UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

PROMESA Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO et al., 

Debtors.1

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 

Court Filing Relates Only to PREPA 

and Shall only be Filed Case No. 17-

BK-4780 (LTS) and Main Case 17-

BK-3283 (LTS) 

 

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); and (v) Puerto Rico Electric 

Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 04780-LTS) (Last Four Digits of 

Federal Tax ID: 3747). 

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JOINDER OF U.S. BANK NATIONAL ASSOCIATION IN ITS CAPACITY AS PREPA 

BOND TRUSTEE TO THE URGENT OBJECTION OF AD HOC GROUP OF PREPA 

BONDHOLDERS TO URGENT MOTION OF THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO FOR ENTRY OF ORDER

CLARIFYING SCOPE OF INTERIM HEARING ON URGENT JOINT MOTION OF 

THE FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO 

AND THE PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY 

AUTHORITY FOR ENTRY OF INTERIM AND FINAL ORDERS (A) AUTHORIZING 

POSTPETITION SECURED FINANCING, (B) GRANTING PRIMING LIENS AND 

PROVIDING SUPERPRIORITY ADMINISTRATIVE EXPENSE CLAIMS, (C) 

MODIFYING THE AUTOMATIC STAY, (D) SCHEDULING A FINAL HEARING, AND 

(E) GRANTING RELATED RELIEF

TO THE HONORABLE COURT: 

 U.S. Bank National Association, solely in its capacity as successor trustee (the 

“PREPA Bond Trustee”) under the Trust Agreement dated as of January 1, 1974 , between it 

and the Puerto Rico Electric Power Authority (“PREPA”), respectfully submits this joinder (the 

“Joinder”) to the Urgent Objection of Ad Hoc Group of PREPA Bondholders to Urgent 

Motion of the Financial Oversight and Management Board for Puerto Rico for Entry of 

Order Clarifying Scope of Interim Hearing on Urgent Joint Motion of the Financial Oversight 

and Management Board for Puerto Rico, and the Puerto Rico Fiscal Agency and Financial 

Advisory Authority for Entry of Interim and Final Orders (A) Authorizing Postpetition Secured 

Financing, (B) Granting Priming Liens and Providing Superpriority Administrative Expense 

Claims, (C) Modifying the Automatic Stay, (D) Scheduling a Final Hearing, and (E) Granting 

Related Relief (Docket No. 558) (the “Objection”).2

The PREPA Bond Trustee agrees with the arguments put forth by the PREPA 

Bondholders. The Oversight Board’s Scope Motion is an inappropriate attempt to limit 

 

2

 Capitalized terms not defined herein shall have the meaning ascribed to them in the 

Objection. 

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meritorious arguments and objections to be raised in opposition to the Loan Motion. 

Accordingly, the PREPA Bond Trustee joins the Ad Hoc Group of PREPA Bondholders in 

respectfully requesting that the Oversight Board’s Scope Motion be DENIED. 

RESPECTFULLY SUBMITTED, 

In San Juan, Puerto Rico, today February 1, 2018. 

 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 notify the attorneys of record. 

RIVERA, TULLA AND FERRER, LLC 

/s Eric A. Tulla 

Eric A. Tulla 

USDC-DPR No. 118313 

Email: etulla@ riveratulla.com

/s Iris J. Cabrera-Gómez 

Iris J. Cabrera-Gómez 

USDC-DPR No. 221101 

Email: icabrera@riveratulla.com

Rivera Tulla & Ferrer Building 

50 Quisqueya Street 

San Juan, PR 00917-1212 

Tel: (787)753-0438 

Fax: (787)767-5784 (787)766-0409 

AND 

MASLON LLP 

By: /s/ Clark T. Whitmore 

Clark T. Whitmore (admitted pro hac vice) 

Jason M. Reed (admitted pro hac vice) 

90 South Seventh Street, Suite 3300 

Minneapolis, MN 55402 

Telephone: 612-672-8200 

Facsimile: 612-672-8397 

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E-Mail: clark.whitmore@maslon.com

jason.reed@maslon.com

ATTORNEYS FOR U.S. BANK NATIONAL 

ASSOCIATION, IN ITS CAPACITY AS PREPA 

BOND TRUSTEE 

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