UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO et al., 

Debtors.1

PROMESA Title III 

Case No. 17 BK 3283-LTS 

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

PUERTO RICO ELECTRIC POWER 

AUTHORITY, 

Debtor. 

PROMESA Title III 

 

Case No. 17 BK 4780-LTS 

Court Filing Relates Only to PREPA 

and Shall only be Filed 

Case No. 17-BK-4780 (LTS) and 

Main Case 17-BK-3283 (LTS) 

DECLARATION OF JOHN T. DUFFEY IN SUPPORT OF 

OBJECTION OF U.S. BANK NATIONAL ASSOCIATION, 

IN ITS CAPACITY AS PREPA BOND TRUSTEE, 

TO PAN AMERICAN GRAIN CO., INC.’S 

MOTION FOR RELIEF FROM STAY TO EXECUTE SET-OFF 

 

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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 04780-LTS) (Last Four Digits of 

Federal Tax ID: 3747). 

Case:17-03283-LTS Doc#:4055 Filed:10/17/18 Entered:10/17/18 14:35:05 Desc: Main

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I, John T. Duffey, pursuant to 28 U.S.C. § 1746, declare and state as follows: 

1. I am a member of the bar of the State of Minnesota, I am admitted to practice 

before this Court pro hac vice, and I am an attorney with the firm of Maslon LLP, attorneys for 

U.S. Bank National Association, in its capacity as trustee (the “PREPA Bond Trustee”) under the 

Trust Agreement dated as of January 1, 1974 (as amended and supplemented from time to time, 

the “Trust Agreement”), between it and the Puerto Rico Electric Power Authority (“PREPA”). 

2. I submit this declaration in support of the PREPA Bond Trustee’s Objection to the 

Motion for Relief from Stay to Execute Set-off filed by Pan American Grain Co., Inc., which 

Objection was filed on this same date as Case No. 17-BK-4780 ECF No. 991, and Case No. 17-

BK-3283 ECF No. 4053. 

3. Attached hereto as Exhibit A-1 through A-7 is a true and correct copy of the Trust 

Agreement, which the PREPA Bond Trustee previously submitted in connection with PREPA’s 

Title III case as part of Proof of Claim No. 14147. 

I declare under penalty of perjury that the foregoing is true and correct. Executed on 

October 17, 2018 in Minneapolis, Minnesota. 

/s/John T. Duffey 

John T. Duffey 

Case:17-03283-LTS Doc#:4055 Filed:10/17/18 Entered:10/17/18 14:35:05 Desc: Main

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