UNITED STATES DISTRICT COURT

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 

No. 17 BK 3283-LTS 

Re: ECF Nos. 3735, 3736, 3755

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, 

Debtor.

PROMESA 

Title III 

No. 17 BK 3283-LTS 

This Joinder relates to the 

Commonwealth, HTA, and PREPA, and 

shall be in Case Nos. 17 BK 3283-LTS, 17 

BK 3567-LTS, and 17 BK 4780-LTS.

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”), 

PROMESA 

Title III 

No. 17 BK 3567-LTS 

 

1 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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Debtor.

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY, 

Debtor.

PROMESA 

Title III 

No. 17 BK 4780-LTS 

JOINDER OF THE PUERTO RICO FISCAL 

AGENCY AND FINANCIAL ADVISORY AUTHORITY ON BEHALF OF THE 

PUERTO RICO ELECTRIC POWER AUTHORITY TO THE COMMONWEALTH’S 

RESPONSE TO (A) OMNIBUS REPLY TO OPPOSITION TO MOTION REQUESTING

LIFTING OF THE STAY AND (B) MOTION REQUESTING HEARING ON 362 

LIFTING OF THE STAY FILED BY AUTONOMOUS MUNICIPALITY OF PONCE

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

The Puerto Rico Fiscal Agency and Financial Authority (“AAFAF”), as the entity 

authorized to act on behalf of the Puerto Rico Power Authority (“PREPA”) pursuant to the 

authority granted to it under the Enabling Act of the Fiscal Agency and Financial Advisory 

Authority, Act 2-2017, respectfully submits this joinder to the Commonwealth’s Response to (a) 

the Omnibus Reply to Opposition to Motion Requesting Lifting of the Stay and (b) the Motion 

Requesting Hearing on 362 Lifting of the Stay Filed by Autonomous Municipality of Ponce [Case 

No. 17 BK 3283-LTS, Dkt. No. 3911] (the “Response”),2and states as follows:3

 

2 Capitalized terms used but not otherwise defined herein have the meanings given to them in the Response.

3 The Financial Oversight and Management Board for Puerto Rico, as the Debtors’ representative pursuant to section 

315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), has authorized 

AAFAF to file this Joinder on behalf of PREPA. 

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1. AAFAF hereby joins the Commonwealth in responding to the Reply to Opposition 

to Motion Requesting Lifting of the Stay [Dkt No. 3735], and (b) the Motion Requesting Hearing 

on 362 Lifting of the Stay [Dkt No. 373] (the “Hearing Request”), both filed by the Autonomous 

Municipality of Ponce (“Movant”), pursuant to the Court’s Scheduling Order Regarding Hearing 

Request and Reply Filed by the Autonomous Municipality of Ponce [Dkt No. 3755] and adopts the 

factual and legal arguments set forth in the Response.

2. For the reasons set forth in the Response, AAFAF respectfully requests the Court 

deny the Motion requesting relief from the automatic stay and the Hearing Request. Specifically, 

AAFAF states on behalf of PREPA that no PREPA project relevant to the present dispute receives 

federal funding.

Dated: September 10, 2018 Respectfully submitted,

San Juan, Puerto Rico

THE PUERTO RICO FISCAL AGENCY

AND FINANCIAL ADVISORY

AUTHORITY, as Fiscal Agent for PREPA

By its attorneys,

/s/ Joseph P. Davis III

Joseph P. Davis III (admitted pro hac vice)

Greenberg Traurig, LLP

One International Place, Suite 2000

Boston, MA 02110

Phone: 617.310.6000

Fax: 617.310.6001

Email: davisjo@gtlaw.com

David D. Cleary (admitted pro hac vice)

Kevin D. Finger (admitted pro hac vice)

Greenberg Traurig, LLP

77 West Wacker Drive

Suite 3100

Chicago, IL 60601

Phone: 312.456.8400

Fax: 312.456.8435

Email: clearyd@gtlaw.com

 fingerk@gtlaw.com

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PUERTO RICO ELECTRIC POWER

AUTHORITY

By its attorneys,

/s/ Arturo Díaz Angueria

USDC No. 117907

/s/ Katiuska Bolaños Lugo

USDC No. 231812

CANCIO, NADAL, RIVERA & DÍAZ, P.S.C.

PO Box 364966

San Juan, PR 00936-4966

Phone: 787.767.9625

Fax: 787.764.4430

Email: adiaz@cnrd.com

kbolanos@cnrd.com

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