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

Re: ECF No. 22549

(Jointly Administered)

URGENT CONSENSUAL MOTION FOR FURTHER EXTENSION

OF RESPONSE DEADLINES AND RESCHEDULING OF HEARING DATE

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

The Commonwealth of Puerto Rico (the “Commonwealth”), and the Puerto Rico Public 

Buildings Authority (“PBA” and, together with the Commonwealth, the “Debtors”), by and 

through the Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), 

as the sole Title III representative of the Debtors pursuant to section 315(b) of the Puerto Rico 

Oversight, Management, and Economic Stability Act (“PROMESA”),2 respectfully submit this 

urgent consensual motion (the “Urgent Motion”) for entry of an order, substantially in the form 

 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); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) 

(Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Last Four

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case No. 19-BK-5523-

LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations).

2

 PROMESA is codified at 48 U.S.C. §§ 2101–2241.

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attached hereto as Exhibit A (the “Proposed Order”), rescheduling the hearing date and extending 

the deadlines established in the Order Granting Urgent Consensual Motion for Further Extension 

of Response Deadlines and Rescheduling of Hearing Date [ECF No. 22549] (the “Extension 

Order”) solely with respect to the Applicable Motions (as defined below), and state as follows:

Background

1. On January 18, 2022, the Court entered the Order and Judgment Confirming 

Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, 

the Employees Retirement System of the Government of the Commonwealth of Puerto Rico, and 

the Puerto Rico Public Buildings Authority [ECF No. 19813] (the “Confirmation Order”), 

confirming the Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth 

of Puerto Rico, et al., [ECF No 19784] (as amended, supplemented, or modified, the “Plan”).

3

 

2. On March 15, 2022, the Effective Date of the Plan occurred, and the Plan was 

substantially consummated [ECF No. 20349]. Pursuant to Section 1.51 and Article III of the Plan 

and decretal paragraph 44 of the Confirmation Order, the deadline for filing proofs of 

Administrative Expense Claims was June 13, 2022 (the “Administrative Claim Bar Date”). Id. 

3. The following motions seeking, among other things, allowance and payment of 

Administrative Expense Claims were filed on or before the Administrative Claim Bar Date 

(collectively, the “Administrative Expense Motions”):

 3 Unless otherwise defined herein, capitalized terms shall have the meanings ascribed thereto in the Plan. 

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Motions for Which Debtors Seek Extension:

ECF 

No. Motion Party4 Status

21187

Evertec’s Motion for 

Allowance of an 

Administrative Expense 

Claim

Evertec Group, LLC 

(“Evertec”)

Objection Deadline: 

November 8, 2022 at 4:00 

p.m. (AST) 

Reply Deadline: November 

15, 2022 at 4:00 p.m. 

Hearing: December 14, 

2022 

[Extension Order, ECF No. 

22549]

21191

Ricoh Puerto Rico, Inc.’s 

Motion for Allowance and 

Payment of Administrative 

Expense Claim in the sum of 

$4,864,017.20

Ricoh Puerto Rico, 

Inc. (“Ricoh”)

Objection Deadline: 

November 8, 2022 at 4:00 

p.m. (AST) 

Reply Deadline: November 

15, 2022 at 4:00 p.m. 

Hearing: December 14, 

2022 

[Extension Order, ECF No. 

22549]

21209

COSEY’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim

Corporacion De 

Servicios Eductativos 

De Yabucoa 

(“COSEY”)

Objection Deadline: 

November 8, 2022 at 4:00 

p.m. (AST) 

Reply Deadline: November 

15, 2022 at 4:00 p.m. 

Hearing: December 14, 

2022 

[Extension Order, ECF No. 

22549]

 4 The parties below are collectively the “Movants”.

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Remaining Pending Motion:

ECF 

No. Motion Party Status

21192

Plaintiff Blanca Iris 

Marrero’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim

Blanca Iris Marrero Objection filed on August 

26, 2022. [ECF No. 21931].

Reply Deadline: November 

8, 2022 at 4:00 p.m. (AST)

[ECF No. 22679].

5

Hearing: December 14, 

2022 [ECF No. 22679].

Resolved Motions:

ECF 

No. Motion Party Status

21194

Application for Allowance 

and Payment of 

Administrative Expense 

Claims Filed by Group 

Wage Creditors in the 

Litigation Caption Madeline 

Acevedo Camacho v the 

Family Department, ARV 

and AIJ of the 

Commonwealth of Puerto 

Rico

2,819 active or former 

full-time career 

employees at the 

Family Department, 

and its administrations 

who are parties to the 

litigation captioned 

Madeline Acevedo 

Camacho et als v 

Family Department 

the ARV and AIJ; 

CASP Case No. 2016-

05-1340

Denied pursuant to Order 

Denying Motions Requesting 

Allowance and Payment of 

Administrative Expense 

Claims Filed by Wage 

Claimants [ECF No. 22799]. 

21195

Application for Allowance 

of Administrative Priority 

Claims and Requesting an 

Order for Immediate 

Payment Filed by Judgment 

Claimants Case Carmen 

Socoro Cruz Hernandez et 

Certain parties to the 

litigation captioned 

Carmen Socorro Cruz 

Hernandez et als v 

Family Department, 

ARV and AIJ , Case 

No. K AC 1991-0665

Denied pursuant to Order 

Denying Motions Requesting 

Allowance and Payment of 

Administrative Expense 

Claims Filed by Wage 

Claimants [ECF No. 22799].

 5 The Debtors consented to a further extension of Ms. Marrero’s reply deadline to allow the parties to seek a 

consensual resolution. The Debtors understand that Ms. Marrero will be filing a motion to extend her reply 

deadline.

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ECF 

No. Motion Party Status

als v the Family 

Department, ARV and AIJ 

of the Commonwealth of 

Puerto Rico

21207

Orlando Santiago Amador’s 

Motion for Allowance and 

Payment of Administrative 

Expense Claim

Orlando Santiago 

Amador

Withdrawn, with prejudice, 

as consensually resolved. 

[ECF Nos. 21905, 21922].

21208

MCG’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim

MCG and the Able 

Child

Withdrawn, with prejudice, 

as consensually resolved. 

[ECF No. 22151].

21224

Application for Allowance 

of Payment Post Petition 

Administrative Claims 

Pursuant to Section 

503(b)(1)(a)(i) of the 

Bankruptcy Code Filed by 

Group Wage Creditors in 

the Litigation Caption 

Francisco bel Tran Cintron 

et als v. the Family 

Department, ARV and AIJ 

of the Commonwealth of 

Puerto Rico and 

Reservation of Rigths (sic)

Certain parties to the 

litigation captioned 

Francisco BeltranCintron et als. v 

Family Department, 

ARV and AIJ, Case 

No. 2021-05-0345

Denied pursuant to Order 

Denying Motions Requesting 

Allowance and Payment of 

Administrative Expense 

Claims Filed by Wage 

Claimants [ECF No. 22799].

21227

Application for Allowance 

of Administrative Expense 

Priority Payment Pursuant 

to Section 503(b)(1)(a)(i) of 

the Bankruptcy Code Filed 

by Group Wage Creditors in 

the Litigation Caption 

Abraham Gimenez (1,046 

Plaintiff's) v the Department 

of Transportation and 

Public Works and 

Reservation of Rights

1,046 active or former

full-time career 

employees at the 

Department of 

Transportation and 

Public Works

Denied pursuant to Order 

Denying Motions Requesting 

Allowance and Payment of 

Administrative Expense 

Claims Filed by Wage 

Claimants [ECF No. 22799].

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ECF 

No. Motion Party Status

21229

Motion Requesting 

Allowance and Payment of 

Administrative Expense 

Claim Filed by Pablo 

Melani Curra and Diana 

Velez Martinez

Pablo Melani Curra 

and Diana Velez 

Martinez

Denied pursuant to Order 

Denying Motion Requesting 

Allowance and Payment of 

Administrative Expense 

Claim Filed by Pablo Melani 

Curra and Diana Velez 

Martinez [ECF No. 22407].

21230

Application for Allowance 

of Payment of Post Petition 

Administrative Expense 

Priority Claims, Filed by 

the Group in Litigation 

Caption Acevedo Arocho et. 

Als. v the Departamento 

Hacienda and Resevation of 

Rigths (sic)

Certain parties to the 

litigation captioned 

Acevedo Arocho, 

Prudencio et als v. 

Departamento de 

Hacienda, Case No. K 

AC 2003-5022

Denied pursuant to Order 

Denying Motions Requesting 

Allowance and Payment of 

Administrative Expense 

Claims Filed by Wage 

Claimants [ECF No. 22799].

Request for Relief

4. Since the filing of the Administrative Expense Motions, the Oversight Board, 

together with AAFAF’s advisors, continue to review the substance and the validity of the claims 

asserted in the Administrative Expense Motions. This process requires obtaining voluminous 

amounts of background information from the Commonwealth, PBA, and its various agencies and 

departments (collectively, the “Government”). While a number of the Administrative Expense 

Motions have been resolved (either consensually or through Court order), the Oversight Board 

requires additional time to complete the review process with respect to the following 

Administrative Expense Motions (collectively, the “Applicable Motions”, and the parties below 

are collectively the “Applicable Movants”):

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Applicable Motions for Extension Request and Rescheduling Hearing

ECF No. Motion Party

21187 Evertec’s Motion for Allowance of an Administrative 

Expense Claim Evertec

21191

Ricoh Puerto Rico, Inc.’s Motion for Allowance and 

Payment of Administrative Expense Claim in the sum of 

$4,864,017.20

Ricoh

21209 COSEY’s Motion for Allowance and Payment of 

Administrative Expense Claim COSEY

5. Furthermore, such additional time would allow the Oversight Board to work with 

the respective Movants to seek a consensual resolution to the Applicable Motions, if possible, and, 

at a minimum, to narrow any contested issues that may ultimately need to be brought before the 

Court.

6. Accordingly, and with the consent of the Applicable Movants, the Oversight Board 

proposes the following extensions to the deadlines set forth in the Extension Order only for the 

Applicable Motions, docketed at ECF Nos. 21187, 21191, and 21209: 

• The deadline to respond to the Applicable Motions be extended to December 8, 

2022 at 4:00 p.m. (Atlantic Standard Time).

• The deadline for parties to file replies to an opposition, if any, be extended to 

December 15, 2022 at 4:00 p.m. (Atlantic Standard Time).

• The hearing date for the Applicable Motions be rescheduled for February 1, 2023

at 9:30 a.m. AST. 

7. For clarity, the Oversight Board is not seeking an extension of deadlines and the 

rescheduling of the hearing with respect to the following Administrative Expense Motion:

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Extension Not Requested

ECF 

No. Motion Reply Deadline

Hearing 

Date

21192 Plaintiff Blanca Iris Marrero’s Motion for Allowance 

and Payment of Administrative Expense Claim 11/08/20226 12/14/2022

8. Pursuant to Paragraph 1.H of the Sixteenth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 20190-1] (the “Case Management Procedures”), the 

Oversight Board certifies that it has carefully examined the matter and concluded that there is a 

true need for an urgent motion; it has not created the urgency through any lack of due diligence; 

has made a bona fide effort to resolve the issues presented in the Urgent Motion; and has made 

reasonable, good-faith communications in an effort to resolve or narrow the issues that are being 

brought to the Court.

Notice

9. The Oversight Board has provided notice of this motion in accordance with the 

Case Management Procedures to the following parties: (a) the Office of the United States Trustee 

for the District of Puerto Rico; (b) the indenture trustees and/or agents, as applicable, for the 

Debtors’ bonds; (c) the entities on the list of creditors holding the 20 largest unsecured claims 

against the Debtors; (d) counsel to the statutory committees appointed in these Title III cases; (e) 

the Office of the United States Attorney for the District of Puerto Rico; (f) counsel to the Oversight 

Board; (g) the Puerto Rico Department of Justice; (h) the Other Interested Parties;7 (i) the 

 6 See Order Granting Plaintiff Blanca Iris Marrero’s Further Consented Motion for Extension of Time to File Reply 

or Otherwise Inform Agreement with Debtors [ECF No. 22679]. 

7 The “Other Interested Parties” include the following: (i) counsel to certain of the insurers and trustees of the bonds 

issued or guaranteed by the Debtors; and (ii) counsel to certain ad hoc groups of holders of bonds issued or 

guaranteed by the Debtors. 

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Applicable Movants; and (j) all parties filing a notice of appearance in these Title III cases. A copy 

of the motion is also available at https://cases.ra.kroll.com/puertorico/. 

10. The Oversight Board submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

WHEREFORE the Debtors request the Court enter the Proposed Order and grant such 

other relief as is just and proper. 

Dated: November 7, 2022

 San Juan, Puerto Rico

PROSKAUER ROSE LLP

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice) 

Brian S. Rosen (pro hac vice) 

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

-and-

/s/ Luis F. del Valle-Emmanuelli

Luis F. del Valle-Emmanuelli 

USDC-PR No. 209514

P.O. Box 79897

Carolina, Puerto Rico 00984-9897 

Tel: (787) 647-3503

OF COUNSEL FOR

A&S LEGAL STUDIO, PSC

434 Avenida Hostos San Juan, PR 00918

Tel: (787) 751-6764 / 763-0565

Fax: (787) 763-8260

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

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Exhibit A

Proposed Order

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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

Re: ECF No. _____

(Jointly Administered)

ORDER GRANTING URGENT

CONSENSUAL MOTION FOR FURTHER EXTENSION OF

RESPONSE DEADLINES AND RESCHEDULING OF HEARING DATE

Through the Urgent Consensual Motion for Further Extension of Response Deadlines and 

Rescheduling of Hearing Date, dated November 7, 2022 (Docket Entry No. _____)

2 (the 

“Extension Motion”),3 the Oversight Board requests the extension of briefing deadlines and the 

 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); (v) Puerto Rico Electric 

Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of 

Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Last Four 

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case 

No. 19-BK-5523-LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to 

software limitations).

2 All docket entry references are to entries in Case No. 17-3283, unless otherwise specified.

3 Capitalized terms used but not otherwise defined herein have the meanings given to them in 

the Extension Motion.

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rescheduling of the hearing with respect to certain, but not all, of the Administrative Expense 

Motions with respect to which briefing deadlines were previously extended and a hearing was 

scheduled by the Order Granting Urgent Consensual Motion for Further Extension of Response 

Deadlines and Rescheduling of Hearing Date (Docket Entry No. 22544). For the sake of clarity, 

extensions of the briefing schedules and adjournments have been requested with respect to the 

following Administrative Expense Motions (the “Applicable Motions” and the movants thereto, 

the “Applicable Movants”):

Docket 

Entry No.

The Applicable Motions (Extension Requested by Docket Entry No. 

_____)

21187 Evertec’s Motion for Allowance of an Administrative Expense Claim4

21191 Ricoh Puerto Rico, Inc.’s Motion for Allowance and Payment of Administrative 

Expense Claim in the sum of $4,864,017.20

21209 COSEY’s Motion for Allowance and Payment of Administrative Expense Claim

Extensions and adjournments have not been requested with respect to the following 

Administrative Expense Motion: 

Docket 

Entry No. Extension Not Requested by Docket Entry No. _____

21192 Plaintiff Blanca Iris Marrero’s Motion for Allowance and Payment of 

Administrative Expense Claim

Accordingly, the Court having found that the Oversight Board provided adequate and 

appropriate notice of the Extension Motion under the circumstances and that no other or further 

notice is required; and the Court having reviewed the Extension Motion; and the Court having 

determined that the factual bases set forth in the Extension Motion establish just cause for the relief 

 4 Docket Entry No. 317 in Case No. 19-5523.

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granted herein; and after due deliberation and sufficient cause appearing therefor, it is hereby

ORDERED that:

1. The Extension Motion is granted as set forth herein.

2. The deadline to respond to the Applicable Motions shall be extended to 

December 8, 2022 at 4:00 p.m. (Atlantic Standard Time).

3. The deadline for the Applicable Movants to file a reply shall be extended to 

December 15, 2022 at 4:00 p.m. (Atlantic Standard Time).

4. The Applicable Motions will be heard in connection with the omnibus hearing 

scheduled for February 1, 2023.

5. This Order resolves Docket Entry No. _____ in Case No. 17-3283.

SO ORDERED.

Dated: November ___, 2022

 

LAURA TAYLOR SWAIN

United States District Judge

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