Hearing Date: July 25, 2018 at 9:30 a.m. (AST)

Objection Deadline: July 12, 2018

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) 

NOTICE OF 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

PLEASE TAKE NOTICE that a hearing on the 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 (the “Motion”) (ECF No. 3427), filed by Kobre & Kim LLP, the 

independent investigator (the “Independent Investigator”) retained by the Financial Oversight 

 1 The debtors in the above referenced cases (the “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); (ii) Puerto Rico Sales Tax Financing 

Corporation (Bankruptcy Case No. 17-BK-3284(LTS)) (Last Four Digits of Federal Tax ID: 8474); (iii) 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico (Bankruptcy Case No. 

17-BK-3566 (LTS)) (Last Four Digits of Federal Tax ID: 9686); and (iv) Puerto Rico Highways and 

Transportation Authority (Bankruptcy Case No. 17-BK-3567 (LTS)) (Last Four Digits of Federal Tax 

ID: 3808); and (v) Puerto Rico Electric Power Authority (Bankruptcy Case No. 17-BK-4780 (LTS)) (Last Four 

Digits of Federal Tax ID: 3747) (collectively, the “Debtors”).

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

Special Investigation Committee of the Oversight Board (the “Special Investigation 

Committee”),2 will be held before the Honorable Laura Taylor Swain, the United States 

District Court for the District of Puerto Rico, 150 Carlos Chardón Street, Federal Building, 

San Juan, Puerto Rico 00918-1767 on July 25, 2018 at 9:30 a.m. (Atlantic Standard Time).

PLEASE TAKE FURTHER NOTICE that any response or objection (any 

“Objection”) to the Motion must be in writing, must conform to the Federal Rules of 

Bankruptcy Procedure and the Local Bankruptcy Rules for the District of Puerto Rico, must 

be filed with the Court (a) by attorneys practicing in the Court, including attorneys admitted 

pro hac vice, electronically in accordance with Rule 5 of the Local Rules for the District of 

Puerto Rico, and (b) by all other parties in interest, on a CD-ROM, in text-searchable portable 

document format (PDF), to the extent applicable, and must be served on the Independent 

Investigator and other parties in interest in accordance with the Court’s Order (A) Imposing

and Rendering Applicable Local Bankruptcy Rules to These Title III Cases, (B) Authorizing 

Establishment of Certain Notice, Case Management, and Administrative Procedures, and (C) 

Granting Related Relief, as amended (ECF Nos. 249, 262, 1065, 1512, 2839, and 

collectively, the “Case Management Order”) no later than July 12, 2018 (the “Objection 

Deadline”).

3

 2 The Special Investigation Committee comprises of Members Ana J. Matosantos, David A. Skeel, and Judge 

Arthur J. Gonzalez (Ret.), and is charged with pursuing investigations pursuant to the authority granted to the 

Oversight Board by PROMESA Section 104(o) and such other authority vested in the Oversight Board under 

PROMESA.

3 See Order Granting Creditors’ Committee’s Motion for Entry of Briefing Schedule Regarding Investigator’s 

Proposed “Exit Plan” dated July 2, 2018, entered by Judge Judith Gail Dein, in the Debtors’ Title III Cases 

(ECF No. 3409).

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PLEASE TAKE FURTHER NOTICE that any reply in support of the relief sought 

in the Motion or any response to an Objection must be filed and served in accordance with 

the Case Management Order by no later than July 20, 2018.

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PLEASE TAKE FURTHER NOTICE that if no Objection to the Motion is timely 

filed and served in accordance with the Case Management Order by the Objection Deadline, 

the relief requested shall be deemed unopposed, and the Court may enter an order granting 

the relief sought in the Motion without a hearing.

Dated: July 3, 2018 

San Juan, Puerto Rico

/s/ D. Farrington Yates

KOBRE & KIM LLP

D. Farrington Yates

800 Third Avenue

New York, New York 10022 

Tel: (212) 488-1211

Fax: (212) 488-1220

Farrington.Yates@kobrekim.com

John D. Couriel (pro hac vice pending)

201 S. Biscayne Blvd., Suite 1900

Miami, Florida 33131

Tel: (305) 967-6100

John.Couriel@kobrekim.com

The Independent Investigator

-and-

 4 See id.

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A&S LEGAL STUDIO, PSC

S/Luis F. del Valle

Luis F. del Valle-Emmanuelli

USDC-PR No. 209514

P.O. Box 79897

Carolina, Puerto Rico 00984-9897

Tel. 787.977.1932

Fax. 787.722.1932

dvelawoffices@gmail.com

Local Counsel for the Independent 

Investigator

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