UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

INFORMATIVE MOTION SUBMITTING

REDLINES OF (I) MODIFIED SECOND AMENDED

TITLE III PLAN OF ADJUSTMENT OF THE PUERTO

RICO ELECTRIC POWER AUTHORITY AND (II) DISCLOSURE

STATEMENT FOR MODIFIED 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 (Bankruptcy Case No. 17-bk-3284-LTS) (Last Four Digits of Federal Tax ID: 8474); 

(iii) Puerto Rico Highways and Transportation Authority (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 (Bankruptcy Case No. 17-bk-3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico 

Electric Power Authority (Bankruptcy Case No. 17-bk-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and 

(vi) Puerto Rico Public Buildings Authority (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).

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

Case No. 17-bk-3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as a representative of

PUERTO RICO ELECTRIC POWER AUTHORITY,

Debtor.

PROMESA Title III

Case No. 17-bk-4780-LTS

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To the Honorable United States District Judge Laura Taylor Swain:

1. On February 26, 2023, the Oversight Board, as Title III representative of PREPA, 

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

[Case No. 17-4780, ECF No. 3278]2 (the “Second Amended Plan”). Contemporaneously 

therewith, the Oversight Board filed the Disclosure Statement for Second Amended Title III Plan 

of Adjustment of the Puerto Rico Electric Power Authority [ECF No. 3279] (the “Disclosure 

Statement”).

2. On February 28, 2023, this Court held a hearing to consider, among other things,

the adequacy of the information contained in the Disclosure Statement.

3. At the hearing, this Court directed the Oversight Board to incorporate certain 

revisions to the Disclosure Statement (the “Disclosure Statement Revisions”) to resolve objections 

from PV Properties, the Hon. Rafael Hernández-Montañez, in his official capacity as Speaker of 

the Puerto Rico House of Representatives and the Hon. José L. Dalmau-Santiago, in his official 

capacity as President of the Puerto Rico Senate, and Manuel Gonzalez Joy (collectively, the 

“Objecting Parties”). Following the hearing, the Oversight Board reached out to counsel for the 

Objecting Parties to discuss the Disclosure Statement Revisions.

4. On March 1, 2023, the Oversight Board filed the Modified Second Amended Title 

III Plan of Adjustment of the Puerto Rico Electric Power Authority [ECF No. 3296] (the “Modified 

Second Amended Plan”).3 Contemporaneously therewith, the Oversight Board filed the 

Disclosure Statement for Modified Second Amended Title III Plan of Adjustment of the Puerto Rico 

Electric Power Authority [ECF No. 3297] (the “Modified Disclosure Statement”).

 2 Unless otherwise stated, all ECF Nos. shall refer to the docket in Case No. 17-4780. 

3 Capitalized terms not otherwise defined herein shall have the meanings given to such terms in the Modified Second 

Amended Plan.

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5. The Modified Second Amended Plan has been updated from the Second Amended 

Plan to (i) indicate the Ballot Date is June 7, 2023, (ii) represent the New Master Indenture shall 

be filed twenty-one (21) days prior to the Ballot Date, (iii) correct a cross-reference in the 

description of the Supporting Creditors’ Fees for the Fuel Line Lenders, and (iv) provide an 

updated number for the amount of PREPA Revenue Bond Claims to be Allowed as Settling

Bondholders, after curing deficient submissions made by Holders of Uninsured PREPA Revenue 

Bonds by the Settlement Offer Deadline.

6. The Modified Disclosure Statement reflects (i) the Disclosure Statement Revisions, 

(ii) an updated number for the amount of PREPA Revenue Bond Claims to be Allowed as Settling 

Bondholders, and (iii) certain voting, discovery, and confirmation deadlines approved on the 

record of the hearing held on February 28, 2023 and in the Order Establishing, Among Other 

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

Connection Therewith [ECF No. 3294].

7. For the convenience of the Court and parties-in-interest, attached hereto as Exhibit 

A is a redline of the Modified Second Amended Plan compared to the Second Amended Plan and 

attached hereto as Exhibit B is a redline of the Modified Disclosure Statement to the Disclosure 

Statement.

[Remainder of Page Left Intentionally Blank] 

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Dated: March 1, 2023

 San Juan, Puerto Rico

Respectfully submitted,

/s/ Martin J. Bienenstock

Martin J. Bienenstock 

Ehud Barak

Margaret A. Dale

Jeffrey W. Levitan 

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 sole Title III representative for PREPA

 O’NEILL & BORGESS LLC

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205 

250 Muñoz Rivera Ave.,Suite 800 

San Juan, PR 00918-1813 

Tel: (787) 764-8181 

Fax: (787) 753-8944

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/ Hermann D. Bauer

Hermann D. Bauer

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