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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 

THE PUERTO RICO ELECTRIC POWER AUTHORITY, 

Debtor. 

PROMESA Title III 

No. 17-BK-4780-LTS 

 

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 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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DECLARATION OF WILLIAM J. NATBONY IN SUPPORT OF ASSURED 

GUARANTY CORP. AND ASSURED GUARANTY MUNICIPAL CORP.’S (I) 

OBJECTION TO MODIFIED SECOND AMENDED TITLE III PLAN OF 

ADJUSTMENT OF THE PUERTO RICO ELECTRIC POWER AUTHORITY AND 

RELATED PROPOSED ORDER AND (II) PARTIAL JOINDER TO OBJECTIONS OF 

THE AD HOC GROUP OF PREPA BONDHOLDERS TO THE MODIFIED SECOND 

AMENDED TITLE III PLAN OF ADJUSTMENT OF THE PUERTO RICO ELECTRIC 

POWER AUTHORITY 

 I, William J. Natbony, state and declare as follows: 

1. I am Counsel at Cadwalader Wickersham & Taft LLP, attorneys for Assured 

Guaranty Corp. and Assured Guaranty Municipal Corp. (collectively, “Assured”) in the abovecaptioned proceedings, admitted to practice law in the State of New York and admitted to appear 

pro hac vice in this matter. I am fully familiar with the facts and procedural history concerning 

this and other PROMESA Title III litigation in which Assured is involved and have personal 

knowledge of the matters set forth herein. I respectfully submit this declaration (the 

“Declaration”), pursuant to the Third Amended and Restated Order Establishing, Among Other 

Things, Procedures and Deadlines Concerning Objections to Confirmation and Discovery in 

Connection Therewith [ECF No. 3565] (“Confirmation Procedures Order”), in support of 

Assured Guaranty Corp. and Assured Guaranty Municipal Corp.’s (I) Objection to Modified 

Second Amended Title III Plan of Adjustment of the Puerto Rico Electric Power Authority and 

related Proposed Order and (II) Partial Joinder to Objections of the Ad Hoc Group of PREPA 

Bondholders to the Modified Second Amended Title III Plan of Adjustment of the Puerto Rico 

Electric Power Authority (the “Assured Objection”). 

2. Attached hereto as Exhibit 1 is a true and correct copy of the cover page, 

certification page, and relevant excerpts from the deposition transcript of David Skeel, dated May 

3, 2023. 

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3. Attached hereto as Exhibit 2 is a true and correct copy of the cover page, 

certification page, and relevant excerpts from the deposition transcript of David Brownstein, dated 

May 16, 2023. 

4. Attached hereto as Exhibit 3 is a true and correct copy of the cover page, 

certification page, and relevant excerpts from the deposition transcript of Fernando Batlle, dated 

May 12, 2023. 

5. Attached hereto as Exhibit 4 is a true and correct copy of the Appellant’s Brief, 

Granada Wines, Inc. v. New England Teamsters and Trucking Industry Pension Fund, Case No. 

84-1518 (1st Cir. July 31, 1984). 

6. Attached hereto as Exhibit 5 is a true and correct copy of the Brief For DebtorsAppellees/Cross-Appellants, Fin. Oversight and Mgmt. Bd. for P.R. v. Cooperativa de Ahorro y 

Credito, Case No. 22-1119 (1st Cir. April 1, 2022). 

7. Attached hereto as Exhibit 6 is a true and correct copy of the Reply Brief For 

Debtors-Appellees/Cross-Appellants, Fin. Oversight and Mgmt. Bd. for P.R. v. Cooperativa de 

Ahorro y Credito, Case No. 22-1119 (1st Cir. April 22, 2022). 

8. Attached hereto as Exhibit 7 is a true and correct copy of National Pegs PREPA 

Settlement Recoveries Above 80% Amid Ongoing Look at Strategic Alternatives Including 

Potential Sale, REORG RESEARCH (Mar. 1, 2023). 

9. Attached hereto as Exhibit 8 is a true and correct copy of the MBIA Inc. 2022 Q4 

Earnings Call Transcript (Mar. 1, 2023). 

10. The Assured Objection cites to a number of exhibits not attached hereto. In those 

instances, Assured has provided docket cites and/or cites to publicly available websites accessible 

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to the Court. For the confirmation hearing, Assured will identify and list such exhibits and, to the 

extent directed by the Court, provide copies. 

11. I declare under penalty of perjury under 28 U.S.C. § 1746 that the foregoing is true 

and correct to the best of my knowledge. 

Executed on June 12, 2023. 

 /s/ William J. Natbony 

 William J. Natbony, Esq.* 

 

 CADWALADER, WICKERSHAM & TAFT LLP 

 200 Liberty Street 

New York, NY 10281 

Telephone: (212) 504-6000 

Facsimile: (212) 504-6666 

Email: bill.natbony@cwt.com

 

 * Admitted pro hac vice

 Attorneys for Assured Guaranty Corp. and 

 Assured Guaranty Municipal Corp.

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