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 

 : 

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

 : 

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

 : 

Debtors.1

 : 

 : 

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FIRST SUPPLEMENTAL VERIFIED STATEMENT OF OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS PURSUANT TO BANKRUPTCY RULE 2019 

 Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

Rules”), made applicable to these title III cases by section 310 of the Puerto Rico Oversight, 

Management and Economic Stability Act of 2016 (“PROMESA”),2 the Official Committee of 

Unsecured Creditors of all title III Debtors (other than COFINA) (the “Committee”) by and 

through its undersigned counsel, hereby submits this first supplemental verified statement (the 

“Supplemental Verified Statement”), and respectfully states as follows: 

 

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); and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy 

Case No. 17-BK-4780 (LTS)) (Last Four Digits of Federal Tax ID: 3747) (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations). 

2

 References to PROMESA are references to 48 U.S.C. §§ 2101 et. seq. 

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1. On June 15, 2017, the Office of the United States Trustee for the District of 

Puerto Rico (the “U.S. Trustee”) filed a Notice Appointing Creditors Committee for Unsecured 

Creditors [Docket No. 338]. 

2. On August 16, 2017, the Committee filed the Verified Statement of Official 

Committee of Unsecured Creditors Pursuant to Bankruptcy Rule 2019 [Docket No. 1050]. 

3. On August 25, 2017, the U.S. Trustee filed an Amended Notice of Appointment of 

Official Committee of Unsecured Creditors [Docket No. 1171] (the “Amended Notice of 

Appointment”). The Amended Notice of Appointment reflected (i) that from and after August 

25, 2017, the Committee would serve as official committee of unsecured creditors in the 

Commonwealth, HTA, ERS, and PREPA title III cases, and (ii) that the U.S. Trustee had 

appointed two additional members of the Committee: Ferrovial Agroman, and Vitol, Inc. 

(“Vitol”). 

4. On August 31, 2017, the U.S. Trustee filed a Second Amended Notice of 

Appointment of Official Committee of Unsecured Creditors [Docket No. 1218) (the “Second 

Amended Notice of Appointment”). The Second Amended Notice of Appointment reflected 

(i) that Ferrovial Agroman had resigned from the Committee, and (ii) that the U.S. Trustee had 

appointed to the Committee one additional member: Peerless Oil & Chemicals, Inc. (“Peerless”). 

5. On April 27, 2018, Vitol resigned as a member of the Committee. As of the date 

of this Supplemental Verified Statement, the U.S. Trustee has not appointed a replacement 

Committee member. 

6. In accordance with Bankruptcy Rule 2019, attached hereto as Exhibit A is a list of 

the names and addresses of each Committee member, and the nature and amount of all 

disclosable economic interests held by each Committee member in relation to the Debtors as of 

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April 30, 2018. The claims and claim amounts set forth on Exhibit A have been provided to 

Committee counsel by the applicable Committee members. 

7. By filing this Supplemental Verified Statement, the Committee makes no 

representation regarding the amount, allowance or priority of such claims and reserves all rights 

with respect thereto. 

8. Nothing contained in this Supplemental Verified Statement (or Exhibit A hereto) 

should be construed as a limitation upon, or waiver of, any Committee member’s right to assert, 

file, or amend its claim(s) in accordance with applicable law and any orders entered in these 

cases, including any order establishing procedures for filing proofs of claim. 

9. The Committee reserves the right to amend or supplement this Supplemental 

Verified Statement in accordance with the requirements set forth in Bankruptcy Rule 2019. 

[Remainder of page intentionally left blank.] 

 

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Dated: May 9, 2018 

 

/s/ G. Alexander Bongartz .

PAUL HASTINGS LLP 

Luc. A. Despins, Esq. (Pro Hac Vice) 

Andrew V. Tenzer, Esq. (Pro Hac Vice)

Michael E. Comerford, Esq. (Pro Hac Vice) 

G. Alexander Bongartz, Esq. (Pro Hac Vice) 

200 Park Avenue 

New York, New York 10166 

Telephone: (212) 318-6000 

lucdespins@paulhastings.com 

andrewtenzer@paulhastings.com 

michaelcomerford@paulhastings.com 

alexbongartz@paulhastings.com 

Counsel to the Official Committee of Unsecured 

Creditors

- and - 

/s/ Juan J. Casillas Ayala .

CASILLAS, SANTIAGO & TORRES LLC 

Juan J. Casillas Ayala, Esq., USDC - PR 218312 

Diana M. Batlle-Barasorda, Esq., USDC - PR 213103 

Alberto J. E. Añeses Negrón, Esq., USDC - PR 302710 

Ericka C. Montull-Novoa, Esq., USDC - PR 230601 

El Caribe Office Building 

53 Palmeras Street, Ste. 1601 

San Juan, Puerto Rico 00901-2419 

Telephone: (787) 523-3434 

jcasillas@cstlawpr.com 

dbatlle@cstlawpr.com 

aaneses@cstlawpr.com 

emontull@cstlawpr.com 

Local Counsel to the Official Committee of Unsecured 

Creditors

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COMMITTEE’S SUPPLEMENTAL VERIFIED STATEMENT 

EXHIBIT A 

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NAME ADDRESS NATURE AND AMOUNT OF DISCLOSABLE ECONOMIC IN

American Federation of Teachers (“AFT”)

555 New Jersey Avenue, N.W., 11th Floor Washington, DC 20001 

AFT, as authorized agent for the Asociación de Maestros de Puerto Rico-Local Sinunsecured claims based upon rights arising under a collective bargaining agreemen

Department of Education of Puerto Rico and under statute, including, but not limitclaims (a) for wage increases for years of service and career enhancement as allowcontract but not paid, (b) that are subject to grievance or arbitration procedures whprocessed or therefore liquidated, and (c) that are for other terms of employment wdenied, and (2) contingent claims including but not limited to claims arising in concompensation, pension, medical and other benefits and/or as a result of any breach or applicable statute or law. 

Drivetrain, LLC, as the Creditors’ Trustee for Doral Financial Corporation (“DFC”)

630 Third Avenue 21st Floor New York, NY 10017 

DFC holds prepetition unsecured claims under a certain closing agreement, dated D

and among the Secretary, in her capacity as Secretary of the Treasury, and DFC an

(the “2013 Closing Agreement”), under which DFC became entitled to a credit for 

amount of $34,097,526. The 2013 Closing Agreement provided that the DFC overeduce estimated taxes or it could be claimed as a tax refund. As of the date hereofthe DFC overpayment. As such, DFC has a tax refund claim in the amount of $34,In addition, based on certain closing agreements, DFC is entitled to accrue a $59,3deduction annually from 2017 through 2021 (the “Tax Asset”), which could be usewould otherwise be subject to Puerto Rico tax. Under these closing agreements, Dentitled to an aggregate deduction of $296,574,455. DFC asserts a claim for any lowell as any impairment of its rights under the closing agreements. DFC also asserts an unliquidated damages claim against the Commonwealth on a n

Genesis Security Services, Inc. (“Genesis”)

5900 Isla Verde Avenue L-2 PMB 438 Carolina, PR 00979

Genesis holds prepetition unsecured claims against the Commonwealth and/or its iagreements for the provision of security services, in the following amounts:2

Commonwealth:  Department of Labor $ Department of Transportation and Public Works  Capitol Superintendence  Department of Education $ Telecommunications Regulatory Board  State Department 

1 The Committee takes no position with respect to the amount, validity, secured status, or priority of any of the Committee member’s asse

herein. The information contained herein was provided to counsel for the Committee by each Committee member. 

2 The entities listed below are title III Debtors or their agencies. 

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NAME ADDRESS NATURE AND AMOUNT OF DISCLOSABLE ECONOMIC IN

 Puerto Rico Department of the Family $ Department of Health $ Corps of Medical Emergencies Bureau Highways & Transportation Authority $Puerto Rico Electric Power Authority Total $1

Peerless Oil & Chemicals, Inc. (“Peerless”) 

671 Road 337 Peñuelas, Puerto Rico 00624-7513

Peerless holds prepetition unsecured claims of $602,709.26 against HTA and $16,amounts owing under certain fuel oil purchase contracts. 

Puerto Rico Hospital Supply, Inc. (“PR Hospital Supply”)

Call Box 158 Carolina, PR 00986-0158 

PR Hospital Supply holds prepetition unsecured claims against the Commonwealth instrumentalities under agreements for the purchase of hospital supplies, inventory

the following amounts:3

Department of Health $Department of Correction and Rehabilitation Total $

Service Employees International Union (“SEIU”)

1800 Massachusetts Avenue, N.W. Washington, DC 20036 

SEIU and its affiliates, SEIU Local 1996/Sindicato Puertorriqueño de TrabajadoreSEIU Local 1199/Unión General de Trabajadores, hold prepetition unsecured contclaims, not currently liquidated, against the Commonwealth and/or its instrumentabenefits and other terms of employment owing to SEIU members under collective with the Commonwealth and/or its instrumentalities, including, but not limited to, terms of employment claimed in pre-petition union grievances and arbitrations and 

other terms of employment denied employees as a result of pre-petition legislativeunilateral action by the Commonwealth; and (2) pension and other post-employmemembers have accrued as a result of their employment with the Commonwealth an

Total Petroleum Puerto Rico Corp. (“Total”)

Citi View Plaza Tower I 48 Road 165 Oficina 803 

Guaynabo, PR 00968-8046 

Total holds prepetition unsecured claims arising under certain contracts and/or tranCommonwealth and/or its instrumentalities, including motor fuel purchase and sup$500,000. 4

3 The entities listed below are title III Debtors or their agencies. 4 Total is in the process of reconciling prepetition invoices and payments received pre- and postpetition from the Commonwealth and/or it

will update its prepetition claim amount in connection with the filing of the next Committee supplemental Rule 2019 statement. 

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NAME ADDRESS NATURE AND AMOUNT OF DISCLOSABLE ECONOMIC IN

The Unitech Engineering Group, S.E. (“Unitech”)

Urb Sabanera 40 Camino de la Cascada Cidra, Puerto Rico 00739 

Unitech holds prepetition unsecured claims against the Commonwealth of Puerto Rconstruction contracts, in the approximate amount of $11,284,462.70, plus interest

Vitol, Inc. (“Vitol”)5 2925 Richmond Ave. 

Houston, Texas 77098 

Vitol holds prepetition unsecured claims of $28,477,244.25 against PREPA for am

fuel oil purchase contracts, as well as claims of $12,995,527.18 for accrued prepetsuch amounts. 

5 Vitol resigned from the Committee on April 27, 2018. 

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