UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

) PROMESA

In re )

)

Title III

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO

et al.,

1

)

) 

) 

) 

) 

) 

)

No. 17-BK-3283 (LTS)

Debtors. ) (Jointly Administered)

)

SUPPLEMENTAL DECLARATION OF EYCK O. LUGO PURSUANT TO 

THE PUERTO RICO RECOVERY ACCURACY IN DISCLOSURE ACT 

I, Eyck O. Lugo, hereby declare under penalty of perjury:

1. I am a Senior Counsel with EDGE Legal, LLC (formerly EDGE Legal 

Strategies, PCS and hereinafter “ELS”), a law firm with its principal offices at 252 

Ponce de Leon Avenue, Suite 1200, in San Juan, Puerto Rico. I am authorized to make 

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 (the “Commonwealth”) (Bankruptcy Case No. 17-BK3283-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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this Declaration on behalf of myself and ELS in compliance with the Order Approving 

List of Material Interested Parties Pursuant to the Puerto Rico Recovery Accuracy in 

Disclosures Act (Docket No. 20467) (the “PRRADA Compliance Order”), entered 

on March 30, 2022. This Declaration is based on my personal knowledge as well 

information provided by other ELS personnel and, if called to testify, I could and would 

testify competently to the written statements made in this Declaration.

2. The Court appointed our client, Brady C. Williamson (the “Fee 

Examiner”) in the Order Pursuant to PROMESA Sections 316 and 317 and 

Bankruptcy Code Section 105(A) Appointing a Fee Examiner and Related Relief

(Docket No. 1416) (the “Fee Examiner Order”)

3. I am licensed to practice law in Puerto Rico and New York, and I am a 

member in good standing of the Bar of the Commonwealth of Puerto Rico and the New 

York State Bar. I am also admitted to practice before the U.S. Court of Appeal for the 

First Circuit, and U.S. District Court for the District of Puerto Rico and the U.S. 

Bankruptcy Court for the District of Puerto Rico. 

4. On May 16, 2022, I submitted the Declaration of Eyck O. Lugo Pursuant 

to the Puerto Rico Recovery and Accuracy in Disclosures Act (Docket No. 20843) 

(“ELS PRRADA Declaration”).

5. On May 20, 2022, I received a communication from the Office of the 

United States Trustee requesting clarification of certain disclosure items listed in the

ELS PRRADA Declaration (“UST Inquiries”). In response thereto, I hereby 

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supplement the ELS PRRADA Declaration as set forth in the enclosed Attachment A: 

Responses to UST Inquiries. 

6. Other than as supplemented herein, all representations and disclosures in 

the initial ELS PRRADA Declaration remain true and correct.

WE HEREBY CERTIFY that on this date, we electronically filed the 

foregoing motion with the Clerk of the Court using the CM/ECF system that will send 

notification of such filing to all attorneys of record registered in the use of the CM/ECF 

system.

In San Juan, Puerto Rico, this 9th day of August 2022.

EDGE Legal, LLC

(formerly EDGE Legal Strategies, PSC)

s/Eyck O. Lugo

Eyck O. Lugo

252 Ponce de León Avenue

Citibank Tower, 12th Floor

San Juan, PR 00918

Telephone: (787) 522-2000

Facsimile: (787) 522-2010

Puerto Rico Counsel for Fee Examiner

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ATTACHMENT A: 

RESPONSES TO UST INQUIRIES 

Initial ELS PRRADA 

Declaration

UST Inquiry Response

ELS provided legal services 

to the Puerto Rico Public 

Building Authority and to the 

Financial Oversight and 

Management Board for 

Puerto Rico in the past 5 

years. The last services 

offered to the Puerto Rico 

Public Building Authority 

were in June 2018. The last 

services offered to the 

Financial Oversight and 

Management Board for 

Puerto Rico were in June 

2020. Currently neither ELS, 

nor I currently represent any 

of the Debtors.

You do not state whether 

these connections represent 

any interest adverse to the 

Fee Examiner. The 

Declaration also does not 

describe the nature of the 

legal services provided to the 

PBA and the FOMB; thus, we 

are unable to determine 

whether these may result in 

any adverse interest to the 

Debtors or the Fee Examiner. 

The representation of these 

clients was in no way adverse 

to the Fee Examiner. 

ELS provided general 

litigation services to the 

Puerto Rico Public Building 

Authority, but withdrew legal

representation of the agency 

in June 2018. No work has 

been done for the agency 

since then.

ELS provided Title V 

permitting legal consulting

services to the Financial 

Oversight Management 

Board until June 2020. These 

services were performed 

exclusively by Atty. Carlos 

López-Freytes, a former “of 

counsel” for the firm, who 

ended his relationship with 

ELS on June 30, 2020.

On its Application to Employ, 

ELS disclosed that it 

provided “general legal 

services” to the American 

Federation of Teachers 

(“AFT”) on “matters wholly 

unrelated to the Debtors or 

these Chapter 11 

cases.” (Docket No. 1549-1, 

p. 9). 

ELS did not disclose the 

connection to the AFT on its 

subsequent Declaration, 

despite it being filed less than 

five years after the 

Application to Employ.

You must amend the 

Declaration to disclose 

whether ELS still provides

legal services to the AFT, and 

whether these are related to 

matters concerning the 

Debtors, the Title III cases, or 

the Fee Examiner’s duties.

ELS still provides legal 

services to the AFT, which 

are wholly unrelated to the 

Debtors, the Title III cases or 

the Fee Examiner’s duties.

ELS services to the AFT are 

related to its relationship and 

interactions with its local 

union affiliate, the Puerto 

Rico Teachers Association. 

ELS does not represent AFT 

in any matters concerning 

Debtors, the Title III cases or 

the Fee Examiner’s duties.

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Our research reveals that ELS 

represented the following 

parties who appear on the 

Amended MIP List:

United States v. Municipality 

of San Juan, 14-cv-1476 

(D.P.R.). ELS represented the 

Municipality of San Juan, 

which appears on Schedule 

8(A) of the Amended MIP 

List, as a material creditor of 

the Commonwealth; and 

Schedule 8(D), as a material 

creditor of PREPA;

Firstbank of Puerto Rico v. 

Rosta Family LP, 16-cv01816 (D.P.R.). ELS 

represented Banco Popular de 

Puerto Rico, as successor in 

interest to Doral Bank and 

other “Doral-related” 

entities. Banco Popular 

appears on Schedules 8(A) 

and (D) of the Amended MIP 

List, as a material creditor of 

the Commonwealth and 

PREPA, respectively; and on 

Schedules 9(B), (D), (E), and 

(F), as an inactive claimant of 

ERS, PREPA, HTA, and 

COFINA, respectively;

In re Ocasio Serrano, 17-bk03257 (Bankr. D.P.R.). ELS 

also represented Banco 

Popular de Puerto Rico;

Continental Casualty 

Company v. Angelet-Frau, 16-

cv-02656 (D.P.R.); and 

Continental Casualty 

Company v. WEG Electric 

Corp., 19-cv-1311 

(D.P.R). ELS represented 

Continental Casualty 

Company, which appears on 

Schedule 8(E) as a material 

Representation of 

Municipality of San Juan:

ELS represented the 

Municipality in several 

environmental law matters 

until June 30, 2020, date in 

which Atty. Carlos LópezFreytes concluded his 

association with the firm. 

These services were 

performed mainly by Atty.

López-Freytes with support 

of ELS staff, as necessary.

The services performed by 

ELS to the Municipality were 

not related to Debtors, the 

Title III cases or the Fee 

Examiner’s duties. ELS no 

longer represents the 

Municipality in any matter.

Representation of Banco 

Popular de Puerto Rico and 

First Bank Puerto Rico:

ELS is panel counsel for 

Fidelity National Title Group 

and, as such, routinely 

represent mortgage lenders in 

a wide array of matters 

related to their insured 

mortgage interests. These 

matters often include 

representation of mortgage

lenders in judicial 

proceedings in defense of a 

particular insured mortgage 

interest.

Our representation of Banco 

Popular de Puerto Rico and 

First Bank Puerto Rico fall 

within the purview of our role 

as panel counsel for Fidelity 

National Title Group. The 

services provided in the 

defense of these lenders are 

not related to Debtors, the 

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creditor of HTA; and 

Schedules 9(E) and (F), as an 

inactive claimant of COFINA 

and HTA, respectively.

Although the matters above 

were unrelated to the Title III 

cases, ELS did not disclose its 

connections to the 

Municipality of San Juan, 

Banco Popular, or Continental 

Casualty Company, in its 

Declaration.

Title III cases or the Fee 

Examiner’s duties.

Representation of

Continental Casualty 

Company:

ELS has served as counsel for 

Continental Casualty 

Company in both insurance 

subrogation and recovery 

actions in Puerto Rico. None 

of the litigations in which 

ELS has been involved in on 

behalf of Continental 

Casualty Company have 

involved Debtors, nor are 

related in any wat to the Title 

III cases or the Fee 

Examiner’s duties.

At present, ELS has no active 

matters for Continental 

Casualty Company.

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