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) 

 

SUPPLEMENTAL DECLARATION OF BRADLEY TUTTLE, SENIOR MANAGING 

DIRECTOR OF EPIQ CORPORATE RESTRUCTURING, LLC, IN SUPPORT OF 

DEBTORS APPLICATION REGARDING THE EMPLOYMENT AND RETENTION OF 

EPIQ CORPORATE RESTRUCTURING, LLC AND COMPLIANCE WITH THE 

PUERTO RICO RECOVERY ACCURACY IN DISCLOSURES ACT 

I, Bradley Tuttle, being duly sworn, depose and state: 

1. I am a Senior Managing Director of Epiq Corporate Restructuring, LLC (“Epiq”), 

with offices located at 777 Third Avenue, 12th Floor, New York, NY 10017. I am authorized to 

make and submit this supplemental declaration (this “Supplemental Declaration”). This 

Supplemental Declaration is filed at the request of the Office of the United States Trustee and 

supplements the declaration of Deirdre A. McGuinness, dated June 9, 2017, (the “McGuinness 

 

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-BK3283 (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-BK3567 (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) (Last 

Four Digits of Federal Tax ID: 3747). 

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Declaration”), attached as Exhibit B to the Application of Debtors for Entry of Order Authorizing 

Employment and Payment of Epiq Bankruptcy Solutions, LLC as Service Agent, Nunc Pro Tunc 

to Petition Date, filed June 9, 2017, [D.I. 299] (the “Epiq Retention Application”). In addition, 

this Supplemental Declaration also supplements the Declaration of Bradley Tuttle, Senior Managing 

Director of Epiq Corporate Restructuring, LLC, In Support of Debtors Application Regarding 

the Employment and Retention of Epiq Corporate Restructuring, LLC and Compliance with The 

Puerto Rico Recovery Accuracy In Disclosures Act, filed May 16, 2022, [D.I. 20808] (the “Tuttle 

Declaration”). 

2. At the time of its engagement, Epiq made a full and thorough conflict review of 

potential parties in interest in these Title III cases as indicated in the McGuiness Declaration. As 

required by the PRRADA Order, Epiq completed a supplemental conflict review of potential 

parties in interest (the “Potential Parties in Interest”) and a copy of the list of Potential Parties in 

Interest was annexed to the Tuttle Declaration as Exhibit 1. The results of the conflicts check 

were compiled and reviewed by employees of Epiq, under my supervision. There are forty-five 

(45) entities that comprise the Epiq Global enterprise. I authorized the search across the Epiq 

Global database where the clients and business relationships of all 45 entities in the Epiq Global 

enterprise are stored for all Epiq Global entities from the top level parent company DTI Topco, 

Inc., to all of its affiliates, including Epiq Corporate Restructuring, LLC and Epiq eDiscovery 

Solutions. To the best of my knowledge, and based solely upon information provided to me by 

the Debtors, neither Epiq, nor any of its affiliates and owners and investors, have any connection 

to the Debtors, their creditors or other relevant parties, by reason of any direct or indirect 

relationship to, connection with, or interest in, the Debtors, or for any other reason. 

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3. As noted in the Tuttle Declaration, at this time, Epiq is not aware of any 

relationship that would present a disqualifying conflict of interest. In addition Epiq has been a 

disinterested person (as defined in 11 U.S.C. § 101(14)) at all times during its representation of 

the Oversight Board. 

4. To the best of my knowledge and based solely upon information provided to me 

by the Debtors, and except as provided herein, neither Epiq, nor any of its professionals, has any 

adverse connection to the Debtors, its creditors or other relevant parties. In addition, to the best 

of my knowledge, neither Epiq, or its professionals serving on the engagement team have held 

any debt or equity securities of the Debtors. 

5. I am generally familiar with the Bankruptcy Code and the Bankruptcy Rules, and 

Epiq will comply with them, subject to the Orders of this Court. In accordance with 28 U.S.C. § 

1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my 

information, knowledge and belief. 

Dated: August 11, 2022 

New York, New York 

/s/ Bradley Tuttle 

Bradley Tuttle 

Senior Managing Director 

Epiq Corporate Restructuring, LLC 

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