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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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STATEMENT OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS 

IN RESPONSE TO MOTION BY AMERICAN FEDERATION OF STATE, COUNTY 

AND MUNICIPAL EMPLOYEES, AFL-CIO (AFSCME) TO

COMPEL COMPLIANCE WITH AUGUST 10, 2017 STIPULATION AND ORDER

To the Honorable United States District Judge Laura Taylor Swain:

The Official Committee of Unsecured Creditors of all title III Debtors (other than 

COFINA) (the “Committee”), as the “Commonwealth Agent” with respect to the

“Commonwealth-COFINA Dispute,” as defined in the Stipulation and Order Approving

Procedure to Resolve Commonwealth-COFINA Dispute [Docket No. 996] (the 

“Commonwealth-COFINA Dispute Stipulation”), hereby submits this statement in response to 

the Motion by the American Federation of State, County and Municipal Employees, AFL-CIO 

 

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 (the “Commonwealth”) 

(Bankruptcy Case No. 17-BK-3283 (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-BK-3567 (LTS)) (Last Four Digits of Federal Tax ID: 3808), and 

(iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284 (LTS)) 

(Last Four Digits of Federal Tax ID: 8474).

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(AFSCME) to Compel Compliance with the August 10, 2017 Stipulation and Order [Docket No. 

3092] (the “Motion”), and respectfully states as follows: 

STATEMENT

The Commonwealth Agent is not the target of the Motion. If anything, the 

Commonwealth Agent is the party that may have been bypassed by certain negotiations between 

the GO Creditor Representative and certain other parties, and the Commonwealth Agent reserves 

its right to respond at the appropriate time to any position taken or disclosure made by any party 

with respect to such matters (including with respect to any violations of the confidentiality

provisions in the mediation agreement related to this court’s Order Appointing Mediation Team

[Docket No. 430]). Moreover, the Commonwealth Agent has always been in compliance, and 

will remain in compliance, with the terms of the Commonwealth-COFINA Dispute Stipulation,

and it has been negotiating, and is continuing to negotiate, with the COFINA Agent with respect 

to the Commonwealth-COFINA Dispute. The Commonwealth Agent does not believe that any

additional response to the Motion is required at this time. 

[Remainder of page intentionally left blank.]

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Dated: May 24, 2018 /s/ G. Alexander Bongartz .

PAUL HASTINGS LLP

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

James R. Bliss, Esq. (Pro Hac Vice)

James B. Worthington, 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 

jamesbliss@paulhastings.com

jamesworthington@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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