Hearing Date: March 13, 2019 at 9:30 a.m. AST 

Objection Deadline: December 6, 2018 (for parties other than the Fee Examiner) 

IN THE 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) 

SUMMARY COVER SHEET TO THE FOURTH INTERIM 

APPLICATION OF MEMBERS OF THE OFFICIAL COMMITTEE OF 

RETIRED EMPLOYEES OF THE COMMONWEALTH OF PUERTO 

RICO FOR REIMBURSEMENT OF EXPENSES INCURRED 

FROM JUNE 1, 2018 THROUGH SEPTEMBER 30, 2018 

Name of Applicant: The Official Committee of Retired 

Employees of the Commonwealth of Puerto 

Rico 

Period for which expense reimbursement is 

sought: 

June 1, 2018–September 30, 2018 

Amount of interim compensation sought as 

actual, reasonable, and necessary: Not applicable 

 

1

 The Debtors in these jointly-administered PROMESA 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: (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) (Last Four Digits of Federal Tax ID: 

8474); (iii) Puerto Rico Highways and Transportation Authority (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 (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax 

ID: 9686); and (v) Puerto Rico Electric and Power Authority (Bankruptcy Case No. 17 BK 4780) (Last 

Four Digits of Federal Tax ID: 3747). 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 1 of 8
ii 

Amount of interim expense reimbursement 

sought as actual, reasonable, and necessary: $308.38 

Are your expense totals different from the 

sum of previously served monthly 

statements? No. 

Petition Date: May 3, 2017 

This is an interim application. 

Total expenses approved by interim order to 

date: 

$2,060.58 

Total expenses paid to date: $2,060.58 

Total expenses subject to objection: None 

Objection Deadline: December 6, 2018 (for parties other than the 

Fee Examiner) 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 2 of 8
Hearing Date: March 13, 2019 at 9:30 a.m. AST 

Objection Deadline: December 6, 2018 (for parties other than the Fee Examiner) 

IN THE 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) 

FOURTH INTERIM APPLICATION OF MEMBERS OF THE OFFICIAL 

COMMITTEE OF RETIRED EMPLOYEES OF THE 

COMMONWEALTH OF PUERTO RICO FOR 

REIMBURSEMENT OF EXPENSES INCURRED 

FROM JUNE 1, 2018 THROUGH SEPTEMBER 30, 2018 

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

Pursuant to the Second Amended Order Setting Procedures for Interim Compensation and 

Reimbursement of Expenses [Dkt. No. 3269] (the “Interim Compensation Order”), the members 

of the Official Committee of Retired Employees of the Commonwealth of Puerto Rico (the 

“Retiree Committee”) in the above-captioned Title III cases, hereby submit their Fourth Interim 

 

1

The Debtors in these jointly-administered PROMESA 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: (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) (Last Four Digits of Federal Tax ID: 

8474); (iii) Puerto Rico Highways and Transportation Authority (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 (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax 

ID: 9686); and (v) Puerto Rico Electric and Power Authority (Bankruptcy Case No. 17 BK 4780) (Last 

Four Digits of Federal Tax ID: 3747). 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 3 of 8
2 

Application of Members of the Official Committee of Retired Employees of the Commonwealth of 

Puerto Rico from June 1, 2018 to September 30, 2018 (the “Application”). By this Application, 

the Retiree Committee members seek reimbursement of reasonable, actual, and necessary expenses 

that they incurred in the aggregate amount of $308.38 during the period of June 1, 2018 to 

September 30, 2018 (the “Interim Period”). In support of this Application, the Retiree Committee 

Members respectfully represent as follows: 

Background 

1. On May 3, 2017, Puerto Rico, by and through the Financial Oversight and 

Management Board for Puerto Rico (“FOMB”), as Puerto Rico’s representative pursuant to 

section 315(b) of PROMESA, filed a petition with the Court under title III of PROMESA. 

2. On May 5, 2017, the Puerto Rico Sales Tax Financing Corporation (“COFINA”), 

by and through the FOMB, as COFINA’s representative pursuant to PROMESA section 315(b), 

filed a petition with the Court under title III of PROMESA. 

3. On May 21, 2017, the Puerto Rico Highways and Transportation Authority 

(“HTA”), by and through the FOMB, as HTA’s representative pursuant to PROMESA section 

315(b), filed a petition with the Court under title III of PROMESA. 

4. On May 21, 2017, the Employees Retirement System for the Commonwealth of 

Puerto Rico (“ERS”), by and through the FOMB, as ERS’s representative pursuant to PROMESA 

section 315(b), filed a petition with the Court under title III of PROMESA. 

5. On July 3, 2017, the Puerto Rico Electric Power Authority (“PREPA”), by and 

through the FOMB, as PREPA’s representative pursuant to PROMESA section 315(b), filed a 

petition with the Court under title III of PROMESA. 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 4 of 8
3 

6. Through Orders of this Court, the Commonwealth, COFINA, HTA, ERS, and 

PREPA Title III Cases are jointly administered for procedural purposes only, pursuant to 

PROMESA section 304(g) and Bankruptcy Rule 1015. [See Dkt. Nos. 242, 537, 1417.] 

7. On June 15, 2017, the U.S. Trustee, pursuant to section 1102(a)(1) of the 

Bankruptcy Code, appointed the Retiree Committee, consisting of the following nine individuals: 

Blanca Paniagua, Carmen Nunez, José Marin, Juan Ortiz, Lydia Pellot, Marcos A. Lopez, Miguel 

Fabre, Milagros Acevedo, and Rosario Pacheco.2

 [Dkt. No. 340.] 

8. The Interim Compensation Order provides that “[e]ach member of any statutory 

committee is to submit statements of expenses ... to the respective committee’s counsel, which 

counsel shall collect and submit for reimbursement in accordance with the Interim Compensation 

Procedures.” (Interim Compensation Order ¶ 4.) In accordance with the Interim Compensation 

Order, expense reports for the Retiree Committee’s members’ expenses were submitted to the 

Notice Parties (as defined in the Interim Compensation Order). 

9. On October 6, 2017, the Court entered an Order appointing Brady Williamson as 

the fee examiner (the “Fee Examiner”) in these Title III Cases. [Dkt. No. 1416.] 

10. On December 15, 2017, the Retiree Committee filed its First Interim Application 

for Reimbursement of Expenses Incurred From June 16, 2017 Through September 30, 2017 (“First 

Interim Application”) [Dkt. No. 2052], seeking $1,181.53 in expenses. On March 7, 2018, the 

Court entered an Order approving the First Interim Application (the “First Interim Order”) [Dkt. 

No. 2685] in the amount of $1,052.94 in expenses, deferring $128.59 of expenses recorded in 

October 2017. 

 

2

 As of April 12, 2018, José Marin resigned from the Retiree Committee. 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 5 of 8
4 

11. On March 19, 2018, the Retiree Committee filed its Second Interim Application for 

Reimbursement of Expenses Incurred From October 1, 2017 through January 31, 2018 (“Second 

Interim Application”) [Dkt. No. 2052], seeking $468.34 in expenses. On June 8, 2018, the Court 

entered an Order approving the Second Interim Application (the “Second Interim Order”) [Dkt. 

No. 3279] in the amount of $468.34 in expenses. 

12. On July 16, 2018, the Retiree Committee filed its Third Interim Application for 

Reimbursement of Expenses Incurred From October 1, 2017 through January 31, 2018 (“Third 

Interim Application”) [Dkt. No. 3547], seeking $539.30 in expenses. On November 9, 2018, the 

Court entered an Order approving the Third Interim Application (the “Third Interim Order”) 

[Dkt. No. 4200] in the amount of $539.30 in expenses. 

Relief Requested 

13. Pursuant to the Interim Compensation Order and § 503(b)(3)(F) of the Bankruptcy 

Code, made applicable to these cases by § 301(a) of PROMESA, the Retiree Committee members 

respectfully request interim allowance and reimbursement of their reasonable, actual, and 

necessary expenses incurred in rendering services as members of the Retiree Committee in the 

amount of $308.38. Detailed expense records for June 2018 through September 2018 are attached 

hereto as Exhibit A. 

Notice 

14. Pursuant to the Interim Compensation Order, the Retiree Committee has provided 

notice of this Application to: (a) the U.S. Trustee; (b) counsel to the FOMB; (c) counsel to 

AAFAF; (d) counsel to the UCC; (e) the Fee Examiner; and (f) all parties that have filed a notice 

of appearance with the Clerk of this Court, pursuant to Bankruptcy Rule 2002 and applicable 

provisions of the Local Rules, and requested such notice. 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 6 of 8
5 

No Prior Request 

15. No prior application for the relief requested by this Application has been made to 

this or any other court. 

 

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 7 of 8
6 

WHEREFORE, the Retiree Committee respectfully requests that the Court enter an order 

allowing the Retiree Committee member’s claims for reimbursement of actual and necessary 

expenses in the amount of $308.38. 

November 16, 2018 

JENNER & BLOCK LLP 

By: 

/s/ Robert Gordon 

Robert Gordon (admitted pro hac vice) 

Richard Levin (admitted pro hac vice) 

919 Third Ave 

New York, NY 10022-3908 

rgordon@jenner.com

rlevin@jenner.com

212-891-1600 (telephone) 

212-891-1699 (facsimile) 

Catherine Steege (admitted pro hac vice) 

Melissa Root (admitted pro hac vice) 

353 N. Clark Street 

Chicago, IL 60654 

csteege@jenner.com

mroot@jenner.com 

312-222-9350 (telephone) 

312-239-5199 (facsimile) 

Respectfully submitted, 

BENNAZAR, GARCÍA & MILIÁN, C.S.P. 

By: 

/s/ A.J. Bennazar-Zequeira 

A.J. Bennazar-Zequeira 

Héctor M. Mayol Kauffman 

Edificio Union Plaza, 1701 

Avenida Ponce de León #416 

Hato Rey, San Juan 

Puerto Rico 00918 

ajb@bennazar.org 

hector.mayol@bennazar.org

787-754-9191 (telephone) 

787-764-3101 (facsimile) 

Counsel for The Official Committee of Retired 

Employees of Puerto Rico

Case:17-03283-LTS Doc#:4274 Filed:11/16/18 Entered:11/16/18 15:44:24 Desc: Main

Document Page 8 of 8