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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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:

In re: :

:

THE FINANCIAL OVERSIGHT AND : PROMESA

MANAGEMENT BOARD FOR PUERTO RICO, : Title III

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as representative of : Case No. 17-BK-3283 (LTS)

:

THE COMMONWEALTH OF PUERTO RICO, et al., : (Jointly Administered)

:

Debtors.1:

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INFORMATIVE MOTION OF THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO 

REGARDING THE CASE STATUS REPORT

To the Honorable United States District Court Judge Laura Taylor Swain:

The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), as 

representative of the Commonwealth of Puerto Rico (the “Commonwealth”) pursuant to § 315 of 

the Puerto Rico Oversight, Management, and Economic Stability Act, hereby files this case status 

report in the form of an informative motion pursuant to the Court’s Order Canceling the April 25, 

2018, Omnibus Hearing. [ECF No. 2946; Case No. 17-BK-3283-LTS]. 

I. Fiscal Plans

During public meetings held on Thursday, April 19, 2018, and Friday, April 20, 2018, in San 

Juan, Puerto Rico, the Oversight Board certified fiscal plans for the Commonwealth and the 

following agencies and instrumentalities: Puerto Rico Aqueduct and Sewer Authority, Puerto Rico 

Electric Power Authority, Government Development Bank, Puerto Rico Highway and 

 

1 The Debtors in these title III cases, along with each Debtor’s respective title III case number listed as a 

bankruptcy case number due to software limitations 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) 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), (iii) Puerto Rico 

Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567-LTS) (Last Four Digits of Federal 

Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284-LTS) 

(Last Four Digits of Federal Tax ID: 8474), and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case 

No. 17-BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747).

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Transportation Authority and the University of Puerto Rico. At that time, the Oversight Board

voted to defer consideration of the fiscal plan for the Public Corporation for the Supervision and 

Deposit Insurance of Puerto Rico Cooperatives pending completion of additional financial analysis. 

Copies of the certified fiscal plans are available for review on the Oversight Board’s website: 

https://juntasupervision.pr.gov/index.php/en/documents/.

II. Mediation

Mediation efforts continue and are currently focused on resolution of the 

Commonwealth-COFINA dispute regarding ownership of sales and use taxes. 

III. Claims and Claims Management

Pursuant to the Court’s Order, dated February 15, 2018 [ECF No. 2521; Case No. 17-

BK-3283-LTS], the Court established May 29, 2018 as the date by which proofs of claim 

against the Title III Debtors must be filed and received (the “Bar Date”). Notices of the Bar 

Date have been mailed to parties listed on the schedules of creditors, published in various 

newspapers and broadcast locally in Spanish and English. Additional notices shall be 

published and broadcast over the next several weeks. As of April 23, 2018, the following 

proofs of claim, separated by Title III Debtor and by top five claim type, have been received 

by mail, at claim filing centers and by online filings: 

Debtor’s Name Claim Sums Per Debtor Claims Filed Per Debtor

Commonwealth $3,441,074,328.22 3,746

COFINA $155,103,322.17 745

HTA $106,174,545.65 451

ERS $133,475,847.15 1,744

PREPA $374,211,944.62 612

TOTAL $4,210,039,987.81 7,298

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Claim Type Aggregate Amount Asserted Number of Claims

Litigation $1,301,105,768.98 173

Bond $1,235,319,173.75 1,153

Income Tax Refunds $303,107,396.11 364

Contract $138,827,552.78 8

Pension/Retiree $75,090,623.34 356

TOTAL $3,053,450,514.96 2,054

On April 13, 2018, the Oversight Board issued a Request for Proposals for claims 

management and reconciliation services for the Title III Debtors, including, without limitation, 

developing reconciliation guidelines and substantive objection categories for all claims filed. The 

Oversight Board, in consultation with the Puerto Rico Fiscal Agency and Financial Advisory

Authority (“AAFAF”), is currently reviewing proposals tendered and shall select a provider on or 

about May 11, 2018. Thereafter, the Oversight Board, together with AAFAF, shall commence the 

claims reconciliation process.

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Dated: April 25, 2018

 San Juan, Puerto Rico

Respectfully submitted,

/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

Email: hermann.bauer@oneillborges.com

Martin J. Bienenstock (pro hac vice) 

Brian S. Rosen (pro hac vice)

PROSKAUER ROSE LLP

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: mbienenstock@proskauer.com 

Email: brosen@proskauer.com

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as the 

representative of the Commonwealth of 

Puerto Rico

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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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