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

In re:

The Financial Oversight and Management Board for 

Puerto Rico, 

as representative of

The 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 

in Case No. 17 BK 4780-LTS and 

Main Docket 17 BK 3283-LTS

AMENDED SIXTEENTH SUPPLEMENTAL VERIFIED STATEMENT OF 

THE AD HOC GROUP OF PREPA BONDHOLDERS PURSUANT

TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2019

Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure 

(“Bankruptcy Rule 2019”), and the Order Further Amending Case Management Procedures

(the Case Management Order”) [Case No. 17-3283, Dkt. No. 20190], this amended 

supplemental verified statement (the “Amended Sixteenth Supplemental Statement”) is 

submitted by certain holders (the “Ad Hoc Group of PREPA Bondholders” or the “Ad Hoc 

Group”) of Power Revenue Bonds and Power Revenue Refunding Bonds (collectively, 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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“Bonds”) issued by the Puerto Rico Electric Power Authority (“PREPA”) under a trust 

agreement between PREPA and U.S. Bank National Association, as successor trustee, dated 

January 1, 1974, as amended and supplemented, in connection with the case (“PREPA Title III 

Case”) commenced by the above-captioned debtor on July 2, 2017 under Title III of PROMESA.

In support of the Amended Sixteenth Supplemental Statement, the Ad Hoc Group 

respectfully states as follows: 

1. As of the date of this Amended Sixteenth Supplemental Statement, in this 

Title III Case, the undersigned represent the Ad Hoc Group (each holder in the Ad Hoc Group, a 

“Member”). 

2. On or about June 26 and June 27, 2014, certain funds managed or advised 

by OppenheimerFunds, Inc. (“Oppenheimer”) and Franklin Advisers, Inc. (“Franklin”) 

retained Kramer Levin Naftalis & Frankel LLP (“Kramer Levin”) to challenge as 

unconstitutional the recently passed and soon to be enacted Puerto Rico Debt Enforcement and 

Recovery Act. Over the course of the next two months, certain holders of Bonds, including 

Franklin and Oppenheimer, contacted and then engaged Kramer Levin to represent a group of 

holders in connection with a potential restructuring of the Bonds. From time to time thereafter, 

certain additional holders of the Bonds have joined the Ad Hoc Group. 

3. On August 2, 2017, counsel to the Ad Hoc Group submitted the Verified 

Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to Bankruptcy Rule 2019 [Case 

No. 17-4780, Dkt. No. 164]. On November 7, 2017, counsel to the Ad Hoc Group submitted the 

First Supplemental Verified Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to 

Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. No. 407]. On December 

13, 2017, counsel to the Ad Hoc Group submitted the Second Supplemental Verified Statement of 

the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy Procedure

2019 [Case No. 17-4780, Dkt. No. 490]. On February 6, 2018, counsel to the Ad Hoc Group 

submitted the Third Supplemental Verified Statement of the Ad Hoc Group of PREPA 

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Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. 

No. 633]. On August 15, 2018, counsel to the Ad Hoc Group submitted corrected versions of the 

Verified Statement, the Second Supplemental Verified Statement and the Third Supplemental 

Verified Statement [Case No. 17-4780, Dkt. Nos. 939, 941 and 940, respectively]. On 

September 11, 2018, counsel to the Ad Hoc Group submitted the Fourth Supplemental Verified

Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy 

Procedure 2019 [Case No. 17-4780, Dkt. No. 959]. On November 29, 2018, counsel to the Ad 

Hoc Group submitted the Fifth Supplemental Verified Statement of the Ad Hoc Group of PREPA 

Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. 

No. 1037]. On May 10, 2019, counsel to the Ad Hoc Group submitted the Sixth Supplemental 

Verified Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of 

Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. No. 1237]. On August 23, 2019, counsel to 

the Ad Hoc Group Submitted the Seventh Supplemental Verified Statement of the Ad Hoc Group 

of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-

4780, Dkt. No. 1610]. On November 13, 2019, counsel to the Ad Hoc Group submitted the 

Eighth Supplemental Verified Statement of the Ad Hoc Group of PREPA Bondholders Pursuant 

to Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. No. 1735]. On 

November 27, 2019, counsel to the Ad Hoc Group submitted the Ninth Supplemental Verified 

Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy 

Procedure 2019 [Case No. 17-4780, Dkt. No. 1789]. On January 21, 2020, counsel to the Ad 

Hoc Group submitted the Tenth Supplemental Verified Statement of the Ad Hoc Group of PREPA 

Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. 

No. 1871]. On March 3, 2020, counsel to the Ad Hoc Group submitted the Eleventh 

Supplemental Verified Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to 

Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. No. 1926]. On July 3, 

2020, counsel to the Ad Hoc Group submitted the Twelfth Supplemental Verified Statement of 

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the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 

2019 [Case No. 17-4780, Dkt. No. 2043]. On April 30, 2021, counsel to the Ad Hoc Group 

submitted the Thirteenth Supplemental Verified Statement of the Ad Hoc Group of PREPA 

Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. 

No. 2470]. On February 22, 2022, counsel to the Ad Hoc Group submitted the Fourteenth

Supplemental Verified Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to 

Federal Rule of Bankruptcy Procedure 2019 [Case No. 17-4780, Dkt. No. 2721]. On April 20, 

2022, counsel to the Ad Hoc Group submitted the Fifteenth Supplemental Verified Statement of 

the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy Procedure 

2019 [Case No. 17-4780, Dkt. No. 2782] (the “Fifteenth Supplemental Statement”).

2

 On 

February 23, 2023, counsel to the Ad Hoc Group submitted the Sixteenth Supplemental Verified 

Statement of the Ad Hoc Group of PREPA Bondholders Pursuant to Federal Rule of Bankruptcy 

Procedure 2019 [Case No. 17-4780, Dkt. No. 3271] (the “Sixteenth Supplemental 

Statement”). Counsel to the Ad Hoc Group submits this Amended Sixteenth Supplemental 

Statement to update the disclosable economic interests currently held by Members of the Ad Hoc 

Group. 

4. The Members of the Ad Hoc Group hold, or are the investment advisors or 

managers of funds or accounts that hold, approximately $3.9 billion in aggregate principal 

amount of the uninsured Bonds, including approximately $369.5 million in aggregate principal 

amount of Monoline Matured Bonds (as defined in Exhibit A hereto), and approximately $206

million in aggregate principal amount of the insured Bonds, both as of February 16, 2023.

3

 In 

 2 The Ad Hoc Group files this Amended Sixteenth Supplemental Statement to note that the Ad Hoc Group’s 

holdings in the Fifteenth Supplemental Statement were overstated. Certain amounts held by Syncora Guarantee, Inc. 

(“Syncora”), which is owned by funds managed by GoldenTree Asset Management LP, were inadvertently included 

twice, totaling approximately $77 million in overstated holdings in the Fifteenth Supplemental Statement. 

Syncora’s holdings were not included in the Sixteenth Supplemental Statement, nor are they included in the 

Amended Sixteenth Supplemental Statement. 

3 Funds managed by GoldenTree Asset Management LP own Syncora which has insured or owns claims relating to 

approximately $178 million of PREPA bonds that are not included in the amounts listed in this Amended Sixteenth 

Supplemental Statement. Syncora’s holdings had been included previously in the Fifteenth Supplemental Statement.

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accordance with Bankruptcy Rule 2019 and the Case Management Order, the address and nature 

and amount of all disclosable economic interests for each Member is set forth in Exhibit A. The 

information contained in Exhibit A is based upon information provided by the Members to 

Kramer Levin and is subject to change.

5. As of the date of this Amended Sixteenth Supplemental Statement, the 

undersigned represent only the Ad Hoc Group in connection with the PREPA Title III Case and 

does not represent or purport to represent any other entities with respect to PREPA’s Title III 

Case. In addition, each Member of the Ad Hoc Group (a) does not assume any fiduciary or other 

duties to any other creditor or person and (b) does not purport to act, represent or speak on behalf 

of any other entities in connection with the PREPA Title III case.

6. Nothing contained in this Amended Sixteenth Supplemental Statement (or 

Exhibit A hereto) is intended to or should be construed to constitute (a) a waiver or release of 

any claims filed or to be filed against or interests in PREPA held by any Member, its affiliates or 

any other entity, or (b) an admission with respect to any fact or legal theory. Nothing herein 

should be construed as a limitation upon, or waiver of, any rights of any Member to assert, file 

and/or amend any proof of claim in accordance with applicable law and any orders entered in 

these cases. 

7. The undersigned verify that the foregoing is true and correct to the best of 

their knowledge.

8. The undersigned reserve the right to amend or supplement this Amended 

Sixteenth Supplemental Statement. 

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I HEREBY CERTIFY that I electronically filed the foregoing with the Clerk of the Court using 

the CM/ECF system, which will notify case participants. 

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, February 24, 2023.

 

TORO COLÓN MULLET P.S.C.

P.O. Box 195383

San Juan, PR 00919-5383

Tel.: (787) 751-8999

Fax: (787) 763-7760

/s/ Manuel Fernández-Bared

MANUEL FERNÁNDEZ-BARED 

USDC-PR No. 204204

E-mail: mfb@tcm.law

/s/ Linette Figueroa-Torres

LINETTE FIGUEROA-TORRES

USDC-PR No. 227104

E-mail: lft@tcm.law

/s/ Nayda Perez-Roman

NAYDA PEREZ-ROMAN

USDC–PR No. 300208

E-mail: nperez@tcm.law 

Counsel for the Ad Hoc Group of PREPA 

Bondholders

KRAMER LEVIN NAFTALIS & 

FRANKEL LLP

1177 Avenue of the Americas

New York, New York 10036

Tel.: (212) 715-9100

Fax: (212) 715-8000

/s/ Amy Caton

AMY CATON*

THOMAS MOERS MAYER*

ALICE J. BYOWITZ*

Email: acaton@kramerlevin.com

tmayer@kramerlevin.com 

abyowitz@kramerlevin.com

*Admitted Pro Hac Vice

Counsel for the Ad Hoc Group of 

PREPA Bondholders

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