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) 

INFORMATIVE MOTION REGARDING WITHDRAWAL OF RETIREE 

COMMITTEE’S MOTION TO COMPEL THE PUERTO RICO DEPARTMENT OF 

TREASURY TO COMPLY WITH THE FIRST AND SECOND AMENDED ORDERS 

SETTING PROCEDURES FOR INTERIM COMPENSATION 

AND REIMBURSEMENT OF EXPENSES OF PROFESSIONAL 

The Official Committee of Retired Employees of the Commonwealth of Puerto Rico (the 

“Retiree Committee”), respectfully states as follows 

1. On July 13, 2018, the Retiree Committee filed an urgent motion (“Motion”) for 

entry of an order directing the Puerto Rico Department of Treasury, part of the Commonwealth’s 

central government (“Hacienda”) to comply with this Court’s First Amended Order Setting 

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Dkt. No. 

 

1 The Debtors in these jointly-administered PROMESA 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: (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) (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 and Power Authority (Bankruptcy Case No. 17 BK 4780) (Last 

Four Digits of Federal Tax ID: 3747). 

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1715] (the “First Amended Interim Compensation Order”) and the Second Amended Order 

Setting Procedures for Interim Compensation and Reimbursement of Expenses of Professionals 

[Dkt. No. 3269] (the “Second Amended Interim Compensation Order, together with the First 

Amended Interim Compensation Order, the “Interim Compensation Orders”). 

2. On July 19, 2018, the Retiree Committee filed a Supplement to the Motion 

(“Supplement”) [Dkt. No. 3649], informing the Court that the Retiree Committee’s Professionals2

had received partial payments of various past-due amounts, but were still owed substantial 

amounts that were past due and/or represented amounts unpaid due to an erroneous application of 

withholding taxes by Hacienda, as discussed in the Motion. 

3. On July 23, 2018, the Retiree Committee filed a Reply in further support of the 

Motion (“Reply”) [Dkt. No. 3673], again noting the Retiree Committee’s Professionals’ efforts to 

consensually resolve the Motion with Hacienda and Hacienda’s continued failure to comply fully 

with the Interim Compensation Orders. 

4. Since the filing of the Reply, each of the Retiree Committee’s Professionals have 

continued to work with Hacienda, and Hacienda has made payment of most of the outstanding fees 

and expenses of the Retiree Committee’s Professionals. Accordingly, the Retiree Committee 

hereby withdraws the Motion without prejudice and expressly reserves the right to renew the 

Motion if Hacienda fails to make any outstanding or future payments to the Retiree Committee’s 

Professionals as required under the Interim Compensation Orders. 

 

 

2 Retiree Committee’s Professionals means Jenner & Block LLP; Bennazar, Garcia & Milián, C.S.P.; FTI 

Consulting; Segal Consulting; and Marchand ICS. 

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July 24, 2018 

JENNER & BLOCK LLP 

By: 

/s/ Robert Gordon 

Robert Gordon (admitted pro hac vice) 

Richard Levin (admitted pro hac vice) 

919 Third Ave 

New York, NY 10022-3908 

rgordon@jenner.com 

rlevin@jenner.com 

212-891-1600 (telephone) 

212-891-1699 (facsimile) 

Catherine Steege (admitted pro hac vice) 

Melissa Root (admitted pro hac vice) 

353 N. Clark Street 

Chicago, IL 60654 

csteege@jenner.com 

mroot@jenner.com 

312-222-9350 (telephone) 

312-239-5199 (facsimile) 

Respectfully submitted, 

BENNAZAR, GARCÍA & MILIÁN, C.S.P. 

By: 

/s/ A.J. Bennazar-Zequeira 

A.J. Bennazar-Zequeira 

Héctor M. Mayol Kauffmann 

Edificio Union Plaza, 

1701 Avenida Ponce de León #416 

Hato Rey, San Juan 

Puerto Rico 00918 

ajb@bennazar.org 

hector.mayol@bennazar.com 

787-754-9191 (telephone) 

787-764-3101 (facsimile) 

Counsel for The Official Committee of Retired 

Employees of Puerto Rico

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