IN THE 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 IDENTIFICATION OF EXPERT WITNESSES

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-BK3567-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-BK3566-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 identification of expert witnesses (this 

“Expert Identification”) in 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) and 26(a)(2)(C). 

1. The Debtor provides herein the identity of the following expert witness 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”), not including any 

rebuttal expert witnesses, pursuant to Federal Rule of Civil Procedure 26(a)(2)(B):

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

Consulting. Dr. George may provide testimony regarding (i) the methodology applied by the 

Oversight Board in determining the Legacy Charge incorporated in the Plan of Adjustment for the 

Puerto Rico Electric Power Authority (as it may be amended, modified, or supplemented, the 

“Plan”), (ii) the reasonableness of the Legacy Charge in balancing stakeholder interests and risks, 

and (iii) the consistency of the Legacy Charge and the methodology used to determine the Legacy 

Charge with principles of just and reasonable rates.

2. Further to the disclosure made in Debtor’s Preliminary List of Witnesses to be 

Offered in Support of Confirmation of Plan of Adjustment [ECF No. 3329], the following witnesses 

may provide testimony on behalf of the Debtor in support of confirmation of the Plan pursuant to 

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

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Federal Rule of Civil Procedure 26(a)(2)(C):3

a. David Brownstein, Managing Director at Citigroup Global Markets Inc.

b. Sheva Levy, Principal at Ernst & Young, LLP

c. Juan Santambrogio, Managing Director at Ernst & Young, LLP

d. Ojas Shah, Partner at McKinsey & Company

e. Mark Shankweiler, Managing Director of Berkeley Research Group, LLC

f. William P. Zarakas, Principal at Brattle Group Inc.

3. The Oversight Board reserves the right to amend this Expert Identification in 

accordance with the terms set forth in the Confirmation Procedures Order.

[Remainder of Page Left Intentionally Blank]

3 In accordance with paragraph 25 of the Confirmation Procedures Order, and as stated by the 

Court at the April 5, 2023 hearing on discovery disputes (Hr’g. Tr. 55:10-20), the disclosures 

required for all witnesses designated under Federal Rule of Civil Procedure 26(a)(2)(C) shall be 

served on April 28, 2023.

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Dated: April 14, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Martin J. Bienenstock

Martin J. Bienenstock

Ehud Barak

Margaret A. Dale

Michael T. Mervis

Daniel S. Desatnik

Elliot R. Stevens

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Paul V. Possinger

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

70 West Madison, Suite 3800

Chicago, IL 60602

Tel: (312) 962-3550

Fax: (312) 962-3551

Attorneys for the Financial 

Oversight and Management Board 

as representative for the Debtor

/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-Attorney for the Financial Oversight and 

Management Board as representative for the 

Debtor

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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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