which shows 

that, contrary to this Court’s admonishments, the Oversight Board has filed a “place holder” plan 

that it never “believe[d] in good faith should move toward approval.” 11/2/2022 Tr. 18. The 

Oversight Board is not dealing fairly with creditors or honestly with creditors, and its abuse of the 

confirmation process to pressure Bondholders into accepting lowball settlement offers—after 

almost six years in Title III—should not be tolerated by this Court. 

20. The Oversight Board and its new allies would have this Court address all of these 

issues only at a confirmation hearing, months from now. But waiting months to address a patently 

unconfirmable Plan would merely postpone the tough political decisions that PREPA will need to 

make to reach fair agreements with the vast majority of its creditors—and creates an overwhelming 

likelihood that PREPA will come out of a July confirmation hearing even further away from 

exiting Title III. 

21. Title III cases are not like ordinary restructuring cases. Creditors cannot propose 

alternative plans to combat a debtor’s unconfirmable plan. See PROMESA § 312(a). Facing no 

risk of ever losing its exclusive right to propose plans, the Oversight Board evidently believes that 

it can take as many bites at the apple as it needs and for as long as it takes. The Court should not 

allow the Oversight Board to operate under this premise, and it should instead take this opportunity 

to again require the Oversight Board to put forward a confirmable plan. 

III. The First Amended Disclosure Statement Remains Inadequate 

22. The February 9 Disclosure Statement contains new material, such as the Legacy 

Charge Derivation (Ex. P), supposedly offered to explain the Oversight Board’s affordability 

conclusion. But this material is woefully insufficient to allow creditors to understand that 

conclusion. For instance, the Derivation references at least $2.245 billion in “necessary costs,” 

including “capital expenditures”—additional to the billions in federal dollars earmarked for 

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PREPA’s system—that are entirely new add-ons to the costs and expenses reflected in PREPA’s 

Fiscal Plan certified by the Oversight Board on June 30, 2022. And yet the Plan and Disclosure 

Statement utter nary a word to explain these brand-new costs and expenditures, or why they have 

suddenly arisen after years of fiscal plans failing to include them.10

23. It is not sufficient disclosure for the Oversight Board to merely present its newly 

revised affordability cap on total creditor recovery, and to vaguely assert that it considered many 

different factors to arrive at it. The Oversight Board must produce actual data underlying these 

decisions so that creditors can assess their merit (or lack thereof). In re Acemla De P.R. Inc., No. 

17-02021 ESL, 2019 WL 311008, at *14 (Bankr. D.P.R. Jan. 22, 2019) (“Creditors rely on the 

disclosure statement to determine what distribution or other assets they will receive and also what 

risks they will face.” (internal quotation marks omitted)). 

24. The February 9 Disclosure Statement continues to omit adequate information about 

the Oversight Board’s and Ad Hoc Group’s affordability analyses (AHG Obj. ¶¶ 79-80); the nature 

and structure of and the process for establishing the Legacy Charge (id. ¶¶ 81-82); and details 

about the New Bonds including the indenture agreement (id. ¶¶ 83-88). The Oversight Board 

should be required to supplement its disclosure with this information.11

CONCLUSION 

The First Amended Plan remains patently unconfirmable, and the First Amended 

Disclosure Statement is inadequate. The Oversight Board’s motion to approve should be denied.

10 The Ad Hoc Group believes, based on the limited information already available in the Legacy Charge 

Derivation, that calculations and adjustments referenced in the Legacy Charge Derivation contain numerous 

errors, and reserves all rights regarding the Oversight Board’s analysis therein. 

11 The Ad Hoc Group has prepared a new markup reflecting the proposed Disclosure Statement edits that 

the Oversight Board did not accept, as well as a supplemental markup to amended portions of the February 

9 Disclosure Statement. This markup is contained in Exhibit A, and a revised Ad Hoc Group statement 

reflecting the National settlement and revisions to the terms of the Series B Bonds is attached as Exhibit B. 

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We hereby certify that, on this same date, we electronically filed the foregoing with the clerk of 

the Court using the CM/ECF system, which will notify the attorneys of record. 

Dated: San Juan, Puerto Rico 

 February 17, 2023 

TORO COLÓN MULLET P.S.C. 

/s/ Manuel Fernández-Bared 

Manuel Fernández-Bared 

USDC-PR No. 204,204 

P.O. Box 195383 

San Juan, PR 00919-5383 

Tel.: (787) 751-8999 

Fax: (787) 763-7760 

E-mail: mfb@tcm.law 

/s/ Linette Figueroa-Torres 

Linette Figueroa-Torres 

USDC-PR No. 227,104 

E-mail: lft@tcm.law 

/s/ Nayda Perez-Roman 

Nayda Perez-Roman 

USDC–PR No. 300,208 

E-mail: nperez@tcm.law 

Counsel for the Ad Hoc Group of PREPA 

Bondholders 

KRAMER LEVIN NAFTALIS & 

FRANKEL LLP 

/s/ Amy Caton 

Amy Caton* 

Thomas Moers Mayer* 

Alice J. Byowitz* 

1177 Avenue of the Americas 

New York, New York 10036 

Tel.: (212) 715-9100 

Fax: (212) 715-8000 

Email: acaton@kramerlevin.com 

tmayer@kramerlevin.com 

abyowitz@kramerlevin.com 

Gary A. Orseck* 

Matthew M. Madden* 

2000 K Street NW, 4th Floor 

Washington DC 20007 

Tel: (202) 775-4500 

Fax: (202) 775-4510 

Email: gorseck@kramerlevin.com 

 mmadden@kramerlevin.com 

*Admitted Pro Hac Vice 

Counsel for the Ad Hoc Group of PREPA 

Bondholders

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