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Table of Contents: Exhibit 1: Ana Matosantos Financial Oversight and Management Board Financial Disclosures. Exhibit 2: Office of Management and Budget, Commonwealth of Puerto Rico (OGPE), Certification of Photovoltaic System Installation, for “Matosantos”. January 13, 2015 Exhibit 3: Puerto Rico Electric Power Authority (PREPA) Interconnection Agreement with Eurocaribe Packing Company. February 13, 2015. Exhibit 4: NLPC Letter to U.S. Attomey General Jeff Sessions. April 9, 2018. Exhibit 5: Translated transcript. Interview with José B, Carrién Il, “Jugando Pelota Dura”, Univision Puerto Rico. April 19, 2019. Exhibit 6: Translated transcript. Post-meeting press conference by José B. Carrién Ill and Financial Oversight and Management Board, June 30, 2017. Exhibit 7: Andrew G. Biggs, Arthur J. Gonzalez, Ana J, Matosantos and David Skeel. “Privatize Puerto Rico’s Power”, The Wall Street Journal. June 29, 2017. Exhibit 8: Green Energy Fund Reservation Agreement between PRDCO-PREAA and Matosantos Commercial Corp. June 4, 2013. Exhibit 9: U.S. Department of Energy. “Puerto Rico ~ Net Metering” htips:/Avww.energy.gov/savings/puerto-rico-net-metering Exhibit 10: Matosantos Commercial Corp. Swom Affidavit by Manuel Matosantos. March 11,2015. Exhibit 11: Green Energy Fund Notice Letter to MCC. May 15,2013, Exhibit 12: Installation invoice in full paid by MCC. February 11, 2015. Exhibit 13: Matocantos Commercial Corp. Letter to Green Energy Fund. March 3, 2015. Exhibit 14: Green Energy Fund Inspection Form. March 12, 2015. Miguel Perez is listed as present on behalf of Matosantos. Exhi it 18: Organic Power Incorporation. October 26, 2012, Exhibit 16: Compilation of public corporate Commercial Corp. ings indicating Miguel Perez’ position at Matosantos Exhibit 17: Contract of Sale, PRIDCO and Gegloma Realty. September 30, 2010. Exhibit 18 Organic Power filing~ Miguel Perez MCC email. April 8, 2013. Exhibit 19: Organic Power —SBA Loan. December 8, 2015. Exhibit 20: Organic Power ~PRLA Loan. December 8, 2015, Exhibit 21: Organic Power ~PRLA Lease. December 8, 2015. Exhibit 22: Resolution adopted by PRIDCO. February 18, 2016. Exhibit 23: Mario Belaval. “PRMA Special Commercial Coverage: Rimco Cat Cogeneration” Caribbean Business. June 1, 2017. Exhibit 24: Registration of Property, Puerto Rico Department of Justice. October 13, 2010. Exhibit 25: Review of Gegloma Realty balance sheets, 1985-2016. Source documentation is available oon request. Exhibit 26: Eurocaribe Packing Company Financial Statement. November 28, 2011. Page 4. Exhibit 27: Control Board Watch. July 28, 2016. “Ana Matosantos”. ttpu/controlboardwatch.org/tag/ana-matosantos! Exhibit 28: Contract of Sale, Gegloma Realty to Organic Power. August 3, 2016. Exhibit 29: Puerto Rico Department of Finance, Electronic Certification, Oriental Bank to Organic Power LLC. Transaction date: August 3, 2016. Exhibit 30: Puerto Rico Department of State, Financing Statements. Organic Power LLC and Oriental Bank, August 3, 2016. Exhibit 31: Purchase and Sale Agreement. Organic Power LLC, Gegloma Realty and Oriental Bank. August 3, 2016. Exhibit 32: Organic Power LLC Deed of Mortgage #1. August 3, 2016. Exhibit 33: Organic Power LLC Deed of Mortgage #2. September 16, 2016. Exhibit 34: Organic Power LLC Deed of Mortgage #3. September 16, 2016. Exhibit 35: U.S. Securities and Exchange Commission, Form 10-K (2016) OFG Bancorp. “Credit Risk”, Page 19. Exhibit 36: U.S. Securities and Exchange Commission, Form 10-K (2017) OFG Bancorp. “Credit Risk” Page 17. Exhibit 37: Ricardo Cortes Chico and Joanisabel Gonzalez. “Entities impacted by PROMESA mandate” El Nuevo Dia. September 30, 2016. Exhibit 38: 2011 Eurocaribe Packing Company Financial Statement. November 28, 2011, Page 4. Annex I: Summary of Investigation into Ms. Ana Matosantos In May 2017, the National Legal and Policy Center (NLPC) launched an investigation into Ms. Ana Matosantos. To start, Ms. Matosantos was selected to be on the Puerto Rico Financial Oversight and ‘Management Board (FOMB) by Minority Leader Nancy Pelosi ostensibly because of her experience as director of the California Department of Finance. ‘Ms. Matosantos is a director! of the Matosantos Commercial Corporation (MCC), a large family-owned conglomerate involved in food distribution, imports and exports, and real estate in Puerto Rico. MCC is the center of the family’s network of corporate interests that include: Eurocaribe Packing Company; and Gegloma Realty Corporation. MCC is heavily invested in China through World Trade International Industrial Ltd., which is a potential new source for private investment for Puerto Rico. Interestingly, Puerto Rico hosted the first China Investment Forum a month into Governor Rossell6’s term. MCC owns and operates a solar energy generation farm in Vega Baja, Puerto Rico? The family has benefitted from a net metering arrangement where it has been selling power to the Puerto Rico Electric Power Authority (PREPA) since being connected to the Island’s power grid in 20152 This was never disclosed publicly until NLPC brought this to the publie’s attention. Further, MCC is the beneficial owner of Organic Power LLC, despite an elaborate scheme by the Matosantos family and a network of friends, associates and employees to conceal or obscure this fact from the public, the Congress, U.S. District Court Judge Laura Taylor Swain and the FOMB. ‘The FOMB’s rejection of PREPA’s Restructuring Agreement (RSA), the decision to take PREPA to Title III bankruptey and subsequent push by the FOMB for the privatization of PREPA and the establishment of micro-electric grids across Puerto Rico raise enough additional questions in the view of NLPC to warrant a federal investigation into Ms. Matosantos for possible violations of 18 USC 208 and PROMESA.* Annex I: Dominate Puerto Rico’s Renewable Energy Market Private Power Plan. Hidden from the public and misunderstood until now is the Matosantos family’s large investments in renewable energy assets. Afler an investigation that began in May 2017 by the National Legal and Policy Center, we have uncovered at least two renewable energy ‘generation assets worth millions of dollars owned by the Matosantos web of companies. " Exhibit 1: Ana Matosantos Financial Oversight and Management Board Financial Disclosures. 2 Exhibit 2: Office of Management and Budget, Commonwealth of Puerto Rico (OGPE), Certification of Photovoltaic System Installation, for “Matosantos”. January 13, 2015. > Exhibit 3: Puerto Rigo Electric Power Authority (PREPA) Interconnection Agreement with Eurocaribe Packing Company. February 13, 2015, “Exhibit 4: NLPC Letter to US. Attomey General Jeff Sessions. April 9, 2018. This raises deep concerns and questions over Ana Matosantos’s role in the Financial Oversight and Management Board’s (FOMB) decision to take PREPA to Title III bankruptcy. The decision to take PREPA to Title III was not unanimous, and in fact, passed on a 4-3 vote.’ Jose Carrién, the chair of the FOMB, likes to say, PREPA’s Title II] vote was “The only deal that we did not make unanimously.” Unfortunately, the FOMB is not transparent with its voting, records, and the roll call vote remains a secret. Furthermore, since PREPA entered bankruptcy, the FOMB has moved to privatize the utility. In ‘an op-ed’ signed by four members of the FOMB, including Ana Matosantos, the board members vwiite, “privatization would enable PREPA to attract the investments needed to reduce expenses and provide the island with a more reliable electric power system.” ‘The decision to take PREPA into bankruptcy and pursue privatization of the utility has serious repercussions for the island. The FOMB has set a target of increasing the island’s energy requirements from renewable energy going forward. This has the potential to be a huge financial windfall for the Matosantos family’s corporate interests, ‘As a director of the MCC, Ana Matosantos had direct knowledge of her family’s business — including the family’s two energy generation assets — directly and through their network of companies, including Eurocaribe Packing Company, Gegloma Realty Corporation and Organic Power LLC. This presents a serious conflict of interest and possible criminal violation of federal law. In Violation of Federal Law. PROMESA requires FOMB personal financial interests to be governed under 18 U.S.C. § 208. Here’s what the code says, “/8 U.S.C. § 208, the basic criminal conflict of interest statute, prohibits an executive branch employee from participating personally and substantially in a particular Government matter that will affect his own financial interests, as well as the financial interests of... An organization in which he serves as an officer, director, trustee, general partner or employee..." Her involvement in PREPA-related matters, including the vote to send PREPA into Title III is now under a cloud of suspicion. NLPC believes Matosantos should have recused herself from all matters regarding PREPA, and since she did not, we believe she has violated 18 USC 208 and PROMESA. Renewable Energy Asset #1: 999kW Solar Generation Farm. © The Matosantos Commercial Corporation owns and operates a taxpayer subsidized solar energy generation farm in Vega Baja, Puerto Rico.' This plant stands to benefit from the S Exhibit §: Translated transcript. Interview with José B. Carrién II. “Jugando Pelota Dura”, Univision Puerto Rico. April 19, 2019 Exhibit 6: Translated transcript. Post-mecting press conference by José B. Carri II and Financial Oversight and Management Board. June 30,2017. Exhibit 7; Andrew G. Biggs, Arthur J. Gonzalez, Ana J. Matosantos and David Skeel. “Privatize Puerto Rico's Power", The Wall Sireet Journal. June 29, 2017 Exhibit 2: Ofice of Management and Budget, Commonwealth of Puerto Rico (OGPE), Certification of Photovoltaic System Installation, for “Matosantos”. January 13, 015. privatization of PREPA because it has been selling power to the utility through net metering since it was connected to the grid in 2015. ‘© Documents reveal that the Matosantos Commercial Corporation obtained an incentive payment of $1,152,156 in June 2013 from the Puerto Rico Energy Affairs Administration (PREAA), an agency under PRIDCO, to build a 999kW solar energy farm at the family's Vega Baja headquarters". As a condition to receive the money, the construction on the solar energy farm had to be completed in one year (i.e. June 2014). However, the Puerto Rico Green Energy Fund extended the completion date to March 2015. " ‘* Documents from 2015 highlight a previously unknown agreement between MCC’s solar energy farm and PREPA, which connected the family’s solar power generators to the Island’s power grid.!? Failure to Disclose. # Ana Matosantos has never fully disclosed her role as a director with Eurocaribe Packing ‘Company as part of her role as a member of the FOMB. © New evidence indicates she either misled and/or backdated her FOMB disclosure forms. © Timeline’: = Matosantos was appointed to the Oversight Board on August 31, 2016. = As of March 5, 2016, Matosantos was not a Director of Eurocaribe Packing Company. As of April 16, 2017, Matosantos is a Director of Eurocaribe Packing Company according to PR Sec. of State documents. At some point during this period, Matosantos becomes a Director of Eurocaribe Packing Company. — Matosantos’s FOMB disclosures — signed in 2017 — do not contain this information. If Matosantos became a Director of Eurocaribe between March 5, 2016 and August 22, 2016, this should have declared on her first financial disclosure as a Member of the FOMB. — If Matosantos became a Director of Eurocaribe between August 23, 2016 and December 31, 2016, this indicates she became a Director at Eurocaribe during her tenure as a Member of the FOMB and should have disclosed it in her second disclosure. — If Matosantos became a Director of Eurocaribe between January 1, 2017 and April 16, 2017, in theory, Matosantos will now disclose it in her next disclosure update. ° Exhibit 3 Exhibit &: Green Energy Fund Reservation Agreement between PRDCO-PREAA and Matosantos Commercial Comp. June 4, 2013, "bid "2 Exhibit 3: Puerto Rico Electric Power Authority (PREPA) Interconnection Agreement with Eurocaribe Packing Company. February 13, 2015. 13 See Exhibit 1 for reference to Timeline items. Net Metering. © The signatory to the PREPA Interconnection Agreement for the 999kW solar farm is Eurocaribe; not MCC, which built the solar farm, Yet, the net metering agreement with PREPA js under “Matosantos Commercial PV System.” All of this was never disclosed. © Matosantos may claim that there is no purchase agreement or that the agreement never ‘went into effect, That is immaterial because rules on net metering with PREPA indicate that no purchase agreement needs to be signed, if a commercial client of PREPA qualifies for net metering purchases by the utility. © According to information from the U.S. Department of Energy (DOE), Puerto Rico adopted a “net metering” law in 2007 allowing corporate customers of PREPA to sell back power through offset credits on their utility bills if they produce it from renewable sources, like the Matosantos solar farm at Cabo Caribe. For a “non-residential” customer, like MCC, to qualify for the sell-back, they must have only up to 1 megawatt capacity. MCC’s solar farm has 999kW capacity. A perfect fit. They've been selling power to PREPA since 2015.'° © Further, a post-PREPA agreement affidavit signed by MCC also promises that the company will not seek nor accept state or federal monies other than what it received under the Green Energy Fund.'° This is a blanket pledge by the company, and not limited to the solar business. © Timeline: — MAY IS, 2013 - Green Energy Fund issues a Notice Letter to Matosantos Commercial Corporation on its 2012 application for a $1.1 million incentive to build the solar farm.” — JUNE 4, 2013 — Green Energy Fund signs incentive agreement with Matosantos Commercial Corporation for $1.1 million to build the solar farm. Eurocaribe is never mentioned in the document.'* — JANUARY 13, 2015 ~ The OGP of P.R. issues certifications of installation of the solar farm, indicating the customer as “Matosantos”. Eurocaribe is not mentioned in the document.” 4 Exhibit 3: Puerto Rico Electric Power Authority (PREPA) Interconnection Agreement with Burocaribe Packing Company. February 13, 2015. Exhibit 9: U.S. Department of Energy. “Puerto Rico — Net Metering” htips/wwww energy gov/savings/puerto- neterin © Exhibit 13: Matosantos Commercial Corp. Swom Affidavit by Manuel Matosantos. March 11, 2015. 1 Exhibit 11: Green Energy Fund Notice Letter to MCC. May 15,2013 ™ Exhibit 8: Green Energy Fund Reservation Agreement between PRDCO-PREAA and Matosantos Commercial Comp. June 4, 2013, Exhibit 2: Office of Management and Budget, Commonwealth of Puerto Rico (OGPE), Certification of Photovoltaie System Installation, for “Matosantos”. January 13, 2015, — FEBRUARY 11, 2015 - Installation invoice from contractor, showing that Matosantos Commercial Corporation was the customer and paid all the expenses related to building the solar farm.”” — FEBRUARY 13, 2015— PREPA Interconnection Agreement, with Eurocaribe Packing Company, for the same solar farm. Matosantos Commercial Corporation is never mentioned in the document." = MARCH 3, 2015 — Letter from Matosantos Commercial Corporation to Green Energy Fund stating that Eurocaribe is a wholly-owned subsidiary of Matosantos Commercial Corporation, with different tax IDs, but sharing the same power supply agreement with PREPA.” = MARCH 11, 2015 - Sworn affidavit, and cover letter, from Matosantos Commercial Corporation to the Green Energy Fund, affirming that Eurocaribe is a wholly-owned subsidiary of MCC, with a different tax ID. The cover letter also indicates that MCC had falsely claimed to the Green Energy Fund in April 2013 “due to a clerical error” that MCC “did not belong to a controlled group” and clarified that it is the 100% owner of Eurocaribe. The affidavit also states that Matosantos Commercial Corporation “will not receive or seek any state and/or federal funds from any incentives, tax benefits, production credits, accelerated depreciation, rebates or grants” other than those provided under the Green Energy Incentives Act of 2010 (Act 83).* = MARCH 12, 2015 - Green Energy Fund Inspection Form, where the GEF inspected the solar farm. “Manuel Matosantos” is listed as the ‘customer’ on the form. The Net Metering System name (i.e., through which the solar farm can sell ‘power back to PREPA under net metering rules) is “Matosantos Commercial PV System”.?4 Renewable Energy Asset #2: Organic Power LLC. ‘© Asseties of documents reveal that the Matosantos Commercial Corporation is the beneficial owner of Organic Power LLC, despite an elaborate scheme by the Matosantos family and a network of friends, associates and employees to conceal or obscure this fact from the public, Congress, Judge Swain and the FOMB. They also raise serious {questions on how the company was financed and secured the land. © Organic Power LLC was set up solely to generate renewable energy by recycling organic material, and operates today at the Matosantos family’s Cabo Caribe industrial park in Vega Baja. 2 Exhibit 12: Installation invoice in full paid by MCC. February 11, 2015. 21 Exhibit 3: Puerto Rico Electric Power Authority (PREPA) Interconnection Agreement with Eurocaribe Packing Company. February 13, 2015. 2 Exhibit 13: Matosantos Commercial Comp. Letter to Green Energy Fund. March 3, 2015. 28 Exhibit 10: Matosantos Commercial Corp. Sworn Affidavit by Manuel Matosantos. March 11, 2015, 244 Exhibit 14: Green Energy Fund Inspection Form, March 12, 2015. Miguel Perez is listed as present on behalf of Matosantos, 25 Exhibit 15: © Exhibit 16: comp. 27 Exhibit 17: * Exhibit 18: ? Exhibit 19: 3° Exhibit 20: 3) Exhibit 21 3? Exhibit 22: > Exhibit 17: According to Puerto Rico Department of State files, Organic Power LLC was incorporated by Miguel Perez Valdez on October 26, 2012.75 Mr. Valdez is also the Finance Director of Matosantos Commercial Corporation” and listed as Secretary of Gegloma Realty Corporation on documents from the purchase of the family’s Vega Baja industrial park where Organic Power now operates.” Despite being set up as a company supposedly owned and controlled by Perez, he has used his email address as an MCC ‘employee to do official business with the Puerto Rico Secretary of State on behalf of Organic Power.”* On December 8, 2015, Organic Power LLC obtained a $3,763,000 loan from the U.S. ‘Small Business Administration for as-yet unknown purposes.”” On the same day, December 8, 2015, Organic Power LLC signed a $250,000 contract with the Commonwealth of Puerto Rico’s Land Authority for “purchase, sale and/or rental of buildings”. It appears that the Land Authority contract was a 10-year lease taken out by Organic Power on two lots of undeveloped land close to the Matosantos family’s Vega Baja industrial park.) In February 2016, PRIDCO quietly passed a resolution authorizing Gegloma Realty to sell part of the Matosantos family’s Vega Baja industrial park to Organic Power LLC.” The PRIDCO Resolution notes that the main purpose of the sale is for Organic Power to build and operate a plant for recycling organic material and generating renewable energy. But curiously, the resolution also states, “this project is of great strategic importance for the Matosantos group of companies and for the entire region for its economic and environmental impact. It represents an investment of $10.7 million in capital and will create around 15 direct jobs and 45 indirect jobs.” All other public documents around Organic Power have obscured the Matosantos family’s role in Organic Power, but the PRIDCO Resolution establishes a clear connection, indicating the enormous financial investment being made in this energy generation asset. It also obscured the fact that Miguel Perez, the MCC executive listed as the owner of Organic Power, was also the Secretary of Gegloma Realty when the Matosantos family first bought the Vega Baja industrial park from PRIDCO in 2010.23 This frames the entire operation as being orchestrated by Matosantos Commercial Corporation and the family’s web of companies for the benefit of the family’s commercial interests. On March 22, 2017, as a member of the FOMB, Ana Matosantos testified before the U.S. House of Representatives Natural Resources Committee. In her testimony, she advocated for changes to PREPA to allow for private power generation in Puerto Rico, Nowhere in ‘Organic Power Incorporation. October 26, 2012, Compilation of public corporate listings indicating Miguel Perez’ position at Matosantos Commercial Contract of Sale, PRIDCO and Gegloma Realty. September 30, 2010. Organic Power filing ~ Miguel Perez MCC email. April 8, 2013. Organic Power ~ SBA Loan. December 8, 2015. Organic Power - PRLA Loan. December 8, 2015, Organic Power ~ PRLA Lease. December 8, 2015. Resolution adopted by PRIDCO. February 18, 2016. Contract of Sale, PRIDCO and Gegloma Realty. September 30, 2010, the disclosure forms at the FOMB™, or as required to testify before Congress, did she disclose the family’s private energy generation assets, nor the Commonwealth and federal taxpayer funds those assets have received. © On June 1, 2017, shortly after our on-the-ground investigation began, the Matosantos family began a campaign in Puerto Rico to obscure their role in Organic Power. A feature story appears in Caribbean Business depicting an individual named Brian Healy, as “the chief operating officer and co-founder of Organic Power. The story says the company ‘was “founded in 2015” and is recycling organic material for animal feed, but also “providing clean energy to clients such as Matosantos Commercial Corp and its ‘manufacturing subsidiaries at Cabo Caribe Industrial Park in Vega Baja” using propane ‘gas. Here’s the problem: No public records can be found that identify Brian Healy as an ‘owner of officer of Organic Power and no mention of MCC financial director Miguel Perez’s role in the energy company. This is an attempt to obfuscate the truth, and a deliberate attempt to hide the Matosantos family’s beneficial ownership of the company. Annex III: Shady Land Deals Financed the Matosantos Family How did the Matosantos family finanee their business empire? ‘The answer to that question begins to emerge from a series of documents obtained by NLPC that center around the family’s 2010 sweetheart deal with PRIDCO to buy the Cabo Caribe industrial park, an inflated mortgage, a massive tax windfall, and a second, even more suspicious land deal in 2016 financed by a local Puerto Rican bank where millions of dollars changed hands just days in and around Ana Matosantos’ official appointment to the FOMB. Land Deal #1: The PRIDCO Sale and the Inflated Mortgage. Itall began for the Matosantos group of companies in September 2010, when their real estate arm, Gegloma Realty, bought an industrial park in Vega Baja from the Puerto Rico Industrial Development Corporation (PRIDCO).** The contract of sale, which listed Matosantos Commercial Corporation financial director Miguel Perez. as Gegloma’s board secretary, listed the sale price as $14,720,000.00.” But curiously, according to public records, Gegloma took out a $24,355,000 mortgage on the property at 12% annual interest from Banco Santander, almost $10 million above the sale price.®* There is no documentation describing the collateral the bank accepted in issuing the inflated mortgage to Gegloma, But what is clear is that a review of Gegloma’s balance sheets from 1985 to 2016, this one land purchase appears to be the most significant event in the family’s real estate business” history, with their land assets more than ‘quadrupling as a result, but remaining flat since.” % Exhibit 1: Ana Matosantos Financial Oversight and Management Board Financial Disclosures. 55 Exhibit 23: Mario Belaval. “PRMA Special Commercial Coverage: Rimco Cat Cogeneration” Caribbean Business. Sune 1, 2017 5° Exhibit 17: Contract of Sale, PRIDCO and Gegloma Realty. September 30, 2010. "Bid 3 Exhibit 24: Registration of Property, Puerto Rico Department of Justice, October 13, 2010. » Exhibit 25: Review of Gegloma Realty balance sheets, 1985-2016, ‘The public documents show that PRIDCO was selling the land to Gegloma so the real estate arm could then rent the industrial park to the family’s food distribution subsidiary, Eurocaribe Packing Company, to set up operations there, PRIDCO included a restrictive covenant allowing Gegloma to rent or sell all or a portion to any wholly owned subsidiary, like Eurocaribe, for up to 10 years from the date of sale, but not to outside entities without PRIDCO’s permission." The Gigantic Tax Windfall for Eurocaribe. ‘According to an audited annual report, Eurocaribe claimed a $15 million tax benefit in 2010 from PRIDCO.*! This was a massive benefit for the Matosantos Commercial Corporation's manufacturing arm, closely following the inflated mortgage issued to the family’s real estate arm. Combined, the two benefits yielded about $25 million for the family’s businesses in a very short period and quadrupled their land asset holdings — practically overnight, and thanks to PRIDCO. At the time of the sweetheart PRIDCO land deal, its executive director was Javier Vazquez~ Morales. He is now the head of the Corporate Department of O° Neill & Borges, the outside legal counsel and lobbyists for the FOMB. A coincidence? Itis also notable that despite Eurocaribe’s central role in obtaining this key windfall for Matosantos Commercial Corporation, Ana Matosantos has never fully disclosed her direct, financial interest in Eurocaribe, and the confused explanation of the timing of her appointment to its board of directors seem to show an effort to obscure her links to this subsidiary.” Land Deal #2: Organic Power. ‘As NLPC reported previously, our investigation revealed that the Matosantos Commercial Corporation, of which Ana Matosantos is a director, is the secret owner of an energy asset called Organic Power LLC. MCC financial director, and Gegloma secretary, Miguel Perez, incorporated this company in 2012 apparently to give the impression of being separate from the Matosantos family. However, as our investigation previously showed the evidence points to beneficial ownership by the family as part of a broader plan to quietly enter the renewable energy ‘generation business. Further investigation shows that in addition to producing energy for Puerto Rico’s electrical grid, Organic Power was also a vehicle for Ana Matosantos’ real estate arm to obtain millions in cash through a very suspicious land deal only days after her name was publicly floated as a candidate for the FOMB. The Suspicious Timeline. July 28, 2016: Ana Matosantos was publicly named as a candidate for the FOMB. Public reports first began to surface that Ana was a candidate for the Oversight ‘© Exhibit 17: Contract of Sale, PRIDCO and Gegloma Realty. September 30, 2010. Exhibit 26: Eurocaribe Packing Company Financial Statement. November 28, 2011. Page 4. © Exhibit 1: Ana Matosantos Financial Oversight and Management Board Financial Disclosures. Board, beginning with an analysis by noted Puerto Rican lawyer and blogger, John Mudd. * August 3, 2016: The Matosantos family held a $375,000 land sale between two of its ‘companies. Six days after Ana’s name is made public, the Matosantos family signed a land deal at Cabo Caribe between their real estate arm Gegloma Realty, and their secretly held energy company Organic Power, whose titular head, Miguel Perez, is an executive at MCC. The contract of sale indicates the deal is worth $375,000.44 © August 3, 2016: On the very same day, Oriental Bank transfers $9 million in a lump sum to Organic Power. On the same day the two Matosantos companies ~ Gegloma and Organic Power ~ signed the contract of sale, Oriental Bank moved almost $9 million to Organic Power in a single transfer, purportedly to finance the $375,000 Organic Power land deal.“ ‘© No collateral is shown to explain the gap between the value of the deal and the money injected by Oriental Bank. Nowhere in the documents signed by Oriental Bank as part of the land deal is there any description of collateral or other explanation why Oriental Bank would loan $9 million to Organic Power for a $375,000 land purchase. Two sets of UCC Fixture Financing Statements specified only a propane engine being on the property along with all fixtures included in the $375,000 land value. © There is also great disarray in the mortgage paperwork with Oriental. While the $9 million was transferred prompily to the family’s energy company around noon on August 3, 2016 from Oriental Bank, the mortgage paperwork is a mess, suggesting the deal was done in haste. + Two mortgages issued for one land purchase. The purchase and sale agreement signed by Oriental Bank on August 3, 2016, stated it would issue two mortgages to Organic Power, one for $5.2 million over five years, and another for $3.7 million for 20 years. No explanation was given on how two mortgages, each worth at least 10 times the documented value of the land, were to be issued on the same property.*” ‘* Only one deed of mortgage found on the sale date, Two mortgages are mentioned in the contract, but only one deed of mortgage for $5.2 million could be found as issued on the date that Oriental Bank wired almost $9 million to Organic Power.** That deed, Exhibit 27 Control Board Watch, July 28, 2016, “Ana Matosantos”. htip/controlboardwatch.org/tag/ana- matosantos “Exhibit 28: Contract of Sale, Gegloma Realty to Organic Power. August 3, 2016 “© Exhibit 29; Puerto Rico Department of Finance, Electronic Certification, Oriental Bank to Orgenic Power LLC. ‘Transaction date: August 3, 2016. “© Exhibit 30; Puerto Rico Department of State, Financing Statements. Organic Power LLC and Oriental Bank. August 3, 2016, © Exhibit 31: Purchase and Sale Agreement. Organic Power LLC, Gegloma Realty and Oriental Bank. August 3, 2016. ‘ Exhibit 32: Organic Power LLC Deed of Mortgage #1. August 3, 2016 written in English, says the foreclosure value of the $375,000 property was $5.2 million, but does not explain how that figure was reached. An August 3 deed for the $3.7 million mortgage was never found. ‘© Then a second set of deeds appeared, but left more questions than answers. Adding ‘more questions and suspicions, a second set of deeds of mortgage were issued on September 16, 2016, a month and a half after Oriental transferred the cash to Organic Power and after Ana joined the Board on August 31, 2016. The second version of the $5.2 million deed was identical to the one issued on the sale date™, but a $3.7 million deed issued in Spanish on September 16" stated the foreclosure value of the property was not $3.7 million but like the other deed, it didn’t explain how Oriental Bank could collect almost $9 million foreclosing on property worth a tiny fraction of that amount. © Numbers don’t lie, or do they? Finally, the total financing from the two mortgages described in all the sales and mortgage documents does not add up to the amount that, Oriental Bank transferred to Organic Power on August 3, 2016. The sale*! and mortgage documents unanimously detail the two mortgages as being $5,257,625.00 and $3,763,000.00, totaling $9,020,625.00. But the electronic transfer certificate from August 3, 2016 shows Oriental Bank transferred $8,937,962.00 to Organic Power. No explanation is given for the difference of $82,663 missing from the transfer. Annex IV: Blurred Lines between Ana Matosantos and Oriental Bank. ‘The suspicious timing, the chaos in the financial paper trail, and the many unanswered questions around the millions that changed hands all suggest the land deal was a rushed and irregular transaction. Nothing about the financing of this land deal makes any sense, except that Oriental Bank gave $9 million to a company secretly held by Matosantos Commercial Corporation six days after Ana Matosantos, a director of that company, surfaced as a serious candidate for the FOMB. A closer look at Oriental’s holdings may give us a better understanding. In particular, in years 2016 and 2017, Oriental Bank remained highly exposed with loans to municipalities. © At December 2016, Oriental “had approximately $197.9 million of credit exposure” to certain municipalities in Puerto Rico. “* * At December 2017, Oriental “had approximately $145.2 million of credit exposure” to certain municipalities in Puerto Rico. *° © Exhibit 33: Organic Power LLC Deed of Mortgage #2. September 16, 2016, % Exhibit 34: Organic Power LLC Deed of Morigage #3. September 16, 2016. 5 Exhibit 31: Purchase and Sale Agreement. Organic Power LLC, Gegloma Realty and Oriental Bank. August 3, 2016. 5 Exhibits 32-34 5 Exhibit 29: Puerto Rico Department of Finance, Electronic Certification, Oriental Bank to Organic Power LLC. Transaction date: August 3, 2016. 5 Exhibit 35: U.S. Securities and Exchange Commission, Form 10-K (20168) OFG Bancorp. “Credit Risk”, Page 19. 5 Exhibit 36: U.S. Securities and Exchange Commission, Form 10-K (2017) OFG Bancorp. “Credit Risk”, Page 17. ‘According to Oriental’s own reports, “Ifthe government restructuring affects the ability of the ‘municipalities to pay their obligations to us as they become due, or under certain other circumstances, we may be required to adversely classify such loans and increase the provision ‘for loan losses in connection therewith. Such provision may significantly impact our earnings.” In fact, the FOMB has chosen not to restructure municipalities. Why? According to El Nuevo Dia “the list of entities covered by PROMESA was drawn up following an analysis carried out by Ana J. Matosantos, former Director of Finance and Budget in the state of California. Matosantos said the entities were selected on the basis of a "holistic" approach because of the complexity of the island's finances.”*" ‘Ana’s “holistic” approach determined that municipalities were not determined to be covered entities. It is common knowledge that the municipalities in Puerto Rico are in bad shape, and choosing not to reorganize is masking a ticking time bomb. Her family’s relationship with Oriental Bank and questionable mortgages raise significant questions about Ana’s role in deciding that the FOMB should not designate municipalities as covered entities and pursue a Title III restructuring of their liabilities. NLPC believes Matosantos should have recused herself from all matters regarding municipalities, and since she did not to the public’s knowledge, we believe she has possibly violated 18 USC 208 and PROMESA. Oriental Bank now owns all the Suspicious Matosantos Mortgages and Municipalities are still not Covered Entities. ‘A curious detail in the purchase and sale agreement between Gegloma, Organic Power and Oriental Bank reveals that at some point, Oriental acquired the inflated mortgage that Gegloma took out in 2010 for the PRIDCO sale.** That means that Oriental holds all of the most crucial financing that the Matosantos web of financial interests needed to launch itself from obscurity in 2010 to the multi-million-dollar renewable energy conglomerate it was on the day Ana ‘Matosantos was named to the FOMB. % Exhibits 35 and 36 57 Exhibit 37:. Ricardo Cortes Chico and Joanisabel Gonzalez, “Entities impacted by PROMESA mandate” ET ‘Nuevo Dia, September 30, 2016. 5 Exhibit 33: Organic Power LLC Deed of Mortgage #2. September 16,2016. See page 5, Note (B) May 16, 2018 The Honorable Jeff Sessions U.S. Attomey General United States of America The Honorable Paul Ryan Speaker U.S. House of Representatives The Honorable Rob Bishop Chairman Committee on Natural Resources USS. House of Representatives Dear Sirs Sessions, Ryan and Bishop: On April 9, 2018, the National Legal and Policy Center (NLPC) requested that Attomey General Jeff Sessions open an investigation into Ms. Ana Matosantos, a member of the Puerto Rico Financial Oversight and Management Board (FOMB) based on conflicts of interest we had ‘uncovered in the course of a one-year investigation.! Since then, the FOMB wrote letters to your offices on May 8, insisting that no investigations be conducted based on any of the evidence we referenced in our April 9 letter. ‘The FOMB’s letters included false, misleading and even contradictory claims that appear to show the Board’s ethics officer acting not as an independent and unbiased watchdog, but as a vigorous advocate for Ms. Matosantos” business interests. An objective reading of these letters, which contain declarative and conclusive defenses of Ms. Matosantos’s business dealings without citing nor attaching corroborating evidence of their claims, suggests the FOMB never actually conducted an independent investigation but merely colluded with her to thwart one being launched by you Given these circumstances, NLPC respectfully restates its request for a U.S. Department of Justice investigation into this matter, as well as a Congressional investigation of the facts and evidence we have uncovered. Since our April 9 letter, we have uncovered a great deal more evidence that has widened the scope of the conflicts Ms. Matosantos must explain, For this reason, and the false and misleading affirmations in its letters to your offices, we also request that the FOMB itself be investigated for its actions to cover up the scandal now engulfing Matosantos and the FOMB. In order to provide the most complete overview of the facts, Ihave attached a comprehensive annex describing the complete results of our investigation, along with all of the " Exhibit 4: NLPC Letter to U.S, Attomey General Jeff Sessions. April 9, 2018. exhibits of evidence we have obtained over the last year. I will add that NLPC has published this full annex and all the exhibits on our website— www.nlpe.org ~ for the purposes of full transparency and public serutiny. In this letter, I will first provide an overview of the new information we have uncovered since our April 9 letter to Attorney General Sessions. Then, I will review and explain each of the false, misleading and contradictory affirmations that the FOMB made in its May 8 letters to your offices, with references to the to the specific exhibits of the evidence we have obtained and enclosed in the annex. It is our hope that the sum of the evidence we are providing here will support a decision to open investigations and get to the truth, The future of Puerto Rico depends on it, and the people of Puerto Rico deserve the truth. New Evidence Implicating Ms. Matosantos in Suspicious Financial Transactions ‘The Matosantos Commercial Corporation (MCC) owns and operates a solar energy generation farm in Vega Baja, Puerto Rico. The family has benefitted from a net metering arrangement with the Puerto Rico Electric Power Authority (PREPA) since being connected to the Island's power grid in 2015. This was never disclosed publicly until NLPC brought this to the public’s attention, and was the basis for our original request to the U.S. Department of Iustice. In the preceding weeks, we had discovered that MCC is the beneficial owner of Organic Power LLC, despite an elaborate scheme by the Matosantos family and a network of friends, associates and employees to conceal or obscure this fact from the public, the Congress, U.S. District Court Judge Laura Taylor Swain and the FOMB.* Since the April 9 letter to you, our concems have only grown. Documents newly obtained by NLPC can now confirm that in order to finance their renewable energy ambitions and other expansions, the Matosantos family used MCC’s real estate arm, Gegloma Realty, to obtain tens of millions in cash through two suspicious land deals involving the Puerto Rico goverment agency, PRIDCO, an industrial park in Vega Baja, Puerto Rico, a massive tax windfall, and a series of dubious mortgages, some of which were issued by one of the largest banks in Puerto Rico just six days after Ana Matosantos’ name was publicly floated as a candidate for FOMB. The newly uncovered documents reveal that in 2010, the family purchased the Vega Baja industrial park from the Puerto Rico Industrial Development Company (PRIDCO) for $14.7 million? Nevertheless, on the same day they somehow obtained a mortgage for $24.3 million, about $10 million above the sale price.® In addition, the family’s business took a massive $15 million tax windfall from PRIDCO the same year.” In all, thanks to PRIDCO, the Matosantos ‘group netted $25 million in financing practically overnight in what can only be termed a sweetheart deal. Exhibit 4: NLPC Letter to U.S. Attorney General Jeff Sessions. April 9, 2018. Tid “Tid S Exhibit 17: Contract of Sale, PRIDCO and Gegloma Realty, September 30, 2010. © Exhibit 24; Registration of Property, Puerto Rico Department of Justice. October 13, 2010, 7 Exhibit 38: 2011 Eurocaribe Packing Company Financial Statement, November 28, 2011. Page 4 ‘Then, in 2016, only six days after Ana Matosantos was publicly named as a candidate for the FOMB, the family sold a portion of that industrial park to their secretly held energy asset, Organic Power LLC, for $375,000.° But on the same day, Oriental Bank transferred $9 million ina lump sum to Organic Power under a mortgage agreement. No collateral is shown to explain the enormous gap between the value of the deal and the money wired to the company. The sale documents and records obtained by NLPC are in disarray, suggesting a hasty and irregular transaction with very suspicious timing. Nothing about the financing of this land deal makes any sense, except that Oriental Bank gave $9 million to a company secretly held by Matosantos Commercial Corporation in August 2016, six days after Ana Matosantos, a director of the company, surfaced as a candidate for the FOMB. Then, in September 2016, Ms. Matosantos chaired the FOMB's analysis into what aspects of the Puerto Rican Government would be considered a “covered entity.” The FOMB described Matosantos’s engagement as “holistic” analysis, which the Board relied on in its decision not to declare municipalities as a “covered entity” under PROMESA."° In doing so, ‘Ana Matosantos sheltered nearly $200 million in credit risk exposure for Oriental Bank'' in the process from possibly being restructured under Title III. ‘As we mentioned in our previous letter, through the Matosantos family’s solar power generation asset and its beneficial ownership of Organic Power LLC, Ms. Matosantos directly benefits from the FOMB’s rejection of PREPA’s Restructuring Agreement (RSA), the decision to take PREPA to Title III bankruptcy and subsequent push by the FOMB for the privatization of PREPA and the establishment of micro-electric grids across Puerto Rico. It raises enough additional questions to warrant a federal investigation into Ms. Matosantos for possible violations of 18 USC 208 and PROMESA. But with the full evidence we have now uncovered, ‘we request the investigation into Ana Matosantos be broader, to include her roles as a director of both Matosantos Commercial Corporation and Eurocaribe Packing Company, her financial interest in Gegloma Realty, and her undisclosed business relationship with Oriental Bank through her disclosed and undisclosed assets. False and Misleading May 8 Letter from FOMB to Attorney General Sessions In his letter to the Attomey General, on behalf of the FOMB, Jaime A. El Koury made several affirmations that are contradicted by the evidence we have provided to you in the annex and exhibits with this letter. I will now list and respond to each one, and make citations to the exhibits in evidence I have provided: 1. “[FJrom the Board’s review, it appears that Ms. Matosantos and MCC have no ownership interest in Organic Power.” * Exhibit 28: Contract of Sale, Gegloma Realty to Organic Power LLC, August 3, 2016. ° Exhibit 29: Puerto Rico Department of Finance, Electronic Certification, Oriental Bank to Organic Power LLC. 4 Exhibit 37 Ricardo Cortes Chico and Joanisabel Gonzalez. “Entities impacted by PROMESA mandate” EI Nuevo Dia, September 30, 2016. 1 Exhibit 35 U.S. Securities and Exchange Commission, Form 10-K (2016) OFG Bancorp. “Credit Risk”, Page 18. ‘This misleading claim from the FOMB is made without citing or describing any documents or public filings, or any testimony, questionnaire, deposition or affidavit that indicates an actual “review” took place. If the FOMB conducted no actual investigation, then the conclusion “would appear” to be true. But the voluminous evidence NLPC has obtained and laid out in the annex to this letter indicates MCC, and by extension Ms. Matosantos as a director of MCC, are the beneficial owners of Organic Power LLC, and have made efforts to hide it from public view. However, the resolution by PRIDCO granting permission to the family’s real estate arm, Gegloma, to sell part of the family’s industrial park in Vega Baja to Organic Power spells out the financial interest directly, stating that Organic Power “is of great strategic importance for the Matosantos group of companies” and it “represents an investment of $10.7 million in capital.” According to Puerto Rico Department of State files, Organic Power LLC was incorporated by Miguel Perez Valdez on October 26, 2012.'? Mr. Valdez was also the Finance Director of Matosantos Commercial Corporation and listed as Secretary of Gegloma Realty Corporation on documents from the purchase of the family’s Vega Baja industrial park where Organic Power now operates.'® With this misleading statement, the FOMB is acting more like the family’s defense counsel rather than as a watchdog, looking more deeply into what all the evidence clearly indicates is going on. “The allegation that Organic Power’s CEO, Miguel Perez Valdez, is also presently an MCC executive and a Secretary of Gegloma Realty is also mistaken. He is neither, and itis the Board’s understanding that he has not had a position with either company since October 2016.” In this affirmation, the FOMB uses a misleading play on words to actually admit that Mr. Perez was indeed the Finance Director of MCC and the Secretary of Gegloma Realty until, at least, October 2016, nvo months afier Ms. Matosantos was appointed to the FOMB. That means the FOMB is admitting he held these positions under the Matosantos family at the same time he incorporated Organic Power LLC® and conducted business on its behalf from October 2012 until October 2016'7. This also means Mr. Perez was still at Gegloma when that company sold land to Organic Power in August 2016", six days after Ms. Matosantos’ name was publicly mentioned as a candidate for the FOMB,'? which led Oriental Bank to wire $9 million dollars to “his” company, Organic Power.” Moreover, Mr. Perez was still at MCC, Gegloma and Organic Power in September 2016 when Ms. Matosantos’ guidance to the FOMB led to the decision not to designate Puerto Rico's municipalities as “covered entities.” Let us also not forget that Mr. Perez was listed as "2 Exhibit 22: Resolution adopted by PRIDCO. February 18, 2016, +3 Exhibit 15: Organic Power Incorporation. October 26, 2012. \ Exhibit 16; Compilation of public corporate listings indicating Miguel Pere2" position at Matosantos Commercial Corp. 15 Exhibit 17; Contract of Sale, PRIDCO and Gegloma Realty. September 30, 2010 6 Exhibit 15 7 Exhibit 18 18 Exhibit 31: Purchase and Sale Agreement. Organic Power LLC, Gegloma Realty and Oriental Bank. August 3, 2016. '° Exhibit 27: Control Board Watch, July 28, 2016. “Ana Matosantos”. 2 Exhibit 29 representing the Matosantos family at the inspection of the family’s solar energy farm," through which they would sell energy to PREPA in the form of credits under net metering rules. Therefore, the FOMB has admitted that Mr. Perez indeed had a very central role on behalf of the Matosantos family in every one of these entities involved in a number of suspicious schemes dating back to 2010 that enriched them by millions of dollars. . 3. “MCC and Gegloma Realty do not presently have business or financial relationships with PREPA, other than as general electricity customers. Indeed, based on the information the Board has collected and reviewed, there is no evidence that MCC sells electricity to PREPA, has any surplus energy to sell to PREPA, or has any plans (or capacity) to do so in the foreseeable future.” ‘This is false, As with its entire letter, the FOMB cites no “information” that it allegedly had “collected and reviewed” to make this claim, But NLPC has obtained the documentation indicating that MCC obtained $1 million from the Green Energy Fund (PRIDCO-PREAA)” and paid all the expenses of building a 999kW solar energy farm at the family’s industrial park in Vega Baja. But the MCC subsidiary, Burocaribe Packing Company, signed the interconnection agreement with PREPA,™ through which power ‘was to be sold to PREPA in the form of credits under Puerto Rico’s net metering rules.” ‘The FOMB letter, in this case, never acknowledges that the MCC subsidiary, Eurocaribe, was inexplicably the signatory of the PREPA agreement despite playing no role in building or financing the solar power farm. But perhaps this omission by the FOMB in its letter was deliberate. It is clear, however, from a swom affidavit signed by Manual Matosantos”* that Eurocaribe is a subsidiary of MCC, and therefore, MCC has the net metering relationship with PREPA. 4. “[T]he Board is not aware of any evidence that Ms. Matosantos stands to realize or suffer any tangible, pecuniary gains or losses as a direct and/or predictable result of any vote or decision concerning PREPA because of her holdings in MCC and Gegloma Realty.” ‘This is an alarming statement coming from a body that claimed to have investigated this matter, that they are “not aware of any evidence” of the clear connections between Ana Matosantos, MCC's solar power farm and PREPA laid out in the exhibits we have provided. It lends further weight to the belief that the FOMB conducted no investigation of these matters at all, and its letter is premised on a falsehood. 2 Exhibit 14: Green Energy Fund Inspection Form, March 12, 2015, 2 Exhibit 8: Green Energy Fund Reservation Agreement between PRDCO-PREAA and Matosantos Commercial Comp. June 4, 2013. ® Exhibit 12: Installation invoice in full paid by MCC. February 11, 2015. % Eshibit 3: Puerto Rico Electric Power Authority (PREPA) Interconnection Agreement with Eurocaribe Packing Company. February 13, 2015 % Eghibit 9: U.S. Department of Energy. “Puerto Rico ~ Net Metering” https:/www.energy gov/savings/puerto- rico-net-metering 2 Exhibit 10: Matosantos Commercial Corp. Sworn Affidavit by Manuel Matosantos. March 11, 2015. “Ms, Matosantos has been transparent concerning her financial interests, and the charges levied against her in the Letter are premised in part on information she disclosed on her financial disclosure forms which the Board has published on its website.” ‘The FOMB has once again made a conclusive affirmation but not provided any of the evidence or information to reach that conclusion, NLPC concurs that our investigation has been premised in part on the information in Ms. Matosantos’ financial disclosure forms”” published on the FOMB’s website. But that was the start of our investigation — indeed, Exhibit 1 — which led us to the comprehensive annex and other exhibits enclosed with this letter. It seems, however, that her financial disclosure forms were the end of the FOMB?s “investigation”. This is a serious dereliction of its duty to investigate and account for conflicts of interest we have seriously substantiated with the evidence provided here, and grounds for an investigation of the FOMB itself. False and Misleading May 8 Letter from FOMB to Chairman Bishop and Speaker Ryan Koury, in response to a letter sent to both officials by the group, Taxpayer Protection Allian In his letter to Chairman Bishop and Speaker Ryan, on behalf of the FOMB, Jaime A. El citing NLPC’s investigation makes several affirmations here that are contradicted by the evidence we have provided to you in the annex and exhibits with this letter. I will now list and respond to each one, and make citations to the exhibits in evidence provided: L “I]t is unclear on what basis the Letter concludes that MCC “secret[ly] own[s]” Organic Power and Organic Fuel, but whatever the case, the allegations appear to be ‘false. From the Board's review, it appears that Ms. Matosantos and MCC have no ‘ownership interest in Organic Power or Organic Fuel.” As stated above, NLPC has already provided ample evidence to substantiate the claim that MCC, and by extension in her role as a director, Ana Matosantos, are beneficial ‘owners of Organic Power. The FOMB states that “the allegations appear to be false,” but again does not cite the evidence they have to reach this conclusion. This misleading statement around the “appearance” of no ownership interest, as in the letter to the Attorney General, suggests no definitive investigation or review took place and they are going merely on appearances, As I have explained in this letter, with ample evidence in the annex, MCC's beneficial ownership of Organic Power was meant to be hidden; therefore, it would not “appear” without an investigation. NLPC conducted one, and the FOMB did not. “It is the Board’s understanding that MCC’s “hidden” net metering agreement with PREPA has not been in effect since August 2017. Additionally, MCC never received “payments from PREPA in the form of credits,” as alleged in the Letter. Instead, MCC's net metering agreement with PREPA provides only for a one-to-one offset on MCC's energy utilization — an arrangement we understand to be standard for these agreements.” 2 Exhibit 1: Ana Matosantos Financial Oversight and Management Board Financial Disclosures. ‘The FOMB misleads by omission and obfuscation in this statement. First, it is true that the interconnection agreement for MCC's solar power farm was signed, inexplicably, by its subsidiary Eurocaribe Packing Company,”* which played no role in its building ot financing. But the details of this agreement were not publicly known, nor disclosed by Ms. Matosantos, until NLPC made them public. Secondly, by attempting to state that net metering does not result in MCC selling power to PREPA in the form of credits, they are contradicting the U.S. Department of Energy’s description of these “arrangements”, stating in black and white that under net metering, “excess credits will be purchased by PREPA.”® By using a play on words, the FOMB says a one-to-one offset is somehow different from a credit, but the USDOE shows they are simply obfuscating on Ms. ‘Matosantos’ behalf. Lastly, the FOMB claims the net metering agreement was no longer in effect in August 2017. But this was a full year after Ms. Matosantos was appointed to the FOMB, after Ms. Matosantos testified in March 2017 before the U.S. House of Representatives Natural Resources Committee, where she advocated for changes to PREPA to allow for private power generation in Puerto Rico, after the FOMB vote rejecting the PREPA RSA and after the Board voted to take PREPA to Title IIT. Nowhere in any of her disclosures did she report this relationship with PREPA, and if it ended in August 2017, it does not exonerate Ms. Matosantos for the conflict it presented for a full year beforehand. To suggest otherwise is yet another reason the FOMB should be investigated. 3. “Significantly, MCC has not received an offset under the agreement since August 2017 and may never benefit from the agreement in the future. That is because, although MCC has solar panels that were previously connected to PREPA’s grid, the Board understands that those solar panels were severely damaged as a result of Hurricanes Irma and Maria, have since been disabled, and may not be repairable, As a result, MCC does not presently have any business or financial relationships with PREPA, other than as a general electricity customer. Indeed, based on the information the Board has collected and reviewed, there is no evidence that MCC sells electricity to PREPA, has any surplus energy to sell to PREPA, or has any plans (or capacity) to do so in the foreseeable future.” This statement from the FOMB contradicts, at least in spirit, the claim that MCC never benefitted from selling energy to PREPA in the form of credits. In fact, this statement fiom the FOMB affirms our investigation that Matosantos and MCC did financially benefit from PREPA, only interrupted by Hurricanes Irma and Maria. Therefore, by implication, the FOMB is admitting that the conflict of interest existed only for her first year as a Board member, may never be restored, and is not currently benefitting. This does not exonerate Ms. Matosantos for either the intent to withhold material information showing a conflict of interest from the day of her appointment until August 2017. Again, this was almost a full year after Ms, Matosantos was appointed to the FOMB, after Ms. ‘Matosantos testified in March 2017 before the U.S. House of Representatives Natural Resources Committee, where she advocated for changes to PREPA to allow for private power generation in Puerto Rico, after the FOMB vote rejecting the PREPA RSA and 2 Exhibit 3 » Exhibit 9 after the Board voted to take PREPA to Title II. The FOMB letter concludes by urging “the U.S. House of Representatives decline to investigate this matter”, again in the manner of a defense counsel for the Matosantos family rather than a collegial body charged with investigating possible violations of federal law by a public official. Mr, Attorney General, Speaker Ryan and Chairman Bishop, we call upon the U.S. Department of Justice and the U.S. House of Representatives to conduct a full investigation into Ms. Matosantos concerning her roles as a director of both Matosantos Commercial Corporation and Eurocaribe Packing Company, her financial interest in Gegloma Realty, her family’s beneficial ownership of Organic Power LLC, and her undisclosed business relationships with PREPA and Oriental Bank through her disclosed and undisclosed assets. 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January 13, 2015. CCERTIFICAGION DE INSTALACION SISTEMA FOTOVOLTAICO DATOS DE LOCALZACION ‘Op user le emecien supiishage oo sok moa eacn da rsalandn Jester Plvotsbos Comers rdo ‘Plowontiao a stom de Auiad de Energie Eaten Nebr: Malang ‘cur en: cosine @azeaa Oe, Dacor Fises, Cobo Cake IndusinL Par ASteehLcl23 Latins oghs CUE} 1B 27.05/65. 220 ‘esa a, Puno ico DATOS DE LOS oUPOS, “To de Eqips: iis Fotis Tee Egos nesses ane itt cheese Noe zy ‘ec ST 2ccor us 8 ne gam ue oATOS DEL PROVECTSTA . “Gniicade poring. Ange R. Zaye ueheone, US 7180 DATOS DE LA NSTALAGION Tnsniasor Ing. Angel ©, varouse Tee, 2203 ‘Goto de magus rafal: $3, 204.878.00, Tipo de Cerfeactn: Pamananto Foot ramiedn- 25 de osu de 204 Nb de Gran: ARE-PV.OR Division NFRAESTRUCTURA Los sg requrnarts y vecomendocaruscrespendan ls Dvn de nest ‘Atos e Energie Eto: CASO NOM: AEE-13-018, CAPACIOAD EVAWUADA: GBB KWAC 007 8514NV OG Wego dei exuactn dob sold se deine quo ssama Inareanaten de Generar Ditibdo (6D) papune ‘ars ao eres ogi pon pons nroaen a. Se Pea nema ste sabi ‘Slaton dopootionee gatas sobre ot tombs en coin del 90. our. 2046 DUISION EDIFICARILIDAD {Los eens requrieion y ecomerdoconesconeaponden ala Dv de Edt: Deter carp con ls reqlstosyfacorendocenes mangas pe a oddad do Eryn Eckert car de 50 ge cole de 2014, a! camo Regimrios, Chagos, -ayenEnttlesy Fedele Sogn epkguen CONDICIONES CENERALES sta reomeniacn es aplcable lamest as stuscén do hechosy dst eogin rosea y eusinds port» CGP, Enron tis lees yrejamorioe opiobes ruriple, essa, aac ietyondo 6 loa ome yFequsimiento ‘laa a cequndad acipmsonal, concen, eectitaay we passe aor. CONDICIONES EEPECIALES Bajo ningina ceansanc, dobersbtepredr aue ea recomendcin fava Imlique Srohaien de metic de eae ort wn proven de constusan aoe 98 ab ice mou Seay fo cosanon de cee Sg, a re et ‘Snesponsiets prise ce coniveli de reqverse, Fimas Selioe Fecha do expeditsn ‘Widemnends 2015 con Porat ‘dyar: | sBiun2g [ sjooy | sseoay NT | MIA weyshS Ad | eIOJSWLUOD SO}UBSO}e|\| Soin in coca Ra teres rwerre nee “CERTIFICACION DE INSTALACION SISTEMA FOTOVOLTAICO DATOS DE LOCALIZACION nc De acrerdo ee nfornostn roninseosa o oso crzarn co wetacn 2 tena folcacme Coneria: Pade Forconecd tom dos Auosdad do Enero Ets embassies ore Scie enn arenas, Nome MA cate ntti AStest Lot Z3 Taonga) 18 208.2820 espa. rao Ba DaToe 96.03 EaUIpOS “once Equpos bcos Floss “Ton de Eat rveaaee Stee saarn fines Noses Nodes Ah SIP 2007s 8 ch STP GOONS 708 DEL PROVESTISTA ‘otflens png Ange. Zan Dichowne, Ue 18100 DATOS DE LAINSTALACION Instatdr ng. Angel. vee Toe, Ue. 24288 Comodo eansseon esos: 32018700 ‘eos Gotkcacr Parmar Pera Matai 2s ecb de ate ‘Ni de Curler: AAEV.O098 DIVISION INERAESTRUCTURA Toe sigs vequerrontonyormandadoes caesponden le Disn de inet: pt De Enea fea, CASO NUM: AEE-.019; CAPACIDAD EVALUADA: 000 HAC 00716 KDC coage cle uncn dace odoinn ue sisson de Gen Dino (3) oe anc decyl pom promos do reteenexn apm Socorro or oes Care ee clones onenes soe ookssbtoras en cra el 0 cb octatre d 2044, DIVISION EDIFICABILIDAD ow sigur eqerniniceyrcomerdaciowe Coverpondo 2a Den de Eceabiiad Cae aere im requsceyrcnmedaderes menceraec po: a Aue do Ene cea ecari cata ee si como ve Rogiamarion, Coden, Leyos Ean Fcersies sg —HIR2E7. ‘CONDICONES GENERALES. cata ecomendarib os apple sourerte ae atvagondarerios y doa rin presets yevuaee pore O07 Enea rocomepdalon oy ole ptctine rnp, ext, oer uyedo a 98 Momma Y requcint carpet oe ecovouraconabucln, secon y do monde omblole- eae aaa poo went iin equon ies, acoso els toma a naan > caine Ngan geri Pe epi denen Everson oa Gs de Gwenn ce Pama, cout 2 wosee man moana te La enna Oo Sonar by Stmros De Enna Renova’ 7 EI Raganoto Se eb Renioos Par Caras De Gonsiasio ¥ Urs Oe Terence CONDICIONES ESPECIALES, ee argue ccaran, Gobo paar qu ea fecunendacn evo impiaw » asain de ai ae cms ss ric ac Obs do conn cls 08s tb et ‘Sretpnctone perso de conse de raqueree. 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The Sunny Tripower delivers ftuee proof solution with fl grid management functionality, cating edge communications end ‘edvanced monitoring. The Sunny Tinower ico equipped with ll pole ground ful protecton and itegrotad AFCIfor a sae, reliable soltion, toes unmatched lextilty with @ wide inputvollagerange-end two independent MPP nockors. Sutcbl for both 600 V DC ond 1,000 DC applications, he Sunny Tipower allews for flexible design and alowerlevalized cost cFenergy. tonnes ope (OC) Na alte Daca’ A} ent © povatoy ° . soaveetoy. | | BalsoV-leo0y so yEToDON | RV] Wey 1s0V/t08V. : ea ee IgM] Sega TESMA/IA | 6BATA SATIN” USANA

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