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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FOURTH SUPPLEMENTAL DECLARATION OF LUC A. DESPINS REGARDING 

RETENTION OF PAUL HASTINGS LLP AS COUNSEL TO OFFICIAL 

COMMITTEE OF UNSECURED CREDITORS 

I, Luc A. Despins, hereby declare under penalty of perjury: 

1. I am a partner in the law firm of Paul Hastings LLP (“Paul Hastings”) with offices 

worldwide, including 200 Park Avenue, New York, New York 10166, and am admitted to 

practice in the State of New York. The facts set forth in this supplemental declaration (the 

“Fourth Supplemental Declaration”) are based upon my personal knowledge, discussions with 

other Paul Hastings attorneys, and the firm’s client/matter records that were reviewed by me or 

other Paul Hastings attorneys acting under my supervision and direction. 

2. On July 10, 2017, I submitted a declaration (the “Initial Declaration”) in support 

of the Application for Order Pursuant to Bankruptcy Code Section 1103(a) and Local 

 

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) (Last 

Four Digits of Federal Tax ID: 3747). 

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Bankruptcy Rule 2014-1(e) Authorizing the Employment and Retention of Paul Hastings LLP as 

Counsel to Official Committee of Unsecured Creditors, Effective as of June 26, 2017 [Docket 

No. 610] (the “Retention Application”)2

 filed by the Official Committee of Unsecured Creditors 

of the Commonwealth of Puerto Rico in the above-captioned cases. On August 25, 2017, the 

U.S. Trustee expanded the role of that Committee to be the official committee for the HTA, ERS, 

and PREPA Debtors. The “Committee” refers to the official creditors’ committee of all Title III 

Debtors (other than COFINA). 

3. By order of this court entered August 10, 2017 [Docket No. 999] (the “Retention 

Order”), Paul Hastings’ retention as counsel for the Committee was approved effective as of 

June 26, 2017. The Retention Order provided that “[t]he retention of Paul Hastings, as counsel 

to the Committee, shall be deemed to apply to the representation of the Committee if ever 

enlarged to include unsecured creditors of other debtors, without the need to obtain a 

modification of this Order.” Accordingly, Paul Hastings’ retention extends to the representation 

of the Committee as the official committee for the HTA, ERS, and PREPA Debtors. 

4. On September 22, 2017, I submitted the First Supplemental Declaration of Luc A. 

Despins Regarding Retention of Paul Hastings LLP as Counsel to Official Committee of 

Unsecured Creditors [Docket No. 1357] (the “First Supplemental Declaration”). 

5. On February 13, 2018, I submitted the Second Supplemental Declaration of Luc 

A. Despins Regarding Retention of Paul Hastings LLP as Counsel to Official Committee of 

Unsecured Creditors [Docket No. 2485] (the “Second Supplemental Declaration”). 

6. On July 27, 2018, I submitted the Third Supplemental Declaration of Luc A. 

Despins Regarding Retention of Paul Hastings LLP as Counsel to Official Committee of 

 

2

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Retention 

Application. 

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Unsecured Creditors [Docket No. 3712] (the “Third Supplemental Declaration” and, together 

with the Initial Declaration, the First Supplemental Declaration, and the Second Supplemental 

Declaration, the “Prior Declarations”). I hereby incorporate by reference, in their entirety, the 

Prior Declarations as if fully set forth herein. 

Review and Disclosure of Additional Interested Parties 

7. Since filing the Third Supplemental Declaration, Paul Hastings has become aware 

of additional Interested Parties (collectively, the “Additional Interested Parties”) in the title III 

cases of the Commonwealth, COFINA, ERS, HTA, and PREPA (collectively, the “Title III 

Cases”) with which Paul Hastings was able to confirm that it has, or may have, a connection. 

The identities of the Additional Interested Parties are set forth on Exhibit A hereto and include 

parties that have been added to the Master Service List (as of September 20, 2018) in the jointly 

administered Title III Cases (i.e., the Commonwealth, COFINA, ERS, HTA, and PREPA) since 

the filing of the Third Supplemental Declaration.3 

8. In preparing this Fourth Supplemental Declaration, I caused to be submitted for 

review under Paul Hastings’ conflicts check system the names of the Additional Interested 

Parties. The results of our conflicts check were compiled and analyzed by Paul Hastings 

attorneys acting under my supervision. While certain individuals and entities may be Interested 

Parties in more than one capacity in the Title III Cases, e.g., as a creditor in one or multiple title 

III cases and as a party that has filed a notice of appearance, Paul Hastings’ updates do not cover 

changes in capacity during the course of a bankruptcy case. Given the prior disclosure of Paul 

Hastings’ relationship, if any, to such entities, such disclosure is not repeated here. 

 

3

 To avoid duplication, entities that were included on Exhibit A to the Prior Declarations have not been included 

again on Exhibit A to this Fourth Supplemental Declaration. Exhibit A does not include the more than 13,000 

individuals that were included in the Rule 2019 statements filed on behalf of certain plaintiff groups. 

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9. To the extent the conflicts check searches indicated that Paul Hastings has 

performed services for any Additional Interested Party within the last five years, the identity of 

such entity and the nature of Paul Hastings’ relationship with such entity are set forth in 

Exhibit B hereto. Exhibit B does not include relationships that Paul Hastings has with parents 

or affiliates of entities that were previously disclosed in the Prior Declarations. 

10. To the best of my knowledge, based on the review procedures described above, 

Paul Hastings does not have any “connection” to the Additional Interested Parties, except as 

described in the Prior Declarations or in this Fourth Supplemental Declaration. Neither the term 

“connection,” as used in Bankruptcy Rule 2014, nor the proper scope of a professional’s search 

for “connection” has been defined; out of an abundance of caution, therefore, I am disclosing 

many representations that are not, to my understanding, disqualifying or problematic under 

PROMESA, the Bankruptcy Code, or applicable standards of professional ethics. 

11. Neither I, nor any partner, of counsel, or associate of Paul Hastings, as far as I 

have been able to ascertain, has any connection with any Additional Interested Party, except as 

set forth below or otherwise in the Prior Declarations or this Fourth Supplemental Declaration 

(including the Exhibits hereto): 

(a) Attached hereto as Exhibit B and incorporated herein by reference is a list of 

Additional Interested Parties (or their affiliates) whom Paul Hastings represents, 

or has represented in the past, in matters unrelated to the matters on which the 

Committee has retained Paul Hastings. Although Paul Hastings has represented, 

currently represents, and may continue to represent certain entities and individuals 

listed on Exhibit B hereto, Paul Hastings will not represent any such entity or 

individual in the Title III Cases. 

(b) Each of the entities identified on Exhibit B hereto as a “current client” accounted 

for less than 1.3% of Paul Hastings’ revenues for the firm’s fiscal year ending 

January 31, 2018. For the avoidance of doubt, the services performed for such 

entities were unrelated to the matters on which the Committee has retained Paul 

Hastings. 

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New Hires 

12. Since filing the Third Supplemental Declaration, a number of individuals, 

including attorneys, legal interns, librarians, paralegals, and other paraprofessionals (collectively, 

the “New Hires”) have joined (or will shortly join) Paul Hastings. Except as detailed below per 

their input in the hiring process, these New Hires neither (i) worked on matters related to the 

Debtors or to Interested Parties in the Title III Cases nor (ii) were exposed to confidential 

information related to the Debtors or to Interested Parties in the Title III Cases in connection 

with their prior positions. Out of an abundance of caution, Paul Hastings has, nonetheless, 

determined to impose an ethical wall on certain of these New Hires, as detailed below: 

i. New Hires Not Exposed to Confidential Information in Prior Position and, Out of 

an Abundance of Caution, Subject to Ethical Wall 

13. In July 2018, Shiori Nishizawa joined Paul Hastings’ corporate practice as a 

Summer Intern in the firm’s Tokyo office. During the summer of 2016, Ms. Nishizawa was a 

summer extern in the Tokyo office of DLA Piper LLP (“DLA Piper”). DLA Piper represents the 

ERS and the University of Puerto Rico (the “UPR”) in the Title III Cases. Ms. Nishizawa has 

informed Paul Hastings that she did not work on matters related to the ERS, the UPR, or the 

Debtors and was not exposed to confidential information related to the ERS, the UPR, or the 

Debtors while she was at DLA Piper. Out of an abundance of caution, Paul Hastings has 

imposed (and will continue to impose) an ethical wall between Ms. Nishizawa and the firm’s 

representation of the Committee in the Title III Cases. 

14. In August 2018, Pedro Jimenez joined Paul Hastings as a partner in the firm’s 

New York office. Before joining Paul Hastings, Mr. Jimenez was a partner in the Miami office 

of Jones Day. Jones Day represents the ERS bondholders in the Title III Cases, as well as certain 

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PRASA bondholders.4 Mr. Jimenez has informed Paul Hastings that he did not work on matters 

related to the ERS, PRASA bondholders, or the Debtors and was not exposed to confidential 

information related to the ERS, PRASA bondholders, or the Debtors while he was at Jones Day. 

Out of an abundance of caution, Paul Hastings initially imposed an ethical wall between Mr. 

Jimenez and the firm’s representation of the Committee in the Title III Cases. Subsequently, Mr. 

Jimenez was informed by Jones Day that the ERS and PRASA bondholders have consented to 

Mr. Jimenez’s working on the Title III Cases and related Puerto Rico matters at Paul Hastings. 

As a result, the ethical wall is no longer in place. 

15. In August 2018, Adish Parr joined Paul Hastings as an attorney in the firm’s 

London office. From July 2015 through January 2016, Ms. Parr worked in the London office of 

Proskauer Rose LLP (“Proskauer”). Proskauer represents the Oversight Board in the Title III 

Cases. Ms. Parr has informed Paul Hastings that she did not work on matters related to the 

Oversight Board or the Debtors and was not exposed to confidential information related to the 

Oversight Board or the Debtors while she was at Proskauer. Out of an abundance of caution, 

Paul Hastings has imposed (and will continue to impose) an ethical wall between Ms. Parr and 

the firm’s representation of the Committee in the Title III Cases. 

16. In September 2018, Craig Gibson joined Paul Hastings as an associate in Paul 

Hastings’ New York office. From January 2010 to March 2016, Mr. Gibson was an associate in 

the New York office of Milbank, Tweed, Hadley & McCloy LLP (“Milbank”). Milbank 

represents Ambac Assurance Corporation (“Ambac”) in the Title III Cases. Mr. Gibson has 

informed Paul Hastings that he did not work on matters related to Ambac or the Debtors and was 

not exposed to confidential information related to Ambac or the Debtors while he was at 

 

4

 PRASA (the Puerto Rico Aqueduct and Sewer Authority) is not a debtor in the Title III Cases. 

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Milbank. Out of an abundance of caution, Paul Hastings has imposed (and will continue to 

impose) an ethical wall between Mr. Gibson and the firm’s representation of the Committee in 

the Title III Cases. 

17. In September 2018, Salvador Bremer joined Paul Hastings’ corporate practice as a 

Foreign Associate in the firm’s New York office. Mr. Bremer was an associate from May 2017 

to August 2017 and a legal trainee from June 2013 to May 2014 in the Mexico City office of 

Ritch, Mueller, Heather y Nicolau, S.C. (“Ritch Mueller”). While at Ritch Mueller, Mr. Bremer 

worked on certain matters unrelated to the Debtors or the Title III Cases for Banco Santander 

(México), S.A.; Grupo Financiero Santander México; Nacional Financiera, S.N.C.; Banco 

Santander, S.A.; and The Bank of Nova Scotia. Mr. Bremer has informed Paul Hastings that he 

did not work on matters related to the Debtors or the Title III Cases and was not exposed to 

confidential information related to the Debtors or the Title III Cases while he was at Ritch 

Mueller. Out of an abundance of caution, Paul Hastings has imposed (and will continue to 

impose) an ethical wall between Mr. Bremer and the firm’s representation of the Committee in 

the Title III Cases. 

18. In September 2018, Gabriella Omorphou joined Paul Hastings’ corporate practice 

as an associate in the firm’s London office. Before joining Paul Hastings, Ms. Omorphou was a 

trainee solicitor in the London office of DLA Piper. Ms. Omorphou has informed Paul Hastings 

that she did not work on matters related to the ERS, the UPR, or the Debtors and was not 

exposed to confidential information related to the ERS, the UPR, or the Debtors while she was at 

DLA Piper. Out of an abundance of caution, Paul Hastings has imposed (and will continue to 

impose) an ethical wall between Ms. Omorphou and the firm’s representation of the Committee 

in the Title III Cases. 

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19. In September 2018, Tylar Moore joined Paul Hastings as a client service 

specialist/analyst in the firm’s Los Angeles office. From September 2012 through September 

2017, Ms. Moore was an entertainment litigation executive assistant in the Los Angeles office of 

O’Melveny & Myers LLP (“O’Melveny”). O’Melveny represents AAFAF in the Title III Cases. 

Ms. Moore has informed Paul Hastings that she did not work on matters related to the Debtors or 

the Title III Cases and was not exposed to confidential information related to the Debtors or the 

Title III Cases while she was at O’Melveny. Out of an abundance of caution, Paul Hastings has 

imposed (and will continue to impose) an ethical wall between Ms. Moore and the firm’s 

representation of the Committee in the Title III Cases. 

20. In September 2018, Irena Goldstein joined Paul Hastings as an attorney in the 

firm’s New York office. From May 2012 to September 2016, Ms. Goldstein worked in the New 

York office of Proskauer. Ms. Goldstein has informed Paul Hastings that she worked on the 

Puerto Rico Corporation Debt Enforcement and Recovery Act of 2014 (the “Recovery Act”), 

which was struck down by the U.S. Supreme Court in 2015. Proskauer has consented to Ms. 

Goldstein’s working on the Title III Cases and related Puerto Rico matters at Paul Hastings. Out 

of an abundance of caution, Paul Hastings has imposed (and will continue to impose) an ethical 

wall between Ms. Goldstein and the firm’s representation of the Committee in the Title III Cases 

in matters pertaining to the Recovery Act. At the time of the filing of this Fourth Supplemental 

Declaration there were no matters opened with respect to the Recovery Act. 

21. In September 2018, Adam Rose joined Paul Hastings’ corporate practice as an 

associate in the New York office. Before joining Paul Hastings, Mr. Rose was an associate at 

Paul, Weiss, Rifkind, Wharton & Garrison LLP (“Paul Weiss”) in New York. Paul Weiss 

represents an ad hoc group of GO Bondholders and Aurelius Capital Master, Ltd. (“Aurelius 

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Capital”) in the Title III Cases. Mr. Rose has informed Paul Hastings that he did not work on 

matters related to the GO Bondholders, Aurelius Capital, or the Debtors and was not exposed to 

confidential information related to the GO Bondholders, Aurelius Capital, or the Debtors while 

he was at Paul Weiss. Out of an abundance of caution, Paul Hastings has imposed (and will 

continue to impose) an ethical wall between Mr. Rose and the firm’s representation of the 

Committee in the Title III Cases. 

22. In September 2018, Lauren Wolfe joined Paul Hastings as an attorney in firm’s 

Washington, D.C. office. From August 2018 to September 2018, Ms. Wolfe worked as a 

contract attorney at Jones Day. Ms. Wolfe has informed Paul Hastings that she did not work on 

matters related to the ERS bondholders or the Debtors and was not exposed to confidential 

information related to the ERS bondholders or the Debtors while she was at Jones Day. From 

November 2017 to January 2018, Ms. Wolfe was a contract attorney at Skadden, Arps, Slate, 

Meagher & Flom LLP (“Skadden”), which represents Vitol Inc. and Vitol S.A. (together, 

“Vitol”) in the Title III Cases. Ms. Wolfe has informed Paul Hastings that she did not work on 

matters related to Vitol or the Debtors and was not exposed to confidential information related to 

Vitol or the Debtors while she was at Skadden. From July 2017 to August 2017, Ms. Wolfe was 

a contract attorney at Kirkland & Ellis LLP (“K&E”), which is listed as a creditor holding one of 

the twenty largest unsecured claims in the Commonwealth of Puerto Rico Title III Case. Ms. 

Wolfe has informed Paul Hastings that she did not work on matters related to the Debtors or the 

Title III Cases and was not exposed to confidential information related to the Debtors or the Title 

III Cases while she was at K&E. From November 2016 to February 2017, Ms. Wolfe was a 

contract attorney at Morrison & Foerster LLP, which is counsel to an ad hoc group of certain 

holders of Government Facilities Revenue Bonds and Government Facilities Revenue Refunding 

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Bonds in the Title III Cases. Ms. Wolfe has informed Paul Hastings that she did not work on 

matters related to the Debtors or the Title III Cases and was not exposed to confidential 

information related to the Debtors or the Title III Cases while she was at Morrison & Foerster. 

Out of an abundance of caution, Paul Hastings has imposed (and will continue to impose) an 

ethical wall between Ms. Wolfe and the firm’s representation of the Committee in the Title III 

Cases. 

23. In September 2018, Nneka Ukpai joined Paul Hastings’ Washington, D.C. office 

as an associate. Before joining Paul Hastings, Ms. Ukpai was an associate at Allen & Overy 

LLP (“Allen & Overy”) in Washington, D.C. Ms. Ukpai has informed Paul Hastings that she did 

not work on matters related to the Debtors or the Title III Cases and was not exposed to 

confidential information related to the Debtors or the Title III Cases while she was at Allen & 

Overy. Out of an abundance of caution, Paul Hastings has imposed (and will continue to 

impose) an ethical wall between Ms. Ukpai and the firm’s representation of the Committee in the 

Title III Cases. 

24. In October 2018, Tienmin Chan joined Paul Hastings’ corporate practice as a 

paralegal in the firm’s Hong Kong office. Before joining Paul Hastings, Mr. Chan was an intern 

in the Beijing office of DLA Piper. Mr. Chan has informed Paul Hastings that he did not work 

on matters related to the ERS, the UPR, or the Debtors and was not exposed to confidential 

information related to the ERS, the UPR, or the Debtors while he was at DLA Piper. Out of an 

abundance of caution, Paul Hastings has imposed (and will continue to impose) an ethical wall 

between Mr. Chan and the firm’s representation of the Committee in the Title III Cases. 

25. In October 2018, Taoran Wang joined Paul Hastings’ corporate practice as a 

paralegal in the firm’s Hong Kong office. From September 2016 to May 2017, Ms. Wang was 

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an intern in the Beijing office of DLA Piper. Ms. Wang has informed Paul Hastings that she did 

not work on matters related to the ERS, the UPR, or the Debtors and was not exposed to 

confidential information related to the ERS, the UPR, or the Debtors while she was at DLA 

Piper. Out of an abundance of caution, Paul Hastings has imposed (and will continue to impose) 

an ethical wall between Ms. Wang and the firm’s representation of the Committee in the Title III 

Cases. 

26. In October 2018, Jenna Carroll joined Paul Hastings’ as an associate in the firm’s 

New York office. From September 2014 to March 2016, Ms. Carroll was a paralegal in the New 

York office of JPMorgan Chase & Co. LLP (“JPMorgan”). Ms. Carroll has informed Paul 

Hastings that she did not work on matters related to the Debtors or the Title III Cases and was 

not exposed to confidential information related to the Debtors or the Title III Cases while she 

was at JPMorgan. Out of an abundance of caution, Paul Hastings has imposed (and will continue 

to impose) an ethical wall between Ms. Carroll and the firm’s representation of the Committee in 

the Title III Cases. 

27. In October 2018, Claudia Vinci joined Paul Hastings as a legal intern in the firm’s 

Milan office. From December 2017 to July 2018, Ms. Vinci was a trainee lawyer in the Milan 

office of DLA Piper. Ms. Vinci has informed Paul Hastings that she did not work on matters 

related to the ERS, the UPR, or the Debtors and was not exposed to confidential information 

related to the ERS, the UPR, or the Debtors while she was at DLA Piper. Out of an abundance 

of caution, Paul Hastings has imposed (and will continue to impose) an ethical wall between Ms. 

Vinci and the firm’s representation of the Committee in the Title III Cases. 

28. In October 2018, Juan Hernandez joined Paul Hastings as an associate in the 

firm’s Los Angeles office. From May 2015 to July 2015, Mr. Hernandez was a summer legal 

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intern in the New York office of Wachtell, Lipton, Rosen & Katz (“Wachtell”). Wachtell 

represents Scotiabank De Puerto Rico in the Title III Cases. Mr. Hernandez has informed Paul 

Hastings that he did not work on matters related to Scotiabank De Puerto Rico or the Debtors 

and was not exposed to confidential information related to Scotiabank De Puerto Rico or the 

Debtors while he was at Wachtell. Out of an abundance of caution, Paul Hastings has imposed 

(and will continue to impose) an ethical wall between Mr. Hernandez and the firm’s 

representation of the Committee in the Title III Cases. 

29. In October 2018, Riccardo Novaretti joined Paul Hastings as an associate in the 

firm’s London office. From September 2017 to September 2018, Mr. Novaretti worked as a law 

clerk in the New York office of White & Case LLP (“White & Case”). From February 2012 to 

May 2016, Mr. Novaretti worked as an associate in the Milan office of White & Case. White & 

Case represents certain junior COFINA bondholders, Doral Financial Corporation, the UBS 

Family of Funds, and the Puerto Rico Family of Funds in the Title III Cases. Mr. Novaretti has 

informed Paul Hastings that he did not work on matters related to such parties or the Debtors and 

was not exposed to confidential information related to such parties or the Debtors while he was 

at White & Case. Out of an abundance of caution, Paul Hastings has imposed (and will continue 

to impose) an ethical wall between Mr. Novaretti and the firm’s representation of the Committee 

in the Title III Cases. 

30. In October 2018, Andrew Clark joined Paul Hastings’ corporate practice as an 

associate in the firm’s Palo Alto office. Before joining Paul Hastings, Mr. Clark was an 

associate at Stradling Yocca Carlson & Rauth (“Stradling Yocca”), which serves as counsel to 

the Municipality of Ponce in the Title III Cases. Mr. Clark has informed Paul Hastings that he 

did not work on matters related to the Municipality of Ponce or the Debtors and was not exposed 

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to confidential information related to the Municipality of Ponce or the Debtors while he was at 

Stradling Yocca. Out of an abundance of caution, Paul Hastings has imposed (and will continue 

to impose) an ethical wall between Mr. Clark and the firm’s representation of the Committee in 

the Title III Cases. 

31. In October 2018, Daniel Sullivan-Byrne joined Paul Hastings as a paralegal in the 

firm’s London office. From October 2017 to October 2018, Mr. Sullivan-Byrne worked in the 

London office of Greenberg Traurig, LLP (“Greenberg”). Greenberg represents PREPA in the 

Title III cases. Mr. Sullivan-Byrne has informed Paul Hastings that he did not work on matters 

related to the Debtors or the Title III Cases and was not exposed to confidential information 

related to the Debtors or the Title III Cases while at Greenberg. Out of an abundance of caution, 

Paul Hastings has imposed (and will continue to impose) an ethical wall between Mr. SullivanByrne and the firm’s representation of the Committee in the Title III Cases. 

32. In October 2018, Cole Malmberg joined Paul Hastings as an associate in the San 

Diego office. From September 2015 to October 2018, Mr. Malmberg was an associate at Quinn 

Emanuel Urquhart & Sullivan, LLP (“Quinn Emanuel”) in Redwood Shores, California. He also 

was a summer associate at Quinn Emanuel in 2014. Quinn Emanuel represents the COFINA 

Senior Bondholders’ Coalition in the Title III Cases. Mr. Malmberg has informed Paul Hastings 

that he did not work on matters related to the COFINA Senior Bondholders’ Coalition or the 

Debtors and was not exposed to confidential information related to the COFINA Senior 

Bondholders’ Coalition or the Debtors while he was at Quinn Emanuel. Out of an abundance of 

caution, Paul Hastings will impose an ethical wall between Mr. Malmberg and the firm’s 

representation of the Committee in the Title III Cases. In the summer of 2013, Mr. Malmberg 

was a legal intern at the U.S. Small Business Administration (the “SBA”) in Washington, D.C. 

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Mr. Malmberg has informed Paul Hastings that he did not work on matters related to the Debtors 

or the Title III Cases and was not exposed to confidential information related to the Debtors or 

the Title III Cases while he was at the SBA. 

ii. New Hires Not Exposed to Confidential Information in Prior Position and Not

Subject to Ethical Wall5

33. For certain of the New Hires, Paul Hastings has determined that it is not necessary 

to set up an ethical wall because, in all instances, these New Hires did not work on matters 

related to the Debtors and were not exposed to confidential information related to the Debtors. 

Moreover, none of these New Hires are expected to work on the Puerto Rico matter. 

34. From August 27, 2018 through August 31, 2018, Akitaka Yamashiro worked as a 

summer intern in Paul Hastings’ Tokyo office. Mr. Yamashiro was a summer associate in the 

Tokyo office of White & Case in August 2015 and a research assistant at White & Case from 

November 1, 2015 through August 31, 2016. Mr. Yamashiro has informed Paul Hastings that he 

did not work on matters related to the junior COFINA bondholders, Doral Financial Corporation, 

the UBS Family of Funds, the Puerto Rico Family of Funds, or the Debtors and was not exposed 

to confidential information related to such parties or the Debtors while he was at White & Case. 

35. In August 2018, Yuki Oi worked as a summer intern and now works as a 

researcher in Paul Hastings’ Tokyo office. From September 4 – 8, 2017, Ms. Oi worked as an 

intern in the Tokyo office of White & Case. Ms. Oi has informed Paul Hastings that she did not 

work on matters related to the junior COFINA bondholders, Doral Financial Corporation, the 

UBS Family of Funds, the Puerto Rico Family of Funds, or the Debtors and was not exposed to 

confidential information related to such parties or the Debtors while she was at White & Case. 

 

5

 In addition to not having been exposed to confidential information in their prior positions, the New Hires listed 

below have not worked on the Title III Cases or related matters while at Paul Hastings and are not expected to 

do so. 

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From August 8, 2017 to September 1, 2017, Ms. Oi was an intern in the Tokyo office of Jones 

Day. Ms. Oi has informed Paul Hastings that she did not work on matters related to the ERS 

bondholders or the Debtors and was not exposed to confidential information related to the ERS 

bondholders or the Debtors while she was at Jones Day. 

36. From September 3 – 7, 2018, Masashi Shimojo worked at Paul Hastings as a 

summer intern in the firm’s Tokyo office. From March 6 – 21, 2017, Mr. Shimojo was a legal 

extern in the Tokyo office of Jones Day. Mr. Shimojo has informed Paul Hastings that he did not 

work on matters related to the ERS bondholders or the Debtors and was not exposed to 

confidential information related to the ERS bondholders or the Debtors while he was at Jones 

Day. From August 6 – 31, 2018, Mr. Shimojo was an intern at Shearman & Sterling LLP 

(“Shearman & Sterling”), which represents EcoEléctrica, L.P. in the Title III Cases. Mr. 

Shimojo has informed Paul Hastings that he did not work on matters related to EcoEléctrica or 

the Debtors and was not exposed to confidential information related to EcoEléctrica or the 

Debtors while he was at Shearman & Sterling. 

37. In September 2018, Anna Cressman rejoined Paul Hastings’ real estate practice as 

an associate in the firm’s San Francisco office, having previously been a Paul Hastings associate. 

From February 2015 to September 2015, Ms. Cressman was an associate in the London office of 

Milbank. Ms. Cressman has informed Paul Hastings that she did not work on matters related to 

Ambac or the Debtors and was not exposed to confidential information related to Ambac or the 

Debtors while she was at Milbank. 

38. In September 2018, Anna Pulimood joined Paul Hastings as a trainee solicitor in 

the firm’s London office. From June 2015 to July 2015, Ms. Pulimood was a Vacation Scheme 

Student in the London office of Skadden. Ms. Pulimood has informed Paul Hastings that she did 

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not work on matters related to Vitol or the Debtors and was not exposed to confidential 

information related to Vitol or the Debtors while she was at Skadden. 

39. In September 2018, Nikita Gudgeon joined Paul Hastings as a paralegal in the 

firm’s London office. In September 2015, Mr. Gudgeon worked for two weeks in the London 

office of Shearman & Sterling. Mr. Gudgeon has informed Paul Hastings that he did not work 

on matters related to EcoElectrica or the Debtors and was not exposed to confidential 

information related to EcoElectrica or the Debtors while he was at Shearman & Sterling. 

40. In September 2018, Sean Meng Zhang joined Paul Hastings as an associate in the 

Shanghai office. From September 2012 through July 2017, Mr. Zhang was an associate at Allen 

& Overy. Mr. Zhang has informed Paul Hastings that he did not work on matters related to the 

Debtors or the Title III Cases and was not exposed to confidential information related to the 

Debtors or the Title III Cases while he was at Allen & Overy. 

41. In October 2018, Aaron Scott joined Paul Hastings’ London office as an 

associate. Before joining Paul Hastings, Mr. Scott was an associate at Allen & Overy in London. 

Mr. Scott has informed Paul Hastings that he did not work on matters related to the Debtors or 

the Title III Cases and was not exposed to confidential information related to the Debtors or the 

Title III Cases while he was at Allen & Overy. 

42. In October 2018, Matthew Bodziak joined Paul Hastings’ corporate practice as an 

associate in the Orange County, CA office. From June 2016 to August 2016, Mr. Bodziak was a 

Legal Intern at the Securities and Exchange Commission (the “SEC”) in Washington, D.C. 

From September 2014 through July 2015, Mr. Bodziak was a staff accountant in the Los Angeles 

office of Ernst & Young LLP. Mr. Bodziak has informed Paul Hastings that he did not work on 

matters related to the Debtors or the Title III Cases and was not exposed to confidential 

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information related to the Debtors or the Title III Cases while he was at the SEC or Ernst & 

Young LLP. 

43. In October 2018, Katerina Syomina joined Paul Hastings’ London office as an 

associate. From September 2011 to June 2014, and from December 2017 to April 2018, Ms. 

Syomina worked at Goldman Sachs International (“Goldman Sachs”), a bondholder in the Title 

III Cases. Ms. Syomina informed Paul Hastings that she did not work on matters related to the 

Debtors or the Title III Cases and was not exposed to confidential information related to the 

Debtors or the Title III Cases while she was at Goldman Sachs. 

44. In October 2018, Benedict Grima joined Paul Hastings as an associate in the 

firm’s London office. Before joining Paul Hastings, Mr. Grima was a trainee solicitor in the 

London office of Sidley & Austin LLP (“Sidley”). Mr. Grima has informed Paul Hastings that, 

while at Sidley, he worked on certain matters unrelated to the Debtors or the Title III Cases for 

Canyon Partners LLC and Massachusetts Mutual Life Insurance Company. In January 2014, Mr. 

Grima was a Vacation Scheme Student in the London office of Jones Day. Mr. Grima has 

informed Paul Hastings that he did not work on matters related to the Debtors or the Title III 

Cases and was not exposed to confidential information related to the Debtors or the Title III 

Cases while he was at Sidley or Jones Day. 

45. In October 2018, Steven Graham King joined Paul Hastings as an associate in the 

firm’s London office. Before joining Paul Hastings, Mr. King was an associate in the London 

office of Skadden. Mr. King has informed Paul Hastings that he did not work on matters related 

to Vitol or the Debtors and was not exposed to confidential information related to Vitol or the 

Debtors while he was at Skadden. 

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46. In October 2018, Nobumasa Hiroi joined Paul Hastings as an associate in the 

firm’s Palo Alto office. Before joining Paul Hastings, Mr. Hiroi was an associate at Kramer 

Levin Naftalis & Frankel LLP (“Kramer Levin”), which represents the Mutual Fund Group in 

the Title III Cases. Mr. Hiroi has informed Paul Hastings that he did not work on matters related 

to the Mutual Fund Group or the Debtors and was not exposed to confidential information 

related to the Mutual Fund Group or the Debtors while he was at Kramer Levin. 

* * * 

47. Based on the foregoing and the Prior Declarations, and except as provided herein 

and in the Prior Declarations, to the best of my knowledge, information, and belief formed after 

reasonable inquiry, Paul Hastings does not represent or hold any interest adverse to the 

Committee with respect to the matters on which the Committee has employed Paul Hastings, and 

Paul Hastings is a “disinterested person” as that term is defined in section 101(14) of the 

Bankruptcy Code (made applicable by PROMESA section 301(a)) in that Paul Hastings: 

(a) is not a creditor, equity security holder, or insider of the Debtors; 

(b) is not and was not, within 2 years before the date of the filing of the petition, a 

director, officer, or employee of the Debtors; and 

(c) does not have an interest materially adverse to the interest of the estate or of any 

class of creditors or equity security holders, by reason of any direct or indirect 

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

reason. 

48. Despite the efforts described above to identify and disclose Paul Hastings’ 

connections with parties in interest in the Title III Cases, Paul Hastings is unable to state with 

certainty that every client representation or other connection has been disclosed. In this regard, 

if Paul Hastings discovers additional information that requires disclosure, Paul Hastings will file 

a supplemental disclosure with the Court. 

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Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true 

and correct. 

Executed this 1st day of November, 2018 

 /s/ Luc A. Despins 

Luc A. Despins 

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