Objection Deadline: January 23, 2018

 Hearing Date: February 7, 2018 

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,

Debtor.

PROMESA

Title III

No. 17 BK 3283-LTS

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

PUERTO RICO HIGHWAYS & TRANSPORTATION 

AUTHORITY,

Debtor.

PROMESA

Title III

No. 17 BK 3567-LTS

DECLARATION OF SALVATORE A. ROMANELLO IN SUPPORT OF NATIONAL 

PUBLIC FINANCE GUARANTEE CORPORATION’S MOTION FOR ENTRY OF AN 

ORDER UNDER BANKRUPTCY RULE 2004 AUTHORIZING LIMITED 

DISCOVERY OF THE GOVERNMENT DEVELOPMENT BANK FOR PUERTO RICO

Salvatore A. Romanello, pursuant to 28 U.S.C. § 1746, declares and states as follows:

1. I am a member of the bar of the State of New York, I am admitted to

practice before this Court pro hac vice and I am a partner with the firm of Weil, Gotshal & 

Manges LLP, attorneys for National Public Finance Guarantee Corporation (“National”).

2. I submit this declaration in support of National’s Motion for Entry of an Order 

under Bankruptcy Rule 2004 Authorizing Limited Discovery of the Government Development 

Bank for Puerto Rico.

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3. Attached hereto as Exhibit A is National’s Proposed Order.

4. Attached hereto as Exhibit B is a true and correct copy of the Puerto Rico 

Infrastructure Bank Agreement (“Bank Agreement”) establishing the PR SIB Trust Fund, dated 

June 12, 1998.

5. Attached hereto as Exhibit C is a true and correct copy of the Puerto Rico 

Highway and Transportation Authority (“PRHTA”) Subordinated Transportation Revenue Bonds 

(Series 1998) Offering Statement, dated July 15, 1998.

6. Attached hereto as Exhibit D is a true and correct copy of PRHTA Resolution No. 

98 - 06 (“1998 Resolution”), adopted February 26, 1998, authorizing and securing 

Transportation and Revenue Bonds, and establishing a 1998 Subordinated Bond Reserve Fund. 

7. Attached hereto as Exhibit E is a true and correct copy of the Cooperative 

Agreement entered among the Federal Highway Administration (the “FHWA”), the Federal 

Transit Administration (the “FTA”), the Puerto Rico Department of Transportation and Public 

Works (“the Department”), and PRHTA on December 22, 1997.

8. Attached hereto as Exhibit F is a true and correct copy of the audited financial 

statements of PRHTA for the years ended June 30, 2014 and 2013. 

9. Attached hereto as Exhibit G is a true and correct copy of the June 22, 2016 letter

sent by GDB President Melba Acosta-Febo to Diana Torres at Bank of New York Mellon 

(“BNY”) in response to the Demand for Payment from the PR SIB Trust Fund made by BNY as 

Fiscal Agent under the 1998 Subordinated Bonds in anticipation of a potential July 1, 2016 

PRHTA default.

10. Attached hereto as Exhibit H is a true and correct copy of a June 29, 2016 letter 

from National’s counsel, Salvatore A. Romanello, to Ms. Acosta-Febo, President of GDB.

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11. Attached hereto as Exhibit I is a true and correct copy of a June 30, 2016 letter 

from GDB’s counsel, Richard J. Cooper, responding to National’s June 29, 2016l letter. 

12. Attached hereto as Exhibit J is a true and correct copy of a July 13, 2016 letter 

from National’s counsel, Salvatore A. Romanello, responding to GDB’s June 30, 2016 letter.

13. Attached hereto as Exhibit K is a true and correct copy of a July 27, 2016 letter

from GDB Counsel, Michael H. Krimminger, replying to National’s July 13, 2016 letter.

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

Date: New York, New York

January 16, 2018 /s/ Salvatore A. Romanello

Salvatore A. Romanello

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