Estimated Hearing Date: To be announced by Court

Objection Deadline: To be announced by Court 

UNITED STATES DISTRICT COURT

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)

PLAINTIFF BLANCA IRIS MARRERO’S FURTHER 

CONSENTED MOTION FOR EXTENSION OF TIME TO FILE REPLY OR 

OTHERWISE INFORM AGREEMENT WITH DEBTORS

1 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 4780-LTS) (Last 

Four Digits of Federal Tax ID: 3747) (Title III case numbers are listed as Bankruptcy Case numbers due to software 

limitations).

Case:17-03283-LTS Doc#:22673 Filed:10/24/22 Entered:10/24/22 10:56:19 Desc: Main

Document Page 1 of 3
Estimated Hearing Date: To be announced by Court

Objection Deadline: To be announced by Court 

TO THE HONORABLE LAURA TAYLOR SWAIN,

UNITED STATES DISTRICT JUDGE:

COMES Now, State Court Plaintiff Blanca Iris Marrero (“claimant”), represented by the 

undersigned attorneys, and very respectfully avers and prays as follows:

1. On June 12, 2022 at ECF No. 21192 the appearing claimant filed her application for 

payment of administrative expenses on account of a civil tort claim filed at the Puerto Rico 

Court of First Instance, San Juan Superior Part.

2. On August 26, 2022 at ECF 21931 the Debtors Commonwealth of Puerto Rico

(“Commonwealth”) and Public Buildings Authority (“PBA”) filed their objection to 

claimant’s application.

3. Counsel for claimant and counsel Steve Ma on behalf of the Debtors held a further 

telephone conference last week to continue to explore the possibility of reaching a 

mutually agreeable solution to this issue. To that effect, certain further courses of action

discussed by the parties’ counsel during their telephone conference last week are being 

considered by counsel for the Commonwealth and PBA. All of this is taking place at 

present.

4. In light of the above stated, counsel for the Commonwealth and PBA amiably agreed to 

grant claimant herein a further 14 day extension of time to be counted from October 25, 

2022, until November 8, 2022 to file any reply, if needed, to the opposition to claimant’s 

administrative claim. In light of this further conversations, the Court’s November 2, 2022

hearing date would need to be set aside and rescheduled to the next available date. We 

respectfully submit that the conversations we have had with counsel Ma have been 

productive.

Case:17-03283-LTS Doc#:22673 Filed:10/24/22 Entered:10/24/22 10:56:19 Desc: Main

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Estimated Hearing Date: To be announced by Court

Objection Deadline: To be announced by Court 

NOTICE

Notice of this Motion has hereby been served by CM/EF and on the Master Service List posted 

on the website of the Debtor’s Claims and Noticing Agent, by e-mail or by first-class mail.

No prior request for the relief sought herein has been made to this Court or to any other court.

WHEREFORE, the appearing Claimant respectfully requests that this Court allow movant 

herein to file her reply to ECF 21931, if needed, by November 8, 2022, and that the hearing on the 

issue set for the November 2, 2022 scheduled date be set aside and moved to the next available 

date, with any other appropriate relief.

RESPECTFULLY SUBMITTED.

Dated: October 24, 2022

Respectfully submitted,

 s/ Fernando Van Derdys, Esq.

 USDC-PR 201913

 Law Offices of F. Van Derdys

 P.O. Box 9021888

 San Juan, PR 00902-1888

 Tel. 787.519.2211

 E-mail: fvanderdys@gmail.com 

Case:17-03283-LTS Doc#:22673 Filed:10/24/22 Entered:10/24/22 10:56:19 Desc: Main

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