UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

INFORMATIVE MOTION SUBMITTING REDLINES 

OF (I) SECOND AMENDED TITLE III PLAN OF ADJUSTMENT 

OF THE PUERTO RICO ELECTRIC POWER AUTHORITY AND (II) 

DISCLOSURE STATEMENT FOR SECOND AMENDED TITLE III PLAN 

OF ADJUSTMENT OF THE PUERTO RICO ELECTRIC POWER AUTHORITY 

To the Honorable United States District Judge Laura Taylor Swain: 

1. On February 26, 2023, the Oversight Board, as Title III representative of PREPA, 

 

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 (Bankruptcy Case No. 17-bk-3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) 

Puerto Rico Highways and Transportation Authority (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 

(Bankruptcy Case No. 17-bk-3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power 

Authority (Bankruptcy Case No. 17-bk-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico 

Public Buildings Authority (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-bk-3283-LTS 

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as a representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

 Debtor. 

PROMESA Title III 

Case No. 17-bk-4780-LTS 

Case:17-03283-LTS Doc#:23634 Filed:02/27/23 Entered:02/27/23 11:00:15 Desc: Main

Document Page 1 of 4
filed the Second Amended Title III Plan of Adjustment of the Puerto Rico Electric Power Authority

[ECF No. 3278] (the “Plan”). Contemporaneously therewith, the Oversight Board filed the 

Disclosure Statement for Second Amended Title III Plan of Adjustment of the Puerto Rico Electric 

Power Authority [ECF No. 3279] (the “Disclosure Statement”). 

2. For the convenience of the Court and parties-in-interest, attached hereto as Exhibit 

A is a redline of the Plan compared to the First Amended Title III Plan of Adjustment of the Puerto 

Rico Electric Power Authority [ECF No. 3200], and attached hereto as Exhibit B is a redline of 

the Disclosure Statement compared to the Modified Disclosure Statement for the First Amended 

Title III Plan of Adjustment of the Puerto Rico Electric Power Authority [ECF No. 3245]. 

3. The Plan has been amended to, among other things, (1) incorporate additional 

comments provided by National, including edits with respect to the Legacy Charge and Series B 

Bonds,2 (2) incorporate the number of Settling Bondholders now that the Settlement Offer 

Deadlines has been reached, (3) remove the $800 million estimate of the Unsecured Claims Pool, 

addressing concerns raised by the Official Committee of Unsecured Creditors, and (4) address 

comments from various creditors raised in objections (and supplemental objections) to the 

Disclosure Statement Motion [ECF No. 3113]. 

4. The Disclosure Statement has been updated to reflect the amendments to the Plan, 

disclose the preliminary results of the number and percentage of Settling Bondholders, and to 

incorporate, in some form, virtually all of the proposed revisions from objectors to the Disclosure 

Statement Motion. 

 

2

 Capitalized terms used but not otherwise defined herein shall have the meaning given such terms in the Plan. 

Case:17-03283-LTS Doc#:23634 Filed:02/27/23 Entered:02/27/23 11:00:15 Desc: Main

Document Page 2 of 4
Dated: February 27, 2023 

 San Juan, Puerto Rico 

Respectfully submitted, 

/s/ Martin J. Bienenstock

Martin J. Bienenstock 

Ehud Barak 

Margaret A. Dale 

Jeffrey W. Levitan 

Michael T. Mervis 

Daniel S. Desatnik 

Elliot R. Stevens 

(Admitted Pro Hac Vice) 

PROSKAUER ROSE LLP

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

Paul V. Possinger 

(Admitted Pro Hac Vice) 

PROSKAUER ROSE LLP

70 West Madison, Suite 3800 

Chicago, IL 60602 

Tel: (312) 962-3550 

Fax: (312) 962-3551 

Attorneys for the Financial 

Oversight and Management Board 

as sole Title III representative for PREPA 

 O’NEILL & BORGESS LLC 

/s/ Hermann D. Bauer 

Hermann D. Bauer 

USDC No. 215205 

250 Muñoz Rivera Ave.,Suite 800 

San Juan, PR 00918-1813 

Tel: (787) 764-8181 

Fax: (787) 753-8944 

Attorneys for the Financial 

Oversight and Management Board 

as representative for PREPA 

 

Case:17-03283-LTS Doc#:23634 Filed:02/27/23 Entered:02/27/23 11:00:15 Desc: Main

Document Page 3 of 4
CERTIFICATE OF SERVICE 

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 send notifications of such filing to all CM/ECF 

participants in this case. 

/s/ Hermann D. Bauer 

Hermann D. Bauer 

 

Case:17-03283-LTS Doc#:23634 Filed:02/27/23 Entered:02/27/23 11:00:15 Desc: Main

Document Page 4 of 4