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)

Re: ECF No. 24495 

JOINT STATUS REPORT IN COMPLIANCE WITH ORDER CONCERNING 

MOTION TO INCLUDE MEMBERS OF THE GROUP THAT WERE NOT 

INCLUDED (DOCKET ENTRY NO. 24477)

To The Honorable United States District Judge Laura Taylor Swain:

1. The Financial Oversight and Management Board for Puerto Rico (the “Oversight 

Board”), as sole Title III representative of the Commonwealth of Puerto Rico (the “Commonwealth,” 

or the “Debtor”) pursuant to Section 315(b) of the Puerto Rico Oversight, Management, and Economic 

Stability Act (“PROMESA”),2 and plaintiffs in the case captioned Maggie Acevedo Sepúlveda, et al. v. 

Department of Health of Puerto Rico, Case No. 2000-06-1639 (collectively, “Movants”), hereby

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

(Bankruptcy Case No. 17- BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) 

Puerto Rico Public Buildings Authority (“PBA”) (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).

2

 PROMESA is codified at 48 U.S.C. §§ 2101-2241. 

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respectfully submit this joint status report pursuant to the Court’s Order Concerning Motion to Include 

Members of the Group That Were Not Included (Docket Entry No. 24477) [ECF No. 24495] (the 

“Order”). 

2. In the Order, the Court instructed the parties to meet and confer concerning the issues 

raised in Plaintiff’s Motion Asking to Include Members of the Group that Were Not Included [ECF No. 

24477] (the “Motion”). Order at 1. The Order further directed the parties to file a joint status report 

by June 26, 2023 at 5:00 p.m. (Atlantic Standard time) if, following that meet and confer, “Movants 

and/or the Oversight Board believe that action from the Court is necessary.” Id. at 1-2. 

3. In compliance with the Order, the parties conferred via email and teleconference and 

agreed to exchange additional information regarding the parties’ legal and factual positions concerning 

the relief requested in the Motion. The parties also agreed that additional time was necessary to permit 

the parties to complete this information exchange and engage in further discussions to resolve the issues 

raised in the Motion.

4. Accordingly, the parties respectfully request that they be permitted to file a further joint 

status report on or before July 17, 2023. In the event the parties require further assistance from the 

Court, it will be noted in such report. A proposed order granting the relief requested herein is attached 

hereto as Exhibit A. 

[Remainder of Page Intentional Left Blank] 

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Dated: June 26, 2023 Respectfully submitted,

 San Juan, Puerto Rico 

/s/ Santiago A. Iturregui Del Toro

Santiago A. Iturregui Del Toro 

USDC No.225006 

P.O. Box 7341 

Ponce, Puerto Rico 00732-7341 

saiturregui@gmail.com 

(787) 298-8155 

Attorney for Movants 

/s/ Hermann D. Bauer

Hermann D. Bauer 

USDC No. 215205 

Carla García Benítez

USDC No. 203708 

Gabriel A. Miranda-Rivera

USDC No. 306704 

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800 

San Juan, PR 00918-1813 

Tel: (787) 764-8181 

Fax: (787) 753-8944 

/s/ Brian S. Rosen 

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 

Attorneys for the Financial Oversight 

and Management Board for Puerto Rico, 

as sole Title III representative for 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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