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.,

Debtors1

PROMESA

TITLE III

No. 17-BK-3283-LTS

(Jointly Administrated)

PROMESA

TITLE III

No. 17-BK-4780-LTS

(Jointly Administrated)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO,

As representative of

PUERTO RICO ELECTRIC POWER 

AUTHORITY,

Debtor 

MOTION SUBMITTING EXPERT WITNESS CREDENTIALS

TO THE HONORABLE COURT:

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-5233-LTS) (Last Four Digits of Federal 

Tax ID: 3801) (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations).

Case:17-03283-LTS Doc#:24015 Filed:04/17/23 Entered:04/17/23 13:52:17 Desc: Main

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COMES NOW, Instituto de Competitividad y Sostenibilidad Economica de Puerto 

Rico (ICSE), as party in interest pursuant to 11 U.S.C. §1109(b), through its undersigned 

attorney and before this Honorable Court very respectfully states and prays:

1. ICSE filed the motion identifying the Expert Witnesses Disclosure on March

24, 2023. (Docket Entry 23870).

2. ICSE submits the experts’ credentials for Ramon Cao (See Exhibit I-CV 

Ramon Cao and for Ramon Luis Nieves (See Exhibit II-CV Ramon Luis Nieves).

3. ICSE notified the witnesses according to the Court timetable and this motion 

is to include the credentials of such witnesses. 

WHEREFORE, ICSE respectfully requests that the Court take notice of the above 

stated.

WE 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 notification of such 

filing to all participants and Standard Parties. A courtesy copy of this Motion will be 

delivered to the Court by email to SwainDPRCorresp@nysd.uscourts.gov as provided in 

First Amended Standing Order.

In San Juan, Puerto Rico, this 17th day of April 2023.

Respectfully submitted.

/s/FERNANDO E. AGRAIT 

FERNANDO E. AGRAIT

USDC 127212 

EDIFICIO CENTRO DE SEGUROS

701 AVENIDA PONCE DE LEON 

OFICINA 414 

SAN JUAN, PUERTO RICO 00907 

TEL. 787-725-3390/3391 

FAX 787-724-0353 

EMAIL: agraitfe@agraitlawpr.com

Case:17-03283-LTS Doc#:24015 Filed:04/17/23 Entered:04/17/23 13:52:17 Desc: Main

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