THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

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 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 (the “Commonwealth”) (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).

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

Case No. 17-03283 (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

Case No. 17-4780-LTS

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STATEMENT OF SUPPORT AND RESERVATION OF RIGHTS

OF NATIONAL PUBLIC FINANCE GUARANTEE CORPORATION 

TO DEBTOR’S JOINT MOTION FOR AN ORDER (I) SCHEDULING 

A HEARING TO CONSIDER THE ADEQUACY OF INFORMATION 

CONTAINED IN THE DISCLOSURE STATEMENT, (II) ESTABLISHING THE 

DEADLINE FOR FILING OBJECTIONS TO THE DISCLOSURE STATEMENT 

AND REPLIES THERETO, (III) APPROVING FORM OF NOTICE THEREOF, 

(IV) ESTABLISHING DOCUMENT DEPOSITORY PROCEDURES IN CONNECTION 

THEREWITH, AND (V) GRANTING RELATED RELIEF

National Public Finance Guarantee Corporation (“National”) hereby submits this

statement of support and reservation of rights with respect to (i) the Disclosure Statement for 

First Amended Title III Plan of Adjustment of the Puerto Rico Electric Power Authority (ECF No. 

3201, and including as further amended, the “Disclosure Statement”);

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(ii) the Motion of Puerto 

Rico Electric Power Authority for an Order (I) Scheduling a Hearing to Consider the Adequacy 

of Information Contained in the Disclosure Statement, (II) Establishing the Deadline for Filing 

Objections to the Disclosure Statement and Replies Thereto, (III) Approving Form of Notice 

Thereof, (IV) Establishing Document Depository Procedures in Connection Therewith, and 

(V) Granting Related Relief (ECF No. 3113, and including as further amended, the “Disclosure 

Statement Motion”); (iii) the Motion of Puerto Rico Electric Power Authority for Order 

Establishing, Among Other Things, Procedures and Deadlines Concerning Objections to 

Confirmation and Discovery in Connection Therewith (ECF No. 3114, the “Procedures Motion”); 

and (iv) all related documents, and respectfully states as follows:

RESERVATION OF RIGHTS

1. On December 16, 2022, the Financial Oversight and Management Board for

Puerto Rico (the “Oversight Board”) filed the Disclosure Statement Motion.

2. On February 9, 2023, the Oversight Board filed the Disclosure Statement for the 

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 Unless otherwise indicated, ECF numbers referenced in this Reservation of Rights refer to the docket in 

Case Number 17-04780-LTS.

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First Amended Title III Plan of Adjustment of the Puerto Rico Electric Power Authority, ECF 

No. 3200 (the “First Amended Plan”).

3. National is a party to a PREPA Plan Support Agreement, executed on February 

2, 2023 (the “National PSA”). National and its advisors continue to engage with the Oversight Board 

advisors with respect to certain further modifications to the First Amended Plan that are necessary and 

appropriate, but National supports the First Amended Plan to the extent it is consistent with the PREPA 

PSA.

4. Certain parties, such as the PREPA Bond Trustee (ECF No. 3187), the Ad Hoc 

Group of PREPA Bondholders (ECF No. 3189), and the Official Committee of Unsecured 

Creditors (ECF No. 3186), have filed objections to the Disclosure Statement that include 

arguments against the settlement embodied in the National PSA. These arguments, while 

substantively unfounded, are simply premature and irrelevant to the issue at hand: Whether the 

Disclosure Statement contains adequate information and should be approved. 

5. National hereby reserves all rights with respect to the Disclosure Statement, 

Disclosure Statement Motion, Procedures Motion, and all related documents, including 

National’s right to address any of the foregoing at any hearing or in any supplemental briefing 

related to the Disclosure Statement.

RESPECTFULLY SUBMITTED, this 10th day of February 2023.

WE HEREBY CERTIFY that on this same date a true and exact copy of this motion 

was filed with the Clerk of Court using the CM/ECF system, which will notify a copy to counsel 

of record. Also, a copy of this document will be notified via electronic mail to all case 

participants.

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ADSUAR MUÑIZ GOYCO

SEDA & PÉREZ-OCHOA, P.S.C.

By: /s/ Eric Pérez-Ochoa 

Eric Pérez-Ochoa

(USDC-PR No. 206314)

Luis Oliver-Fraticelli

(USDC-PR No. 209204)

Alexandra Casellas-Cabrera

(USDC-PR No. 301010)

PO BOX 70294

San Juan, PR 00936

Telephone: 787.756.9000

Facsimile: 787.756.9010

Email: epo@amgprlaw.com

 loliver@amgprlaw.com

acasellas@amgprlaw.com

Attorneys for National Public Finance

Guarantee Corporation

WEIL, GOTSHAL & MANGES LLP

By: /s/ Robert Berezin 

Matthew S. Barr* 

Jonathan Polkes* 

Robert Berezin* 

767 Fifth Avenue

New York, New York 10153

Telephone: (212) 310-8000

Facsimile: (212) 310-8007

Email: matt.barr@weil.com

jonathan.polkes@weil.com

robert.berezin@weil.com

Gabriel A. Morgan* 

700 Louisiana Street, Suite 1700

Houston, TX 77002

Telephone: (713) 546-5000

Facsimile: (713) 224-9511

Email: gabriel.morgan@weil.com

*Admitted pro hac vice

Attorneys for National Public Finance

Guarantee Corporation

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