The documents provided below are just a subset of the evidence we have gathered. Multiple other documents are being withheld for strategic reasons and / or due to ongoing or upcoming litigation. All documents provided below are public and have either been obtained through formal requests to PR-DNER, OGPE, the PR Tourism Company, Freedom of Information Act (FOIA) requests, or through the Puerto Rico SUMAC court system database. We will continue to update this database as more information comes in.

Documents related to the Puerto Rico Tourism Company and Tax Credits

• Concession of Tax Exemption and Tax Credits granted to Rincon Bluewater LLC by Puerto Rico Tourism Company

Documents related to EPA violations at project site (wetland fill & NPDES). These are PUBLIC documents obtained through a FOIA request.

• Wetland fill notification and RFI from EPA to Rincon Bluewater LLC

• EPA NPDES Inspection Report

• EPA NPDES Request for Information

• EPA NPDES Compliance Order

Letters between Rincon Bluewater and land seller regarding wetland fill and mortgage execution court case. These are PUBLIC documents obtained through the SUMAC court system database.

• Letter #1 from Rincon Bluewater to land seller, where Lonnie Fuller expresses his intent to direct his engineers to redraft or modify the Jurisdictional Wetland Determination Study to a more favorable one to Rincon Bluewater

• Letter #2 from Rincon Bluewater to land seller, requesting time extension to deal with “wetlands” issue

• Letter from #1 from land seller to Rincon Bluewater, indicating that Rincon Bluewater was fully aware of the wetland fill issues

• Letter from #2 from land seller to Rincon Bluewater, where seller notifies Rincon Bluewater that “It is worth noting that the record will show that back in October 2018, Mr. Fuller, officer of RBW, acknowledged the presence of such filling material in the property and later in November of the same year, he consented on its continuing presence in the property after closing and up to this date”

Documents related to ongoing court cases between land seller and Bluewater Rincon

• Mortgage execution lawsuit

• Rincon Bluewater’s answer to lawsuit

• Rincon Bluewater’s opposition to summary judgment

• Resolution where judge confirms Bluewater knew of wetlands

Miscellaneous documents related to plans, soil studies, etc.

• Soil study conducted by Rincon Bluewater that confirms existence of wetlands and swam deposits and fill material over wetlands

• Rincon Bluewater site plan

• Flora and fauna study conducted by Rincon Bluewater, carried out, rather conveniently, just after the fill was placed over the wetland

• Declaration of no environmental impact, carried out, rather conveniently, just after the fill was placed over the wetland