Exhibit A

UNSWORN DECLARATION UNDER PENALTY OF PERJURY 

PURSUANT TO 28 U.S.C. § 1746(2)

Case:17-03283-LTS Doc#:23874-1 Filed:03/27/23 Entered:03/27/23 12:09:02 Desc:

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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

Re: ECF No. 23427

 

UNSWORN DECLARATION UNDER PENALTY OF PERJURY

PURSUANT TO 28 U.S.C. § 1746(2)

I, Luis R. Emanuelli, of legal age, married, resident of Trujillo Alto, Puerto Rico, under 

penalty of perjury declares the following:

1. My name and other circumstances are as stated above. 

2. I am the Regional Vice President, Puerto Rico Region, of Fresenius Medical Care, North 

America (“FMC”).

3. FMC is the party in interest in Proof of Claim No. 30574. 

1 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number listed as a bankruptcy 

case number due to software limitations and the last four (4) digits of each Debtor’s federal tax identification number, 

as applicable, are the (i) Commonwealth of Puerto Rico (the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283 

(LTS)) (Last Four Digits of Federal Tax ID: 3481), (ii) 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), (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567 

(LTS)) (Last Four Digits of Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) 

(Bankruptcy Case No. 17-BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric 

Power Authority (“PREPA”) (Bankruptcy Case No. 17-4780 (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).

Case:17-03283-LTS Doc#:23874-1 Filed:03/27/23 Entered:03/27/23 12:09:02 Desc:

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4. I was the executive in charge of the FMC office when Hurricane Maria struck the Island 

in 2017 causing severe damage to the building located at 461 Francia Street, San Juan, 

Puerto Rico 00917. 

5. All the paper copies of invoices sent to the Puerto Rico Department of Health (“PRDH”) 

were water damaged, could not be salvaged, and were discarded. 

6. There are no digital backups of these paper invoices. 

7. However, all paper invoices were regularly delivered to the PRDH for processing. 

8. I have read the foregoing Response To The Five Hundred Sixty-First Omnibus Objection 

(Non-Substantive) Of The Commonwealth Of Puerto Rico, Puerto Rico Highways And 

Transportation Authority, And Puerto Rico Public Buildings Authority To Deficient Claims 

(“Response”); and

9. The factual assertions in the Response are true and correct to the best of my knowledge, 

information, and belief and/or pursuant to documents in my possession and my personal 

involvement in the facts of this case. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on March ___, 2023.

________________________

LUIS R. EMANUELLI

Regional Vice President, Puerto Rico Region

Fresenius Medical Care, North America

Case:17-03283-LTS Doc#:23874-1 Filed:03/27/23 Entered:03/27/23 12:09:02 Desc:

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