67300564_2

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

Case No. 17 BK 3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

PUERTO RICO POWER ELECTRIC AUTHORITY,

Debtor.

PROMESA Title III

Case No. 17 BK 4780-LTS

APPLICATION FOR ADMISSION PRO HAC VICE

COMES NOW, Keith H. Wofford, applicant herein, and respectfully states:

1. Applicant is an attorney with the law firm Ropes & Gray LLP, with offices at 1211 Avenue 

of Americas, New York, NY 10036, telephone no. (212) 596-9000, fax no. (212) 596-9090, 

and e-mail: keith.wofford@ropesgray.com.

2. Applicant will sign all pleadings with the name Keith H. Wofford.

 

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); and (v) Puerto Rico Electric 

Power Authority (Bankruptcy Case No. 17 BK 04780-LTS) (Last Four Digits of Federal Tax ID: 3747) (Title III case 

numbers are listed as Bankruptcy Case numbers due to software limitations).

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3. Applicant has been retained personally or as a member of the above-named firm by

Knighthead Capital Management, LLC (and certain funds and accounts managed or 

advised by it) to provide legal representation in connection with the above-styled cases

now pending before the United States District Court, District of Puerto Rico.

4. Since February 14, 1994, applicant has been and presently is a member in good standing 

of the highest court of the State of New York. Applicant’s bar license number is 2582062.

5. Applicant has been admitted to practice before the following courts: U.S. Supreme Court 

(2014); U.S. Court of Appeals for the Third Circuit (2015); U.S. District Court for the 

Eastern District of New York (2002); U.S. District Court for the Southern District of New 

York (1994).

6. Applicant is a member in good standing of the bars of the courts listed in paragraph 5.

7. Applicant is not currently suspended from the practice of law before any court or 

jurisdiction.

8. Applicant is not currently the subject of any complaint for unethical conduct, disciplinary 

proceeding or criminal charges before any court or jurisdiction.

9. During the past three years, applicant has not filed for pro hac vice admission in the United 

States District Court of Puerto Rico.

10. Local counsel of record associated with applicant in this matter are Manuel FernandezBared, Linette Figueroa-Torres, and Nayda Perez-Roman, all of Toro, Colón, Mullet, 

Rivera & Sifre, P.S.C., P.O. Box 195383, San Juan, Puerto Rico 00919-5383, telephone 

no. (787) 751-8999, fax no. (787) 763-7760, and emails mfb@tcm.law, lft@tcm.law, and 

nperez@tcm.law.

11. Applicant has read the Local Rules of this Court and will comply with same.

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12. Applicant has read the Local Rules of the United States District Court for the District of 

Puerto Rico which provide in part that attorneys appearing pro hac vice must comply with 

the provisions set forth therein and pay an admission fee of $300.00 per appearance in each 

new case before the Court. Accordingly, payment of the pro hac vice admission fee is being 

made herewith.

WHEREFORE, applicant respectfully requests to be admitted to practice in the United 

States District Court for the District of Puerto Rico for the above-styled cases only.

RESPECTFULLY SUBMITTED, 

In San Juan, Puerto Rico, today February 9, 2018

ROPES & GRAY LLP

By: /s/ Keith H. Wofford

Keith H. Wofford 

1211 Avenue of the Americas

New York, NY 10036-8704

Telephone: (212) 596-9000

Facsimile: (212) 596-9090

Email: Keith.Wofford@ropesgray.com

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I HEREBY CERTIFIED, pursuant to Local Rule 83A(f), that I consent to the designation 

of local counsel of record for all purposes. 

RESPECTFULLY SUBMITTED, 

In San Juan, Puerto Rico, today February 9, 2018

TORO COLÓN MULLET P.S.C.

s/ Manuel Fernández-Bared

MANUEL FERNÁNDEZ-BARED

Email: mfb@tcm.law

s/ Linette Figueroa-Torres______

LINETTE FIGUEROA-TORRES

Email: lft@tcm.law

s/ Nayda Pérez-Román______

NAYDA PEREZ-ROMAN

Email: nperez@tcm.law

P.O. Box 195383

San Juan, PR 00919-5383

Tel.: (787) 751-8999

Fax: (787) 763-7760

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67300564_2

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I filed this document electronically with the Clerk of the Court 

using the CM/ECF System, and a copy of the foregoing pleading has been electronically mailed 

to all attorneys of record.

RESPECTFULLY SUBMITTED, 

In San Juan, Puerto Rico, today February 9, 2018

TORO COLÓN MULLET P.S.C.

s/ Manuel Fernández-Bared

MANUEL FERNÁNDEZ-BARED

Email: mfb@tcm.law

s/ Linette Figueroa-Torres______

LINETTE FIGUEROA-TORRES

Email: lft@tcm.law

s/ Nayda Pérez-Román______

NAYDA PEREZ-ROMAN

Email: nperez@tcm.law

P.O. Box 195383

San Juan, PR 00919-5383

Tel.: (787) 751-8999

Fax: (787) 763-7760

Attorneys for Knighthead Capital Management, 

LLC and certain funds and accounts managed or 

advised by it

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