UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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In re: : 

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THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

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 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 JULY 25-26, 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 Regarding Procedures for Attendance, Participation and Observation of July 25-26, 2018, 

Omnibus Hearing, dated July 10, 2018 [Docket No. 3472] (the “Scheduling Order”) and 

respectfully states as follows: 

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) in Courtroom 2 of the United 

 

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 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); and (v) 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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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];

(ii) Creditors' Committee's Informative Motion Regarding Renewed Rule 2004 

Motion and Discovery Items to Be Addressed at July 25, 2018 Omnibus 

Hearing [Docket No. 3424];

(b) Motion of the Independent Investigator for an Order: (I) Establishing Procedures 

for Resolving Any Confidentiality Dispute in Connection With Publication of the 

Independent Investigator’s Final Report; (II) Approving the Disposition of 

Documents and Information; (III) Relieving the Independent Investigator From 

Certain Discovery Obligations; (IV) Exculpating the Independent Investigator in 

Connection With the Investigation and Publication of the Final Report; and (V) 

Granting Related Relief [Docket No. 3427];

(i) Creditors' Committee's Joinder to Retiree Committee's Limited Objection 

Regarding Investigator's Exit Plan Motion [Docket No. 3498];

(c) Motion of Official Committee of Unsecured Creditors to Clarify or Amend Fourth 

Amended Notice, Case Management and Administrative Procedures Regarding 

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Disclosure Requirements Pursuant to Federal Rule of Bankruptcy Procedure 

2019 [Docket No. 3432];

(i) Reply of Official Committee of Unsecured Creditors in Support of Motion 

to Clarify or Amend Fourth Amended Notice, Case Management and 

Administrative Procedures Regarding Disclosure Requirements Pursuant 

to Federal Rule of Bankruptcy Procedure 2019 [Docket No. 3607];

(d) Official Committee of Unsecured Creditors' (A) Urgent Motion, Pursuant to 

Bankruptcy Code Section 105(a), to Compel Debtors to Comply With Interim 

Compensation Orders and (B) Joinder in Motions of Retiree Committee and 

COFINA Agent to Compel Compliance With Same [Docket No. 3604];

(e) Commonwealth Agent's Renewed Motion, Pursuant to Bankruptcy Code Section 

105(a) and Bankruptcy Rule 9019, for Order Establishing Procedures Governing 

5.5% SUT Revenues Collected On or After July 1, 2018 [Adv. Proc. No. 17-257, 

Docket No. 526];

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

pleadings; and

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

adversary proceeding pending therein. 

2. In addition, Luc A. Despins of Paul Hastings LLP reserves the right, in 

accordance with the Order Granting Limited Intervention [Adv. Proc. No. 18-080, Docket No. 

13], to address, as necessary, the issues raised in: 

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(a) Defendants’ Notice of Motion Pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6) to 

Dismiss Plaintiffs’ Complaint Dated July 5, 2018 [Adv. Proc. No. 18-080, Docket 

No. 16]; 

(b) Defendants’ Memorandum of Law in Support of Motion Pursuant to Fed. R. Civ. 

P. 12(b)(1) and 12(b)(6) to Dismiss Plaintiffs’ Complaint Dated July 5, 2018

[Adv. Proc. No. 18-080, Docket No. 17]; and 

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

pleadings.

3. 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: July 19, 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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