UNITED STATES DISTRICT COURT 

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) 

THE PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY 

AUTHORITY’S RESPONSE TO MOTION TO COMPEL OF THE AD HOC GROUP OF 

GENERAL OBLIGATION BONDHOLDERS, AMBAC ASSURANCE CORPORATION, 

ASSURED GUARANTY CORP., ASSURED GUARANTY MUNICIPAL CORP., THE 

MUTUAL FUND GROUP, AND NATIONAL PUBLIC FINANCE GUARANTEE 

CORPORATION, AND REQUEST FOR ENTRY OF PROTECTIVE ORDER

 

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: (i) the Commonwealth of Puerto Rico 

(Bankruptcy Case No. 17 BK 3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) the Puerto Rico Sales Tax 

Financing Corporation (“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 

8474); (iii) the Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-

LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) the 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) the 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.

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The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”), hereby 

responds to the Motion to Compel Compliance with February 26, 2018 Order and For Entry of a 

Protective Order of Ad Hoc Group of General Obligation Bondholders, Ambac Assurance 

Corporation, Assured Guaranty Corp., Assured Guaranty Municipal Corp., The Mutual Fund 

Group, and National Public Finance Guarantee Corporation ECF No. 2865 (the “Motion”). 

INTRODUCTION 

The Motion is a thinly-veiled motion for reconsideration of the Court’s February 26, 

2018 discovery order regarding the use of Fiscal Plan Development Materials and should be 

denied. In its prior order, this Court ruled “Movants have not shown good cause for the 

immediate use of the information, which would require the disclosure of many documents 

currently shared amongst the parties pursuant to protective orders and/or non-disclosure 

agreements.” ECF No. 2590 (“Order”) at 11. 2 The Court left the issue of appropriate 

confidentiality restrictions regarding such material for a future date, holding that “while Movants 

may attempt to use the Fiscal Plan Development Materials in the Title III or adversary 

proceedings, Respondents are not prejudiced from objecting to that use on a document by 

document basis. Such objections may include the necessity of keeping a particular protective 

order in place.” Id. In other words, the Court denied Movants’ request for immediate use in 

litigation, subject to Movants’ right to seek to use the subject material in the future and 

Respondents’ right to oppose such use. 

 

2

“Movants” are the Ad Hoc Group of General Obligation Bondholders, Ambac Assurance 

Corporation, Assured Guaranty Corp., Assured Guaranty Municipal Corp., the Mutual Fund 

Group, and National Public Finance Guarantee Corporation. “Respondents” are AAFAF, the 

Commonwealth of Puerto Rico (the “Commonwealth”), as a Title III Debtor, by and through the 

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

Commonwealth’s representative pursuant to section 315(b) of the Puerto Rico Oversight, 

Management, and Economic Stability Act (“PROMESA”), and the Oversight Board.

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Movants completely overlook this fundamental aspect of the Court’s order, insisting the 

Order stripped confidentiality protections from virtually all the materials Respondents have 

provided, including information Respondents have provided to Movants in the Data Room and 

through mediation. See Motion, Ex. C, ECF No. 2865-3.3 The Court did no such thing, and its 

carefully considered balancing of the rights of the parties as embodied in the Order cannot be so 

cavalierly ignored. Movants have not shown good cause to disregard confidentiality and obtain 

authority to use information however they wish, or provided a compelling reason to grant the 

relief they seek, let alone prior to a document-by-document review and their Motion should be 

denied. 

Some of Movants’ arguments are simply recycled from prior pleadings this Court 

rejected. Confidentiality restrictions should be eliminated, they contend, because Movants want 

to show Data Room materials to litigation experts. See Motion, ECF No. 2865, at 5, n.4. But 

this Court already found that Movant’s bare references to expert discovery, untethered to any 

pending litigation deadline, did not constitute good cause to lift the Data Room confidentiality 

restrictions. See Order, ECF No. 2590 at 11. Movants also want to show currently nonpublic 

information to trading principals of their clients without the need for those individuals to sign an 

NDA or the mediation agreements. Motion, ECF No. 2865 at 8. But Movants’ clients can easily 

sign these agreements; parties do in virtually every major restructuring case if they want to 

participate in settlement discussions or otherwise receive sensitive financial information. And if 

Movants’ clients wish to maintain trading optionality, they can easily abide by procedures for 

 

3 Though Movants’ brief asks the Court to “compel production” of certain Fiscal Plan 

Development Materials, this is a misnomer: Respondents have given Movants access to all these 

materials already. The disputed issue is the level of confidentiality those materials should be 

afforded.

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screening non-public information that creditors routinely implement in bankruptcy cases. See In 

re Washington Mut., Inc., 461 B.R. 200, 266 (Bankr. D. Del. 2011), vacated in part on other 

grounds, No. 08-12229 MFW, 2012 WL 1563880 (Bankr. D. Del. Feb. 24, 2012) (explaining 

“creditors who want to participate in settlement discussions in which they receive material 

nonpublic information about the debtor must either restrict their trading or establish an ethical 

wall between traders and participants in the bankruptcy case” since “[t]hese types of restrictions 

are common in bankruptcy cases” and “a requirement to restrict trading or create an ethical wall 

in exchange for a seat at the negotiating table” does not “place[] an undue burden on creditors 

who wish to receive confidential information and give their input.”). 

Finally, this Court should not grant Movants’ requested protective order, which 

unreasonably risks waiver of confidentiality protections over certain material. Respondents have 

proposed a protective order, attached hereto as Exhibit A, which preserves the confidentiality of 

Data Room documents unless the parties agree or the Court orders otherwise. If the Court enters 

any protective order, it should use this version instead of that urged by Movants.

BACKGROUND

On December 22, 2017, the Parties submitted a Joint Report identifying only two 

disputes remaining for resolution: (1) the applicability of the deliberative process privilege; and 

(2) the confidentiality restrictions that should apply to materials made available to Movants 

through the Data Room. ECF No. 2154. Over the course of litigating these disputes, Movants 

conceded that Respondents posted to the Data Room “information sufficient to respond to the 

requests for Fiscal Plan Development Materials relating to the 2017 Plan,” and that Respondents 

have agreed to provide the Fiscal Plan Development Materials in connection with the 2018 plan 

once it is certified. See Order, ECF No. 2590, at 6-7. On February 26, 2018, this Court held that 

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pre-decisional Fiscal Plan materials were privileged, subject to a categorical logging 

requirement,4and that Movants had not shown good cause to strip the Fiscal Plan Development 

Materials from the confidentiality protections in the NDAs and mediation agreements. See 

Order, ECF No. 2590. 

The Order stated: 

Having ruled that the documents fall within the scope of Rule 2004, this Court 

nonetheless holds that Movants have not shown good cause for the immediate use 

of the information, which would require the disclosure of many documents 

currently shared amongst the parties pursuant to protective orders and/or nondisclosure agreements. 

Order, ECF No. 2590 at 11 (emphasis added). The Court considered Movants’ request for 

immediate use of Fiscal Plan Development Materials to prepare a challenge to the eventual plan 

of adjustment, and rejected it:

The Movants have only asserted that they may need to use the materials in 

connection with the cross-examination of experts or other challenges to an eventual 

plan of adjustment. No timetable for such potential use has been provided. As a 

result, this Court orders that while Movants may attempt to use the Fiscal Plan 

Development Materials in the Title III or adversary proceedings, Respondents are 

not prejudiced from objecting to that use on a document-by document basis. Such 

Objections may include the necessity of keeping a particular protective order in 

place.

Id. (emphasis added)

The Order also recognized that “deciding what material in the Data Room should be 

released from their confidentiality restrictions may involve a lot of unnecessary work since the 

Movants may not be seeking to use much of the material.” Id. To avoid this problem, the Court 

ordered the parties to follow a procedure mirroring Section I(a) of the Parties’ Joint Report. Id. 

at 11-12. Section I(a) states that Respondents will identify Data Room materials that consist of 

 

4 Several of the Movants filed Objections to this ruling. ECF No. 2707. Consistent with the 

Court’s order, Respondents served extensive categorical privilege logs on April 6, 2018.

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data or factual information that they agree may be used in litigation, subject to a protective order. 

Joint Report, ECF No. 2154 at 2.5 

Meet and Confer

Instead of following the Court-ordered procedure, Movants sent a letter on February 27, 

2018, claiming the Order required Respondents to lift the NDA and mediation confidentiality 

restrictions from every single document in the Data Room folder housing diligence materials 

relating to the central Government, and over eighty percent (153 of 184) of the documents the 

Commonwealth had given its creditors through mediation to date. See Motion, ECF No.2865, 

Ex. C 2865-3. The letter also reserved the Commonwealth’s creditors’ right to send additional 

demands for the release of confidentiality restrictions from instrumentality-specific documents, 

and additional documents exchanged through mediation. Id.

On March 1, 2018, consistent with the Order and Section I(a) of the Joint Report, 

Respondents provided Movants with a list of Data Room documents and folders that, as of the 

date of this filing, includes 122 Data Room documents that Respondents determined constitute 

“data or factual information” responsive to the Joint Requests, and agreed that these documents, 

along with the thousands of documents produced in adversary proceedings, may be used for 

 

5 The entirety of the paragraph reads as follows: 

The Parties agree that, subject to the entry of a protective order, data or factual 

information produced in the Data Room will be produced or deemed produced 

pursuant to the 2004 Requests Nos. 1 through 7, 11, 14 and 15. Movants may 

attempt to use such produced information in the Title III or adversary proceedings 

and Respondents reserve and do not waive any objection to such future use. 

Respondents will provide Movants with a schedule of materials in the Data Room 

that they in good faith determine to be data or factual information within the 

meaning of this paragraph. 

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litigation purposes, subject to the entry of a protective order. Motion, Ex. E, ECF 2865-5.6 

Respondents also agreed to meet and confer with Movants regarding potentially lifting NDA or 

mediation confidentiality restrictions over additional materials, to the extent Movants could 

articulate a current need to lift the restrictions. Id.

The GO Group responded on March 7, 2018, reasserting that the Order stripped all Data 

Room materials that Movants contend are responsive to the Joint Request from the NDA and 

mediation confidentiality restrictions. Motion, Ex. D, ECF 2865-4. Notwithstanding this claim, 

the letter also included an appendix listing 65 specific documents for which Movants sought a 

release of Data Room confidentiality restrictions. Id. Respondents reviewed these 65 

documents, and in a letter dated March 12, 2018, agreed that 15 of them consisted of “data or 

factual information” that could be used in litigation, subject to a protective order, and notified the 

Movants that one of the documents on the list was already publicly available. See Motion, Ex. F, 

ECF 2865-6. This brings the total number of Data Room documents for which Respondents 

agreed to modify the Data Room confidentiality restrictions to date to 137. See id. Exs. E-F, 

ECF Nos. 2865-5, 2864-6. Another 11 documents from the appendix consisted of materials 

concerning the Puerto Rico Highways & Transportation Authority (“HTA”) that were provided 

to HTA’s creditors in mediation. Respondents requested to meet and confer to discuss the basis 

for the Commonwealth creditors’ request for these documents. Motion, Ex. F at 3, ECF No. 

2865-6. The remaining 37 documents consisted of projections and models underlying the 

Commonwealth Fiscal Plan certified on March 13, 2017 (31 documents), and certain materials 

underlying the in-development 2018 Fiscal Plan that were shared with creditors as part of the 

 

6 Respondents clarified that they do not assert confidentiality over publicly available materials 

that they had compiled in the Data Room for creditors’ convenience. 

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mediation process (6 documents). With respect to these 37 documents, Respondents noted, as 

this Court held, that Movants had not shown good cause for release of these materials, but 

invited Movants to have their experts and clients sign NDAs and mediation agreements to 

facilitate their access to those materials. Id. 

Movants never responded to the March 12 letter, and instead filed the instant Motion 

nearly a month later on April 9, 2018. 

Protective Order

The Parties have been exchanging protective order drafts since January. The only point 

in contention is whether the materials Respondents have made available solely through the Data 

Room, subject to NDAs and mediation agreements, should be presumed to be “Confidential” 

under a litigation protective order in the event they are released from the data room restrictions. 

See Ex. B (redline of competing drafts). Respondents’ draft states that such materials would 

remain “Confidential” unless the Parties agree, or the Court orders otherwise. See Ex. A, ¶ 8. 

Movants’ draft assumes all Data Room confidentiality restrictions were lifted by the Order, and 

would require Respondents to re-designate responsive Data Room materials as “Confidential” 

under the protective order within five business days of its entry, or else risk waiver of all 

confidentiality protections. See Motion, Ex. A, ¶ 8, ECF No. 2865-1. Respondents’ draft makes 

no accommodation for materials subsequently posted in the Data Room, or for materials 

provided through mediation. Id.

The Motion

The Motion badly misrepresents the meet and confer process to try to convince the Court 

that Respondents have not complied with the Order. For instance, the Motion repeatedly claims 

Respondents have not produced any Fiscal Plan Development Materials. This is false. 

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Respondents have received Fiscal Plan Development Materials through the Data Room. 

Respondents have further identified 137 Data Room documents, and the thousands of documents 

produced in adversary proceedings, that will be made available subject to a protective order. 

Respondents have also offered to make the Data Room materials available to Movants’ experts 

and clients if they sign the Data Room confidentiality agreements. See Motion, Exs. E-F, ECF 

Nos. 2865-5, 2865-6. 

The Motion seeks to compel Respondents to release 467documents from the Data Room 

confidentiality restrictions. Motion, Ex. B, ECF No. 2865-2. Movants claim they need the Data 

Room confidentiality restrictions lifted from these materials so that they can show them to expert 

witnesses and principals of their clients who are subject to trading restrictions. Motion at 5, n.4 

& 8. Movants did not discuss 9 of these 46 documents with Respondents before filing the 

Motion8—and 6 of those 9 are already available to Movants outside the Data Room.9 

The 40 documents that remain at issue consist of projections and models underlying the 

obsolete 2017 Fiscal Plan (31 documents) and models and analyses underlying drafts of the indevelopment 2018 Fiscal Plan that were disclosed through mediation (9 documents). All the 

2017 Fiscal Plan materials have been superseded. The 2018 Fiscal Plan materials were shared 

with creditors on a confidential basis in mediation to facilitate voluntary resolution of disputes; 

 

7

Items 4 and 8 in Movants’ list of 47 are duplicates. 

8 These are items 20, and 40-47 of Exhibit B to the Motion. Item 20 was uploaded to the Data 

Room on June 26, 2017. Items 40-47 were uploaded on March 9, 2018, in connection with 

mediation.

9

Item 41 is publicly available at 

https://data.femadata.com/FIMA/NHRAP/Maria/HurricaneMaria_ARA_InitialRun.pdf. Items 

42-44 are duplicates of documents that Respondents already agreed to make available subject to 

a litigation protective order in their March 12 letter. The information in items 45 and 46 was 

published as part of the draft Commonwealth Fiscal Plan that the Governor submitted to the 

Board on April 5, 2018. See http://www.aafaf.pr.gov/assets/newfiscalplanforpuerto-rico-2018-

04-05.pdf, slide 185.

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much of which has been partially or entirely superseded. Now that the Oversight Board has 

certified the 2018 Commonwealth Fiscal Plan, AAFAF agrees to provide backup materials in its 

possession, custody, and control for the certified Fiscal Plan subject to a litigation protective 

order. In addition, many of these materials underlying both the 2017 and 2018 Fiscal Plans were 

prepared by financial advisors, and contain “trade secret or confidential research, development, 

or commercial information” that is not appropriate for public disclosure. See 11 U.S.C. §

107(b)(1). 

ARGUMENT

I. MOVANTS HAVE NOT DEMONSTRATED GOOD CAUSE TO STRIP DATA 

ROOM RESTRICTIONS FROM FISCAL PLAN DEVELOPMENT MATERIALS.

This Court has already held, “Movants have not shown good cause for the immediate use 

of the information, which would require the disclosure of many documents currently shared 

amongst the parties pursuant to protective orders and/or non-disclosure agreements.” Order at 

11, ECF No. 2590. Nothing has changed: Movants do not even try to establish the good cause 

this Court found lacking on February 26. Rather, they insist the Order means something other 

than what it says, and insist the Order stripped away the applicable confidentiality provisions 

governing particular documents. Motion at 5-7, ECF No. 2865. In the alternative, Movants 

claim they need confidentiality restrictions immediately lifted because they would like to show 

Data Room materials to retained litigation experts without use restrictions and to principals of 

their clients without compromising their ability to trade. Id. at 5, n.4 & 8. Neither constitutes 

good cause to immediately lift Data Room confidentiality restrictions. 

This Court has already considered and rejected Movants’ claim that they need to 

immediately use the Data Room materials for use with experts. See Order at 11, ECF No. 2590. 

If Movants seek to use Data Room materials for litigation to challenge an eventual plan of 

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adjustment, this Court already ruled that such use is premature at this time. See id. (rejecting 

argument for immediate use of Data Room materials because “no timetable for such potential use 

has been provided”). Nothing has changed in this regard since February 26. No plan of 

adjustment has been proposed, and no timetable has been set for doing so. And Movants offer 

no support whatsoever for their suggestion that their desire to share nonpublic information with 

trading principals justifies stripping confidentiality protections. Consistent with the accepted 

approach in bankruptcy cases, Respondents have offered to make the Data Room materials 

available to Movants’ principals, if they sign the confidentiality agreements governing those 

materials. See Motion, Ex. F at 3, ECF No. 2865-6. That these principals want to both review 

these materials and preserve their ability to trade does not change the confidential nature of these 

documents, nor does it provide any reason for the Court to deviate from the accepted approach 

courts take in such situations. See In re Washington Mut., Inc., 461 B.R. at 266 (Bankr. D. Del. 

2011), (explaining that it is generally accepted that creditors “restrict trading or create an ethical 

wall in exchange for a seat at the negotiating table”).

Nor is it surprising that Movants have not articulated good cause, as there is none. The 

2017 Fiscal Plan Development Materials, 31 of the 40 documents at issue, are stale in light of the 

complete overhaul of the Commonwealth Fiscal Plan following Hurricane Maria and will not 

become the basis of any plan of adjustment. 

Nor could Movants articulate good cause to strip the 9 documents pertaining to drafts of 

the 2018 Fiscal Plan from the confidentiality restrictions in the mediation agreements. The 2018 

materials were provided in mediation only as a good faith attempt to continue ongoing 

confidential negotiations. These documents have since been superseded, and, AAFAF will make 

the backup materials in its possession, custody or control for the certified 2018 Fiscal Plan 

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available, subject to a litigation protective order. Movants simply cannot justify undermining the 

mediation process by stripping mediation materials from the confidentiality protections afforded 

to those negotiations for an unspecified immediate use. 

II. THE COURT SHOULD ENTER RESPONDENTS’ PROTECTIVE ORDER. 

The single point in dispute with respect to the protective order is whether Data Room 

materials responsive to the Rule 2004 requests, which are currently subject to nondisclosure or 

mediation agreements, should enjoy a presumption of confidentiality under the protective order. 

Ex. B (redline of protective order drafts).

Specifically, Respondents have proposed a protective order that states that documents 

uploaded into the Data Room would remain presumptively Confidential, under either the Data 

Room confidentiality agreements or the protective order, unless Respondents agreed otherwise in 

writing, or the Court so ordered. See Ex. A (Respondents’ proposed protective order). The 

Respondents’ proposed protective order also provides that Movants may designate materials 

from the Data Room they believe should be released from the Data Room restrictions (in 

addition to those materials that Respondents already released), and that the parties would meet 

and confer on any dispute before seeking court intervention. Id. Movants instead ask this Court 

to enter a protective order that would require Respondents to identify all potentially responsive 

documents in the Data Room, including materials shared through mediation, and reproduce them 

with a confidentiality stamp within five business days of entry of the Order, otherwise the 

documents would no longer be deemed confidential. Motion, Ex. A, ¶ 8, ECF 2865-1. The 

Movants’ proposed protective order provides no mechanism for designating materials 

subsequently uploaded to the Data Room, including mediation materials that may be deemed 

responsive to the Rule 2004 requests. Id.

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Contrary to Movants’ assertion, Respondents’ proposed protective order does not reflect 

a refusal to make confidentiality determinations on a document-by-document basis. Cf. Motion 

at 8, ECF No. 2865. The decision to share non-public materials solely through the Data Room 

reflects a determination that those materials warrant confidential treatment.10 When AAFAF 

determines that information pertaining to the Commonwealth’s financial condition or to the 

development of the Fiscal Plans is not confidential, it publishes that information. See ECF 1928 

(cataloging extensive publicly available materials responsive to the Joint Requests). For 

instance, AAFAF publishes weekly reports showing inflows and outflows of the Government’s 

principal bank account, and monthly cash account balance updates for its other accounts.11 

AAFAF also publishes the Fiscal Plan drafts the Governor has submitted to the Oversight Board, 

and the Oversight Board also publishes the results of its reviews of those drafts.12

It is entirely proper to request that the materials shared through the Data Room be treated 

as confidential under a litigation protective order, unless the parties agree or the Court orders 

otherwise. The Data Room materials at issue here consist of projections and models underlying 

the obsolete 2017 Fiscal Plan and drafts of the 2018 Fiscal Plan. The vast majority of these 

documents have been superseded, either as a result of the impact of the Hurricanes, or as the 

result of refinements and revisions of the 2018 Fiscal Plan. Courts have recognized that the 

Government has an interest in limiting the dissemination of materials that do not reflect a final 

policy determination, or for which disclosure would confuse the public as to what the 

 

10 In some cases Respondents have compiled materials that are publicly available in Data Room 

folders to assemble them for the convenience of the creditors. Respondents have already made 

clear they do not claim that materials available outside the Data Room are subject to the Data 

Room restrictions. Motion Ex. E at 2. ECF 2865-5.

11 See http://www.aafaf.pr.gov/documents.html#otherdocumentspin

12 See http://www.aafaf.pr.gov/documents.html#fiscalplanspin; 

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

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Governments’ position is. See New Hampshire Right to Life v. U.S. Dept. of Health and Hum. 

Services, 778 F.3d 43, 52 (1st Cir. 2015) (recognizing deliberative process privilege as a 

mechanism to protect government’s interest “preventing confusion among the public” that could 

result from public disclosure). In addition, some of these materials contain proprietary 

information belonging to third-party consultants for which confidential treatment is entirely 

appropriate. See 11 U.S.C. § 107(b)(1) (“On request of a party in interest, the bankruptcy court 

shall . . . protect an entity with respect to a trade secret or confidential research, development, or 

commercial information”); Fed. R. Bankr. P. 9018 (to same effect). Moreover, materials 

concerning the 2018 Fiscal Plan were shared within the confines of mediation. Entering 

Movants’ proposed protective order, which puts mediation materials at risk of a waiver of 

confidentiality, would undermine the mediation efforts. 

CONCLUSION

 For the reasons stated above, AAFAF respectfully requests that the Court deny the 

Motion, and enter the proposed protective order, attached hereto as Exhibit A.

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Dated: April 23, 2018

San Juan, Puerto Rico

/s/ Peter Friedman

John J. Rapisardi 

(Admitted Pro Hac Vice) 

O’MELVENY & MYERS LLP 

7 Times Square 

New York, NY 10036 

Tel: (212) 326-2000 

Fax: (212) 326-2061 

Peter Friedman

(Admitted Pro Hac Vice) 

O’MELVENY & MYERS LLP 

1625 Eye Street, NW

Washington DC 20006

Tel: (202) 383-5300

Fax: (202) 383-5414

Elizabeth L. McKeen

(Admitted Pro Hac Vice)

O’MELVENY & MYERS LLP 

610 Newport Center Drive

17th Floor

Newport Beach, California 92660

Tel: (949) 823-6900

Fax: (949) 823-6994

Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

Respectfully submitted,

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Email: lmarini@mpmlawpr.com

/s/ Carolina Velaz-Rivero

Carolina Velaz-Rivero

USDC No. 300913

E:mail: cvelaz@mpmlawpr.com

MARINI PIETRANTONI MUÑIZ LLC

MCS Plaza, Suite 500

255 Ponce de León Ave.

San Juan, Puerto Rico 00917

Tel: (787) 705-2171

Fax: (787) 936-7494

Co-Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

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