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 

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 

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) 

 

 

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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). 

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INFORMATIVE MOTION OF U.S. BANK NATIONAL 

ASSOCIATION AS PREPA BOND TRUSTEE REGARDING 

APPEARANCE AT NOVEMBER 7-8 OMNIBUS HEARING 

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

U.S. Bank National Association, solely in its capacity as successor trustee (the 

“Trustee”) under the Trust Agreement dated as of January 1, 1974 (as amended and 

supplemented from time to time, the “Trust Agreement”), between the Puerto Rico Electric 

Power Authority and the Trustee, by its undersigned attorneys, hereby submits this informative 

motion in response to the Court’s Order entered on October 26, 2018 [Case No. 17-BK-4103, 

ECF No. 4103] regarding the attendance and participation at the November 7-8, 2018 Omnibus 

Hearing (“Hearing”). 

1. Clark T. Whitmore and John T. Duffey will appear on behalf of the Trustee in 

person at the Hearing in the San Juan courtroom. 

2. Clark T. Whitmore will present argument on behalf of the Trustee, regarding the 

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 [Case No. 17-BK4780, ECF No. 991, and Case No. 17-BK-3283 ECF No. 4053] and all related replies, and 

responsive pleadings. 

 Respectfully submitted in San Juan, Puerto Rico, on this 1st day of November, 2018. 

 We hereby certify that on this same date we electronically filed the foregoing with the 

Clerk of the Court using the CM/ECF System of the U.S. Bankruptcy Court for the District of 

Puerto Rico for Case No. 17-BK-4780 and Case No. 17-BK-3283, which will send notification 

of such filing to all counsel of record participating in the CM/ECF System. 

 

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Respectfully submitted, Respectfully submitted, 

RIVERA, TULLA AND FERRER, LLC 

/s Eric A. Tulla 

Eric A. Tulla 

USDC-DPR No. 118313 

Email: etulla@ riveratulla.com 

/s Iris J. Cabrera-Gómez 

Iris J. Cabrera-Gómez 

USDC-DPR No. 221101 

Email: icabrera@riveratulla.com 

Rivera Tulla & Ferrer Building 

50 Quisqueya Street 

San Juan, PR 00917-1212 

Tel: (787)753-0438 

Fax: (787)767-5784 (787)766-0409 

MASLON LLP 

By: /s Clark T. Whitmore 

Clark T. Whitmore (admitted pro hac vice) 

John T. Duffey (admitted pro hac vice) 

90 South Seventh Street, Suite 3300 

Minneapolis, MN 55402 

Telephone: 612-672-8200 

Facsimile: 612-672-8397 

E-Mail: clark.whitmore@maslon.com 

john.duffy@maslon.com 

ATTORNEYS FOR U.S. BANK NATIONAL 

ASSOCIATION, IN ITS CAPACITY AS 

TRUSTEE

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