IN THE UNITED STATES BANKRUPTCY 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

Case 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

Case No. 17 BK 4780-LTS

SREAEE’S JOINDER TO RELIEF SOUGHT IN URGENT MOTION TO FILE 

SUPPLEMENTAL OBJECTION TO DISCLOSURE STATEMENT FOR FIRST 

AMENDED TITLE III PLAN OF ADJUSTMENT

[SPACE INTENTIONALLY LEFT BLANK]

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 4780-LTS) (Last Four Digits of Federal 

Tax ID: 3747). (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations.)

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TO THE HONORABLE DISTRICT COURT:

COMES NOW Sistema de Retiro de los Empleados de la Autoridad de Energía Eléctrica, 

(“SREAEE”), duly represented by the undersigned counsel and respectfully states as follows: 

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

(“Oversight Board”), as representative of the Puerto Rico Electric Power Authority 

(“PREPA”), filed its Title III Plan of Adjustment of the Puerto Rico Electric Power Authority, 

[Case No. 17-0480-LTS, Docket No. 3110], and its Disclosure Statement for Title III Plan of 

Adjustment of the Puerto Rico Electric Power Authority (“Disclosure Statement”). [Docket 

No. 3111] The deadline to object the Disclosure Statement was February 3, 2023. [Docket No. 

3119] SREAEE filed its objection within the deadline. [Docket No. 3179]

2. Nonetheless, on February 9, 2023, the Oversight Board filed the First Amended Plan of 

Adjustment of the Puerto Rico Electric Power Authority (“Plan”) [Docket No. 3200] and 

subsequently a Disclosure Statement for First Amended Title III Plan of Adjustment of the 

Puerto Rico Electric Power Authority (“Amended Disclosure Statement”). [Docket No. 3201]

3. On February 10, 2023, the Ad Hoc Group pf PREPA Bondholders filed an Urgent Motion to 

File Supplemental Objection to Disclosure Statement for First Amended Title III Plan of 

Adjustment of the Puerto Rico Electric Power Authority (“Motion”). [Docket No. 3204] As 

such, SREAEE respectfully submits this Joinder to the relief sought in the Motion.

4. As the Amended Disclosure Statement introduces significant changes to its prior iteration, but 

does not fully address SREAEE’s objection, SREAEE joins the relief sought in the Motion and 

also requests leave to file a supplemental objection by February 17, 2023, at 3:00pm (AST). 

As noted in the Motion, the Oversight Board has consented to this relief. 

WHEREFORE, in view of the foregoing, SREAEE joins the Motion and requests relief in 

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accordance with this Joinder.

WE HEREBY CERTIFY that on this same date we electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system, which will send notification of such filing to all 

participants and Standard Parties. A courtesy copy of this Motion will be delivered to the Court by 

email to SwainDPRCorresp@nysd.uscourts.gov as provided in First Amended Standing Order.

In Ponce, Puerto Rico, this 13th day of February, 2023.

ORTIZ MENDOZA & FARINACCI FERNÓS, LLC

Edificio Banco Cooperativo Plaza 

623 Ponce de León Ave., Suite 701-B

San Juan, PR 00917-4820

Tel: 787-963-0404

BUFETE EMMANUELLI, C.S.P.

P.O. Box 10779

Ponce, Puerto Rico 00732

Tel.: 787-848-0666

Fax: 1-787-841-1435

/s/Rafael A. Ortiz-Mendoza 

Rafael A. Ortiz-Mendoza, Esq. 

USDC-PR: 229103

rafael.ortiz.mendoza@gmail.com

/s/Rolando Emmanuelli-Jiménez 

Rolando Emmanuelli-Jiménez, Esq.

USDC: 214105

rolando@emmanuelli.law

Co-counsel to SREAEE

/s/Jessica E. Méndez-Colberg 

Jessica E. Méndez-Colberg, Esq.

USDC: 302108

jessica@emmanuelli.law

/s/ Zoé C. Negrón-Comas

Zoé C. Negrón-Comas, Esq. 

USDC: 308702

zoe@emmanuelli.law

Co-counsel to SREAEE

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