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

PUERTO RICO ELECTRIC POWER AUTHORITY,

Debtor.

PROMESA

Title III

No. 17-BK-4780-LTS

(Jointly Administered)

NOTICE OF VIDEOTAPED DEPOSITION OF SUSAN TIERNEY, PHD

PLEASE TAKE NOTICE that, pursuant to Rules 26 and 30 of the Federal Rules of Civil

Procedure, made applicable to this proceeding by Rules 7026 and 7030 of the Federal Rules of

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- BK5523-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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Bankruptcy Procedure pursuant to section 310 of the Puerto Rico Oversight, Management, and

Economic Stability Act (“PROMESA”)2

, the Financial Oversight and Management Board for 

Puerto Rico (the “Oversight Board”), as the sole Title III representative of the Puerto Rico 

Electric Power Authority (“PREPA” or the “Debtor”), will take the remote deposition upon oral

examination of Susan Tierney, Ph.D. on May 31, 2023 at 9:30 am EST. The topics of Dr. 

Tierney’s deposition will include, without limitation: the subject matter set forth in the Expert 

Report of Susan Tierney, Ph.D. [ECF No. 3423-2 in Case No. 17-BK-4780-LTS] and the 

Rebuttal Expert Report of Susan Tierney, Ph.D. [ECF No. 3503-3 in Case No. 17-BK-4780-

LTS]; Dr. Tierney’s qualifications; Dr. Tierney’s history testifying in other cases; and the details 

of any compensation Dr. Tierney received for testifying in this case. To observe or participate in 

Dr. Tierney’s deposition remotely, please use the following link:

https://proceedings.veritext.com/?token=9486d51d7f3c60f6ce0887091e549173

[Remainder of Page Intentionally Left Blank]

2 PROMESA has been codified at 48 U.S.C. § 2101-2241.

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Dated: May 18, 2023

New York, New York

Respectfully submitted,

/s/ Margaret A. Dale

Martin J. Bienenstock

Paul V. Possinger

Ehud Barak

Margaret A. Dale

Michael T. Mervis

Julia D. Alonzo

Laura Stafford

Javier F. Sosa

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial Oversight and 

Management Board, as representative for 

PREPA

/s/ Hermann D. Bauer 

Hermann D. Bauer

USDC No. 215205

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-Attorneys for the Financial 

Oversight and Management Board, as 

representative for PREPA

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CERTIFICATE OF SERVICE

I hereby certify that, on this same date, I electronically filed the foregoing with the Clerk

of the Court using the CM/ECF system, which will send notifications of such filing to all 

CM/ECF participants in this case.

/s/ Hermann D. Bauer

Hermann D. Bauer

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