UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

-------------------------------------------------------------x

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

 Debtors.1

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of 

THE EMPLOYEES RETIREMENT

SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO (“ERS”),

 Debtor.2

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3566-LTS

(Joint Administration Requested)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of 

THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”),

 Debtor.3

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3567-LTS

(Joint Administration Requested)

 

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 BK 3283-LTS) (Last Four Digits of Federal Tax ID: 

3481); and (ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case 

No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474).

2

The last four (4) digits of ERS’s federal tax identification number are 9686.

3

The last four (4) digits of HTA’s federal tax identification number are 3808.

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DEBTORS’ STATUS REPORT REGARDING (A) FINANCIAL DISCLOSURES

TO CREDITORS AND (B) STATUS OF SETTLEMENT DISCUSSIONS

To the Honorable United States District Court Judge Laura Taylor Swain:

The Commonwealth of Puerto Rico (the “Commonwealth”), the Puerto Rico Sales Tax 

Financing Corporation (“COFINA”), the Puerto Rico Highways and Transportation Authority 

(“HTA”), and the Employees Retirement System of the Government of the Commonwealth of 

Puerto Rico (the “ERS,” and together with the Commonwealth, COFINA, and HTA, the 

“Debtors”), by and through the Financial Oversight and Management Board for Puerto Rico (the 

“Oversight Board”), as the Debtors’ representative pursuant to section 315(b) of the Puerto Rico 

Oversight, Management, and Economic Stability Act (“PROMESA”),4respectfully submit this 

status report (the “Status Report”), as directed by the Court at the May 17, 2017 hearing in the 

Initial Title III Cases (as defined herein):

Background

1. On June 30, 2016, the Oversight Board was established under PROMESA section 

101(b). On August 31, 2016, President Obama appointed the Oversight Board’s seven voting 

members.

2. Pursuant to PROMESA section 315, “[t]he Oversight Board in a case under this 

title is the representative of the debtor[s]” and “may take any action necessary on behalf of the 

debtor[s] to prosecute the case[s] of the debtor[s], including filing a petition under section 304 of 

[PROMESA] . . . or otherwise generally submitting filings in relation to the case[s] with the 

court.”

3. On September 30, 2016, the Oversight Board designated the Debtors as covered 

entities under PROMESA section 101(d).

 

4

PROMESA has been codified in 48 U.S.C. §§ 2101-2241.

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4. On May 3, 2017, the Oversight Board issued a restructuring certification pursuant 

to PROMESA sections 104(j) and 206 and filed a voluntary petition for relief for the 

Commonwealth pursuant to section 304(a) of PROMESA, commencing a case under title III 

thereof (the “Commonwealth’s Title III Case”).

5. On May 5, 2017, the Oversight Board issued a restructuring certification pursuant 

to PROMESA sections 104(j) and 206 and filed a voluntary petition for relief for COFINA 

pursuant to PROMESA section 304(a), commencing a case under title III thereof (together with 

the Commonwealth’s Title III Case, the “Initial Title III Cases”).

6. On May 21, 2017, the Oversight Board issued a restructuring certification 

pursuant to PROMESA sections 104(j) and 206 and filed a voluntary petition for relief for ERS 

and HTA pursuant to PROMESA section 304(a), commencing cases under title III thereof (the 

“Additional Title III Cases,” and collectively with the Initial Title III Cases and any subsequent 

case under Title III of PROMESA commenced by a covered territorial instrumentality under 

PROMESA, the “Title III Cases”).

7. On May 26, 2017, Judge Laura Taylor Swain was designated as the presiding 

judge in the Additional Title III Cases. See In re Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico, Case No. 17-3566 [ECF No. 16]; In re 

Puerto Rico Highways and Transportation Authority, Case No. 17-3567 [ECF No. 7].

8. On June 1, 2017, the Court entered an order granting the joint administration of 

the Initial Title III Cases, for procedural purposes only [ECF No. 242]. On June 9, 2017, the 

Debtors filed a motion seeking the joint administration of the Additional Title III Cases with the 

Initial Title III Cases [Bankruptcy Case No. 17 BK 3567-LTS, ECF No. 79; Bankruptcy Case 

No. 17 BK 3566-LTS, ECF No. 61].

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9. Background information regarding the Commonwealth and its instrumentalities, 

and the commencement of the instant Title III Cases, is contained in the Notice of Statement of 

Oversight Board in Connection with PROMESA Title III Petition [ECF No. 1], attached to the 

Commonwealth’s Title III petition.

10. At the May 17, 2017 hearing in the Initial Title III Cases, the Court directed the 

Commonwealth and COFINA to file a status report on settlement discussions with and financial 

disclosure to the Debtors’ creditors by June 15, 2017. See Minutes of Proceedings Before 

Honorable Laura Taylor Swain [ECF No. 213] (noting that “by June 15, 2017, a status report 

discussing the status of settlement discussions and financial disclosure to creditors [must be 

filed].”); see also May 17, 2017 Hr’g Tr. at 147:16-25 (“With respect to the disclosure and 

meditation issues, I would like a status report by mid June as to attention to and I hope further 

progress on issues relating to the disclosure of information to creditors. And if there are 

particular points of conflict about the structure or the nature of the information to be informed as 

to your – not in their granular specifics, but what those issues are and what is being done in terms 

of work on them, and whether there are, there have been and are ongoing further negotiation 

sessions, and as to what constituencies.”).

11. The Debtors (now including ERS and HTA) submit this Status Report in 

accordance with the Court’s direction.

Status of Financial Disclosure to Creditors and One Recurring Issue

A. Dataroom

12. The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”) has 

established the Intralinks Project AAFAF Dataroom (the “Dataroom”), in which extensive 

financial information regarding the Debtors, all of which are covered by the Commonwealth’s 

certified Fiscal Plan dated as of March 13, 2017 (as subsequently amended, the “Certified Fiscal 

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Plan”), has been made available to creditor groups and their financial and legal advisors

beginning on April 5, 2017. Such information includes, without limitation, the Certified Fiscal 

Plan, the Fiscal Plan Model in Excel format,5and the Fiscal Plan Debt Model in Excel format.

6

 

The Dataroom also includes over 40 source documents covering macroeconomic assumptions, 

revenues, expenses, measures, and other categories, and has been updated and supplemented 

following discussions with creditor groups and their advisors.

13. A “live” version of the Fiscal Plan Model, which includes formulae and links 

between tabs of the file, was provided to the creditor groups seeking such information by posting 

it to the Dataroom on June 6, 2017. A detailed overview of the Fiscal Plan Model, each of its 

tabs, how they relate to each other, and what relevant sources and documents have been made 

available to creditor groups through the Dataroom, has been prepared by AAFAF’s financial 

advisor, Rothschild & Co. This overview was provided to creditors requesting financial 

information on June 13, 2017 as described below. A copy of this overview is attached hereto as 

Exhibit A.

 

5

The Fiscal Plan Model provides the detailed buildup of the revenue, expenses, and measures 

presented in the Government of Puerto Rico’s Certified Fiscal Plan for Fiscal Years 2017 –

2026.

6

The Fiscal Debt Model provides the detailed buildup of the forecasted debt service 

requirements (if not restructured) for the Government of Puerto Rico for Fiscal Years 2017 –

2047. Detailed debt schedules are provided for (a) general obligation (“GO”), (b) Puerto Rico 

Building Authority, (c) COFINA, (d) HTA, (e) Puerto Rico Convention Center District 

Authority, (f) Puerto Rico Infrastructure Financing Authority, (g) Puerto Rico Public Finance 

Corporation, (h) University of Puerto Rico, (i) ERS, (j) GDB (as defined herein), and 

(k) Puerto Rico Industrial Development Company bonds, with source data from Bloomberg 

provided as well. Other information includes the capitalization table summarizing the total debt 

for the Government of Puerto Rico as of February 1, 2017, a summary of public corporation 

debt outstanding as of December 31, 2016, and a schedule of unpaid principal and interest 

payments through February 1, 2017.

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B. Publicly-Available Financial Information

14. In addition to the Dataroom, financial and other information has been made

publicly available on the Oversight Board’s website, and other governmental websites. This 

information includes the fiscal year 2018 budget broken down by agency, the fiscal year 2018 

general fund budget proposal, the Office of Management and Budget’s report on the fiscal year 

2018 budget proposal, the Commonwealth’s quarterly report, information relating to public 

pensions, and documents identifying rents paid by the Territorial Government or any Territorial 

Government Instrumentality to the Public Building Authority, among other information. A 

further list of publicly available information, including the entity providing the information, the 

web link, and the type of information, is attached hereto as Exhibit B.

15. Although certain creditors have complained that some data provided to them is 

publically available, the Commonwealth’s publication of extensive financial data does not render 

it any less pertinent. 

C. Q&A with Creditors

16. On April 6, 2017, AAFAF and the Oversight Board held an initial meeting with 

62 representatives of the GO and COFINA creditor groups, including several of their financial 

advisors. At that meeting, AAFAF provided an introduction to the Certified Fiscal Plan (which 

was made publicly available on both the AAFAF and Oversight Board’s websites on March 13, 

2017), and conducted a brief question and answer session. The Oversight Board’s economist 

answered questions about the economic assumptions underlying the fiscal plan. After the 

meeting, the creditors’ financial advisors were invited to submit diligence questions, and a total 

of 346 questions were submitted on April 7-8, 2017. The questions covered a range of topics, 

including debt, expenses, healthcare, liquidity, macroeconomic assumptions, measures, the 

Fiscal Plan Model, pensions, and revenue. The Debtors provided responses to 262 of such 

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questions on April 11, 2017, which are available in the Dataroom. This response rate is high 

given several factors, including the time constraints, and that many of the requests sought 

documents and information that do not exist, are privileged, or involve proprietary models of 

AAFAF or the Oversight Board.

17. Shortly thereafter, on April 11, 2017, a financial diligence session was held with 

34 representatives of financial advisors for the GO and COFINA creditor groups, including the 

monoline insurers. AAFAF and its advisors presented on several topics and answered questions 

relating to macroeconomic assumptions, baseline revenue and expenses, measures, liquidity, and 

financial controls and procurement. AAFAF subsequently made additional information available

to, and answered myriad questions by, creditor groups in attendance at mediation sessions held 

on April 13, 17, 20, and 25, 2017. Additionally, several members of the Oversight Board and its 

business advisors attended and answered creditors’ questions at the mediation sessions.

D. Subsequent Information Requests 

18. Following the May 17, 2017 hearing in the Initial Title III Cases, the Debtors 

received extensive informal information requests (the “Informal Requests”) from attorneys for

the Ad Hoc Group of Puerto Rico General Obligation Bondholders (the “GO Group”), Assured 

Guaranty Corp. and Assured Guaranty Municipal Corp. (collectively, “Assured”), and National 

Public Finance Guarantee Corporation. The requests generally fall into the following categories:

a. documents relating to the Certified Fiscal Plan, including models, analyses, 

assumptions, sensitivities, and projections;

b. documents relating to the Debtors’ revenues, including projected revenues and 

use of taxes;

c. documents relating to the Debtors’ expenses, including projected expenses;

d. documents relating to the Commonwealth’s debt sustainability, including the 

Commonwealth’s access to capital markets and analyses relied upon in 

determining the Commonwealth’s sustainable debt load; and

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e. documents relating to the restructuring or wind down of the Government 

Development Bank of Puerto Rico (the “GDB”).7

19. Many of the Informal Requests relate directly to information that has already been 

made available to the requesting parties. As described above, the Commonwealth has made a 

large amount of the requested data public to comply with its own laws and rules concerning 

public disclosure.8 Also, the Dataroom contains relevant data readily understandable and useful 

to any financial professional willing to examine it.

20. Significantly, the same monoline insurers and other entities requesting data have 

now filed multiple adversary proceedings involving the same data, including:

a. Adv. Proc. No. 17-00125, Assured Guaranty Corp., et al. v. Commonwealth of 

Puerto Rico, et al.

b. Adv. Proc. No. 17-00151, Peaje Investment, LLC v. Puerto Rico Highways & 

Trans. Authority, et al.

c. Adv. Proc. No. 17-00152, Peaje Investment, LLC v. Puerto Rico Highways & 

Trans. Authority, et al.

d. Adv. Proc. No. 17-00155, Assured Guaranty Corp., et al. v. Commonwealth of 

Puerto Rico, et al.

e. Adv. Proc. No. 17-00156, Assured Guaranty Corp., et al. v. Commonwealth of 

Puerto Rico, et al.

f. Adv. Proc. No. 17-00159, Ambac Assurance Corporation v. Commonwealth of 

Puerto Rico, et al.

 

7

The GDB has not commenced a Title III Case.

8

The fact that such information is public does not make the disclosures or availability any less 

responsive to the requests received, and indeed, the Debtors have already borne the expenses 

associated with culling through such data and identifying information of particular relevance.

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Notably, neither the Oversight Board nor AAFAF has refrained from disclosing additional data 

based on the filing of the foregoing adversary proceedings. But, given the extensive data already 

produced and the litigants’ implicit admissions that they have sufficient data to allege causes of 

action, the Oversight Board and AAFAF have reserved their rights to do so.

21. On June 13, 2017, the Oversight Board and AAFAF provided preliminary written 

responses to the creditors’ document requests and provided directions to relevant materials.9 In 

their preliminary responses, the Oversight Board and AAFAF agreed to produce a substantial 

amount of additional data and documents related and responsive to the Informal Requests, 

including “raw” data (i.e. revenue, cash flow, “clawback,” and expense data) used in the 

Certified Fiscal Plan, to the extent such data exists. Those requests are being fulfilled on an 

ongoing basis, and the Oversight Board and AAFAF are making every effort to complete 

uploading of reasonably accessible data to the Dataroom by end of June. The June 13 responses 

also included the detailed overview of the Fiscal Plan Model and related material in the 

Dataroom as set forth on Exhibit A hereto to assist the requesting parties in making full use of 

these materials.

22. Although the Debtors and AAFAF have agreed to produce, or have already

produced, documents and data responsive to the Informal Requests, the Debtors and AAFAF 

also reserved their rights and interposed objections to certain of the Informal Requests in their 

June 13 responses. With respect to certain documents, communications, and analyses, the 

Debtors have asserted that privileges, protections, or immunities apply and shield production of 

 

9

For example, the GO Group and Assured requested “[a] complete version of the Fiscal Plan, 

including any amendments mandated by the Board Resolution Adopted March 13, 2017.” A 

complete, live version of the Fiscal Plan has already been uploaded to the Dataroom.

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those documents, including, without limitation, the attorney-client privilege, the deliberative 

process privilege or the executive privilege,

10 and/or the attorney work product doctrine. 

23. When the Debtors believed certain of the Informal Requests were unduly 

burdensome, overly broad, or irrelevant to the resolution of the Title III Cases, the Oversight 

Board and AAFAF invited the requesting parties to meet and confer with them to clarify and 

narrow the scope of the subject Informal Requests.

24. The Recurring Issue. On March 13, 2017, the Oversight Board certified the 

Commonwealth’s fiscal plan which contained a debt sustainability analysis showing exactly how 

much money would be available to service debt. In a nutshell, the problem is not the disclosure 

of data. Rather, creditors do not like the disclosed data and the debt sustainability it supports. 

Accordingly, rather than negotiate to divide up the money available for debt service under the 

fiscal plan, the creditors have been very clear that they want the Oversight Board to certify a 

different fiscal plan showing more debt can be sustained. To accomplish their goal of 

compelling the Oversight Board to redo the fiscal plan, creditors have demanded production of 

all documents relating to virtually every decision the Oversight Board made to conclude to 

certify the current fiscal plan. And, while the Oversight Board wishes it could satisfy creditors’ 

desires for higher repayments, the Oversight Board is resolute that it will only certify fiscal plans 

 

10 “[D]eliberative process [privilege] covers ‘documents reflecting advisory opinions, 

recommendations and deliberations comprising part of a process by which governmental 

decisions and policies are formulated.’” Dep’t of Interior v. Klamath Water Users Protective 

Ass’n, 532 U.S. 1, 8 (2001). [“The deliberative process privilege rests on the obvious 

realization that officials will not communicate candidly among themselves if each remark is a 

potential item of discovery and front page news, and its object is to enhance ‘the quality of 

agency decisions’ by protecting open and frank discussion among those who make them within 

the Government.” Id. at 8-9.] The deliberative process privilege is the federal counterpart of 

Puerto Rico’s official information privilege. See W Holding Co. v. Chartis Ins. Co. of Puerto 

Rico, 42 F. Supp.3d 319, 324 (D.P.R. 2014) (characterizing Puerto Rico’s official information 

privilege and federal deliberative process privilege as “essentially co-extensive”).

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it believes are feasible and will create fiscal responsibility and capital market access, as 

PROMESA requires. In chapter 11, creditors sometimes negotiate and litigate the debtor’s 

business plan. PROMESA, however, goes to extraordinary lengths to prevent that from 

happening. 

25. PROMESA section 106(e) provides “There shall be no jurisdiction, in any United 

States district court to review challenges to the Oversight Board’s certification determinations 

under this Act.” Even though Congress barred challenges to certified fiscal plans, many 

creditors want to take discovery as if the Court has jurisdiction over an action challenging the 

fiscal plan.11 Indeed, some creditors have commenced actions challenging the fiscal plan and 

have requested discovery outside the actions seeking data relating to the actions. See, e.g., 

Adv. Proc. No. 17-00125, Assured Guaranty Corp., et al. v. Commonwealth of Puerto Rico, et 

al., and Adv. Proc. No. 17-00159, Ambac Assurance Corporation v. Commonwealth of Puerto 

Rico, et al.

26. The public policies PROMESA carries out are clear, namely to encourage the 

Oversight Board to make the best judgments its can make in certifying a fiscal plan, by being 

completely protected from governmental and creditor pressures. PROMESA sections 101(b)(1)

and 101(g) establish the Oversight Board as seven uncompensated members, and PROMESA 

sections 104, 108(a), and 201-207 empower the Oversight Board to make fiscal, budgetary, and 

other decisions for the Commonwealth and its instrumentalities, independently of the Governor 

 

11 PROMESA section 201(c)(3), among other sections, provides that the Oversight Board 

“determines in its sole discretion” whether a fiscal plan satisfies PROMESA’s requirements. 

PROMESA section 105 provides “[t]he Oversight Board, its members, and its employees shall 

not be liable for any obligation of or claim against the Oversight Board or its members or 

employees or the territorial government resulting from actions taken to carry out this Act.”

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and Legislature. The Oversight Board’s certifications are not even subject to being secondguessed by the Court. PROMESA § 106(e). In sum, Congress expressly took extraordinary 

steps to insulate the Oversight Board from third party pressure and the temptation to make overly

optimistic economic assumptions to justify more governmental services and more debt service

than the Oversight Board believes is realistic. 

27. To be clear, creditors’ rights under the United States constitution are protected. If 

a creditor believes its collateral is being taken for public use without just compensation, nothing 

prevents the creditor from requesting stay relief if it does not obtain adequate protection or just 

compensation. 

28. Some creditors contend they will be entitled to discovery into the Certified Fiscal 

Plan when they object to confirmation because PROMESA section 201(b)(1)(N) requires fiscal 

plans to respect lawful priorities and liens, and PROMESA section 314(b)(6) requires a plan of 

adjustment to be in the best interests of creditors after considering what creditors would receive 

if they enforced their remedies under Commonwealth law and its priorities. Conversely, the 

Oversight Board believes the creditors will simply prove what they would receive if they all 

enforced their claims, and compare that to what the plan of adjustment provides them. No 

discovery into the fiscal plan would have any relevance. Similarly, some creditors contend that 

because PROMESA section 314(b)(7) requires a plan of adjustment to be consistent with a 

certified fiscal plan, discovery into the Certified Fiscal Plan is required. To be sure, the Certified 

Fiscal Plan and its budget will always be public documents and discoverable. Consistency with 

the fiscal plan, however, will not turn on the process leading up to certification of the fiscal plan 

or discovery into that deliberative process.

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29. It appears the recurring discovery issue involving the Certified Fiscal Plan will be 

resolved in the pending adversary proceedings attempting to challenge the certification. For 

now, the Oversight Board and AAFAF will continue to provide creditors the raw data underlying 

the Certified Fiscal Plan. 

Progress Toward Resolution of Creditor Disputes

30. On June 10, 2017, the Debtors filed the Motion of Debtors for Order Approving 

Procedure to Resolve Commonwealth-COFINA Dispute [ECF No. 303] (the “Dispute Procedures

Motion”) seeking to establish, among other things, procedures to resolve the ongoing dispute 

between the Commonwealth, on the one hand, and COFINA, on the other, regarding their 

competing interests in certain sales and use taxes collected in Puerto Rico (the “SUT Dispute”). 

By the Dispute Procedures Motion, the Commonwealth and COFINA seek to have independent 

agents chosen by the Oversight Board from creditor nominations represent their respective 

interests with respect to the SUT Dispute, with the aspiration of consensual resolution. Absent 

consensual resolution, and under the schedule contemplated by the Dispute Procedures Motion, 

the Court should have the opportunity to adjudicate the SUT Dispute, on or before November 1, 

2017. The Debtors and Oversight Board are hopeful the Dispute Procedures Motion will result 

in the consensual resolution of outstanding issues between and among the Commonwealth, 

COFINA, their creditors, and other parties in interest. 

31. By notice and order dated June 14, 2017 [ECF No. 329], the Court established a 

very eminent mediation team of sitting federal judges having extraordinary restructuring 

experience. That team can only enhance the prospects of success for Puerto Rico. If the Dispute 

Procedures Motion is granted, the two agents may well be able to negotiate a settlement with the 

aid of the mediation team. 

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32. By motion dated June 7, 2017 [Bankruptcy Case No. 17 BK 3284-LTS, ECF No.

139], The Puerto Rico Funds and the Mutual Funds Group requested stay relief to prosecute a 

motion requesting that the SUT Dispute be certified to the Puerto Rico Supreme Court. In their 

responses to that motion, the Oversight Board and AAFAF will explain why they believe the 

SUT Dispute should be decided by the Title III Court.

33. In addition, the GDB, in coordination with AAFAF, has negotiated a term sheet 

and restructuring support agreement (the “GDB RSA”) with its bondholders and nonCommonwealth affiliated depositors (the “Affected Creditors”). The GDB RSA contemplates a 

wind-down of the GDB and its assets, with returns from those assets used to fund recoveries to 

creditors. In exchange for current bonds and non-governmental deposit claims, new bonds will 

be issued by a special purpose vehicle in a securitization structure and without recourse to the 

GDB.

34. The GDB and AAFAF have notified the Oversight Board that close to 50% of 

Affected Creditors are already signatories to the GDB RSA. As a result, the GDB has expressed 

its desire to pursue a Title VI Qualifying Modification through a voluntary agreement process. 

The GDB intends to submit a proposed modification to the Oversight Board for certification as a 

Qualifying Modification under PROMESA section 601(g)(2) within the coming weeks. The 

Oversight Board has been in close consultation with representatives of AAFAF regarding the 

information the Oversight Board requires in order to make various certification determinations 

under Title VI of PROMESA.

Notice

35. The Debtors have provided notice of this Status Report to the following parties: 

(a) the Office of the United States Trustee for the District of Puerto Rico; 

(b) the indenture trustees and/or agents, as applicable, for the Debtors’ bonds; (c) the entities on 

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the list of creditors holding the 20 largest unsecured claims against each Debtor; (d) the Office of 

the United States Attorney for the District of Puerto Rico; (e) counsel to the Puerto Rico Fiscal 

Agency and Financial Advisory Authority on behalf of the Governor of Puerto Rico; (f) the 

Puerto Rico Department of Justice; (g) the Other Interested Parties;

12 and (h) all parties filing a 

notice of appearance in these Title III Cases.

Reservation of Rights

36. By this Status Report, neither the Debtors nor the Oversight Board waives or 

releases any rights.

[Remainder of Page Intentionally Left Blank]

 

12The “Other Interested Parties” include the following: (i) counsel to certain of the insurers and 

trustees of the bonds issued or guaranteed by the Debtors; and (ii) counsel to certain ad hoc 

groups of holders of bonds issued or guaranteed by the Debtors.

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Dated: June 15, 2017

San Juan, Puerto Rico

Respectfully submitted,

/s/ Martin J. Bienenstock

Martin J. Bienenstock

Paul V. Possinger 

Ehud Barak 

Maja Zerjal 

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

/s/ Hermann D. Bauer 

Hermann D. Bauer

USDC No. 215205

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

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