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, et al., 

Debtors.1

PROMESA 

Title III 

No. 17-BK-3283-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 

No. 17-BK-4780-LTS 

(Jointly Administered) 

DEBTOR’S REBUTTAL EXPERT DISCLOSURES 

The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), 

as the sole Title III representative of the Puerto Rico Electric Power Authority (“PREPA” or the 

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); (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). 

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“Debtor”), pursuant to section 315(b) of the Puerto Rico Oversight, Management, and Economic 

Stability Act (“PROMESA”),2 respectfully submits its rebuttal expert witness disclosures in 

accordance with accordance with paragraphs 3 and 24 of the Amended and Restated Order 

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

Confirmation and Discovery in Connection Therewith [ECF No. 3305] (the “Confirmation 

Procedures Order”) and Federal Rules of Civil Procedure 26(a)(2)(A). 

1. The Debtor provides herein the identity of the following rebuttal expert witnesses 

who may provide opinion testimony on behalf of the Debtor in support of confirmation of the 

Modified Second Amended Title III Plan of Adjustment of the Puerto Rico Electric Power Authority

[ECF No. 3296] (as it may be amended, modified, or supplemented, the “Plan”): 

a. Dr. Jurgen Weiss, MBA, PhD, Academic Advisor, The Brattle Group 

and/or William P. Zarakas, Principal, The Brattle Group 

b. Dr. Andrew Wolfe, PhD, Adjunct Professor (Retired), Rice University’s 

Baker School of Public Policy 

c. Glenn R. George, MBA, PE, PhD, Partner, Bates White Economic 

Consulting 

2. The Oversight Board reserves all rights regarding these rebuttal expert witness 

disclosures. 

[Remainder of Page Intentionally Left Blank] 

 

2 PROMESA is codified at 48 U.S.C. §§ 2101–2241.

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Dated: May 8, 2023 

New York, New York 

Respectfully submitted, 

/s/ Margaret A. Dale 

Martin J. Bienenstock 

Paul V. Possinger 

Ehud Barak

Margaret A. Dale 

Michael T. Mervis 

Julia D. Alonzo

Laura Stafford 

Javier F. Sosa 

(Admitted Pro Hac Vice) 

PROSKAUER ROSE LLP

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

Attorneys for the Financial Oversight and 

Management Board, as representative for 

PREPA 

/s/ Hermann D. Bauer 

Hermann D. Bauer 

USDC No. 215205 

O’NEILL & BORGES LLC 

250 Muñoz Rivera Ave., Suite 800 

San Juan, PR 00918-1813 

Tel: (787) 764-8181 

Fax: (787) 753-8944 

Co-Attorneys for the Financial 

Oversight and Management Board, as 

representative for PREPA

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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 

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