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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INFORMATIVE MOTION OF OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS REGARDING JUNE 6-7, 2018 OMNIBUS HEARING

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”) hereby submits this informative motion in response to the Court’s

Order (I) Regarding Procedures for Attendance, Participation and Observation of June 6-7, 

2018, Omnibus Hearing and (II) Directing the Oversight Board to Provide a Status Report at the 

Omnibus Hearing, dated May 16, 2018 [Docket No. 3075] (the “Scheduling Order”) and

respectfully states as follows:

 

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-BK-3567 (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 (LTS)) 

(Last Four Digits of Federal Tax ID: 3747).

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1. Luc A. Despins of Paul Hastings LLP will appear in person on behalf of the 

Committee at the Hearing (as defined in the Scheduling Order) on June 6, 2018 in Courtroom 3 

of the United States District Court for the District of Puerto Rico, and address, as necessary, the 

following matters:

(a) Renewed Motion Seeking Entry of Order, Under Bankruptcy Rule 2004, 

Authorizing Discovery With Respect to Certain Causes of Puerto Rico Financial 

Crisis Beginning on August 15, 2018 [Docket No. 3066];

(i) Omnibus Reply in Support of Renewed Motion of Creditors' Committee 

Seeking Entry of Order, Under Bankruptcy Rule 2004, Authorizing 

Discovery Program With Respect to Certain Causes of Puerto Rico 

Financial Crisis Beginning on August 15, 2018 [Docket No. 3183];

(b) Motion of the Official Committee of Retired Employees of the Commonwealth of 

Puerto Rico Regarding Representation of PREPA Retirees [Docket No. 3056]; 

(i) Statement of Official Committee of Unsecured Creditors in Response to 

Motion of the Official Committee of Retired Employees of the 

Commonwealth of Puerto Rico Regarding Representation of PREPA 

Retirees [Docket No. 3114];

(c) Joint Motion for Entry of an Order Further Amending the Interim Compensation 

Order [Docket No. 3133];

(d) Motion of the Fee Examiner to Amend the Fee Examiner Order with Respect to 

the Scope of the Fee Examiner’s Authority in the Interest of Administrative 

Efficiency [Docket No. 3032];

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(e) Second Interim Fee Application of Paul Hastings LLP, as Counsel to Official 

Committee of Unsecured Creditors, for Services Rendered and Reimbursement of 

Expenses for Period from October 1, 2017 through January 31, 2018 [Docket No. 

2735]; 

(f) Second Interim Application of Members of Official Committee of Unsecured 

Creditors, for Reimbursement of Expenses for Period through January 31, 2018

[Docket No. 2737];

(g) Any objections, responses, joinders, statements, or replies to any of the foregoing

pleadings; and

(h) Any statements made by any party in connection with the title III cases or any 

adversary proceeding pending therein.

2. In addition, Mr. Juan J. Casillas Ayala of Casillas, Santiago & Torres LLC and 

one of his co-counsel will also be attending, on behalf of the Committee, the Hearing.

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WHEREFORE, the Committee respectfully requests that the Court take notice of the 

above. 

Dated: May 30, 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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