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 REBUTTAL EXPERT REPORTS AND DISCLOSURES 

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-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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“Debtor”), pursuant to section 315(b) of the Puerto Rico Oversight, Management, and Economic 

Stability Act (“PROMESA”),2 respectfully submits its rebuttal expert reports 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”),3 and in accordance with 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. Pursuant to Federal Rule of Civil Procedure 26(a)(2)(B), and consistent with the 

witnesses identified in paragraph 1 of Debtor’s Rebuttal Expert Disclosures [ECF No. 3469], 

attached hereto are the following exhibits: Exhibit A is the rebuttal expert report of Dr. Jurgen 

Weiss, MBA, Ph.D.; Exhibit B is the rebuttal expert report of Dr. Andrew Wolfe, Ph.D.; and 

Exhibit C is the rebuttal expert report of Glenn R. George, MBA, PE, Ph.D. 

[Remainder of Page Intentionally Left Blank] 

 

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

3 Capitalized terms not defined herein shall have the meanings ascribed to them in the Plan.

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Dated: May 15, 2023 

New York, New York 

Respectfully submitted, 

/s/ Margaret A. Dale 

Martin J. Bienenstock 

Paul V. Possinger 

Ehud Barak

Margaret A. Dale 

Michael T. Mervis 

Julia D. Alonzo

Laura Stafford 

Javier F. Sosa 

(Admitted Pro Hac Vice) 

PROSKAUER ROSE LLP

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

Mee (Rina) Kim 

(Admitted Pro Hac Vice) 

PROSKAUER ROSE LLP

1001 Pennsylvania Avenue NW, Suite 600 

Washington, D.C. 20004 

Tel: (202) 416-6800 

Fax: (212) 969-2900 

Attorneys for the Financial Oversight and 

Management Board, as representative for 

PREPA 

/s/ Luis F. del Valle-Emmanuelli 

Luis F. del Valle-Emmanuelli 

USDC-PR No. 209514 

P.O. Box 79897 

Carolina, Puerto Rico 00984-9897 

Tel. 787.647.3503 

Fax. N/A 

dvelawoffices@gmail.com 

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Of Counsel for A&S Legal Studio, PSC 

434 Avenida Hostos 

San Juan, PR 00918 

Tel (787) 751-6764/763-0565 

Fax (787) 763-8260 

Co-Attorneys for the Financial 

Oversight and Management Board 

as Representative for PREPA

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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/ Luis F. del Valle-Emmanuelli 

Luis F. del Valle-Emmanuelli

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