UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

 as representative of : Case No. 17-BK-3283 (LTS) 

 : 

THE COMMONWEALTH OF PUERTO RICO, et al., : 

: 

(Jointly Administered) 

Debtors.1

 : 

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 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

 as representative of : Case No. 17-BK-4780 (LTS) 

 : 

PUERTO RICO ELECTRIC POWER AUTHORITY, et al., : 

: 

Debtors. : 

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NOTICE OF FILING OF PROPOSED LETTER OF OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS WITH RESPECT TO SECOND AMENDED TITLE III 

PLAN OF ADJUSTMENT OF THE PUERTO RICO ELECTRIC POWER AUTHORITY 

 

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-5233 (LTS)) (Last Four Digits of Federal Tax ID: 3801) 

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

Case:17-03283-LTS Doc#:23637 Filed:02/27/23 Entered:02/27/23 17:03:11 Desc: Main

Document Page 1 of 3
PLEASE TAKE NOTICE that, on December 16, 2022, the Financial Oversight and 

Management Board for Puerto Rico (the “Oversight Board”) filed the Title III Plan of 

Adjustment of the Puerto Rico Electric Power Authority [Docket No. 23094] (as amended, the 

“Plan”)2

 and the related Disclosure Statement for Title III Plan of Adjustment of the Pueto Rico 

Electric Powr Authority [Dockt No. 23097] (as amended, the “Disclosure Statement”).3

PLEASE TAKE FUTHER NOTICE that, on February 3, 2023, the Official Committee 

of Unsecured Creditors (the “Committee”)4

 filed its Omnibus Objection of Official Committee of 

Unsecured Creditors to (I) Disclosure Statement for Title III Plan of Adjustment of Puerto Rico 

Electric Power Authority and (II) Related Motions [Docket No. 23477] (the “Preliminary 

Objection”), and, on February 17, 2023, the Committee filed its Supplemental Objection of 

Official Committee of Unsecured Creditors in Response to Disclosure Statement for First 

Ameded Title III Plan of Adjustment of the Puerto Rico Electric Power Authority [Docket No. 

23565], (the “Supplemental Objection” and, together with the Preliminary Objection, the 

“Disclosure Statement Objections”). 

PLEASE TAKE FURTHER NOTICE that, as indicated in the Disclosure Statement 

Objections, the Committee hereby files a draft of its proposed letter (the “Letter”), to be included 

 

2

 On February 9, 2023, the Oversight Board filed the First Amended Tittle III Plan of Adjustment of the Puerto 

Rico Electric Power Authority [Docket No. 23506] and, on February 26, 2023, the Oversight Board filed the 

Second Amended Tittle III Plan of Adjustment of the Puerto Rico Electric Power Authority [Docket No. 23630]. 

Capitalized terms used but not otherwise defined herein have the meanings set forth in the Plan or the Disclosure 

Statement. 

3

 On February 9, 2023, the Oversight Board filed the Disclosure Statement for First Amended Title III Plan of 

Adjustment of the Puerto Rico Electric Power Authority [Docket No. 23507], on February [__], 2023, the 

Oversight Board filed the Modified Disclosure Statement for First Amended Title III Plan of Adjustment for the 

Puerto Rico Electric Power Authority [Docket No. 23584], and, on February 27, 2023, the Oversight Board filed 

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

Authority [Docket No. 23631]. 

4

 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and 

COFINA 

Case:17-03283-LTS Doc#:23637 Filed:02/27/23 Entered:02/27/23 17:03:11 Desc: Main

Document Page 2 of 3
in the solicitation package, recommending that holders of allowed General Unsecured Claims 

vote to reject the Plan. A copy of the Letter is attached hereto as Exhibit A. The Committee 

also shared a draft of the Letter with counsel for the Oversight Board on Thursday, February 23, 

2023. 

Dated: February 27, 2023 

 San Juan, Puerto Rico 

/s/ G. Alexander Bongartz .

PAUL HASTINGS LLP 

Luc A. Despins, Esq. (Pro Hac Vice) 

Nicholas A. Bassett, Esq. (Pro Hac Vice) 

G. Alexander Bongartz, Esq. (Pro Hac Vice) 

200 Park Avenue 

New York, New York 10166 

Telephone: (212) 318-6000 

lucdespins@paulhastings.com 

nicholasbassett@paulhastings.com 

alexbongartz@paulhastings.com 

Counsel to the Official Committee of Unsecured 

Creditors

- and – 

/s/ Juan J. Casillas Ayala .

CASILLAS, SANTIAGO & TORRES LLC 

Juan J. Casillas Ayala, Esq., USDC - PR 218312 

Israel Fernández Rodríguez, Esq. (USDC - PR 

225004) 

Juan C. Nieves González, Esq. (USDC - PR 231707) 

Cristina B. Fernández Niggemann, Esq. (USDC - PR 

306008) 

PO Box 195075 

San Juan, Puerto Rico 00919-5075 

Telephone: (787) 523-3434 Fax: (787) 523-3433 

jcasillas@cstlawpr.com 

ifernandez@cstlawpr.com 

jnieves@cstlawpr.com 

cfernandez@cstlawpr.com 

Local Counsel to the Official Committee of 

Unsecured Creditors

Case:17-03283-LTS Doc#:23637 Filed:02/27/23 Entered:02/27/23 17:03:11 Desc: Main

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