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 Nos. 22383, 22388

(Jointly Administered)

URGENT CONSENSUAL MOTION FOR EXTENSION OF DEADLINES

To the Honorable United States District Judge Laura Taylor Swain:

The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”), on behalf

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

(“ERS”), respectfully submits this urgent consensual motion (the “Urgent Motion”) for entry of 

an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), extending 

the deadlines set forth in the Order Scheduling Briefing of Motion for Relief from Stay [ECF No. 

22388] (the “Scheduling Order”).2

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”) (Bankruptcy Case 

No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as Bankruptcy 

Case numbers due to software limitations).

2

 The Financial Oversight and Management Board for Puerto Rico, as ERS’s representative pursuant to section 315(b) 

of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), has authorized AAFAF to 

file this Urgent Motion on behalf of ERS.

Case:17-03283-LTS Doc#:22554 Filed:10/07/22 Entered:10/07/22 15:21:48 Desc: Main

Document Page 1 of 5
Request for Relief

1. On September 24, 2022, César Caminero Ramos (“Movant”) filed a Motion for 

Relief from Stay [ECF No. 22383] (the “Motion”), seeking relief from the automatic stay to 

liquidate his asserted claim against ERS in action captioned César E. Caminero Ramos v. DTOP, 

under Civil Case No. 2016-0059. See Motion at ¶¶ 5-8. 

2. On September 26, 2022, the Court entered the Scheduling Order, which provides 

that responses to the Motion must be filed by October 7, 2022, and Movant’s reply by October 14, 

2022. 

3. ERS is still in the process of gathering the information in connection with the 

Motion to determine whether a consensual resolution is possible. Accordingly, ERS, with 

Movant’s consent, proposes the following extensions of the deadlines set forth in the Scheduling 

Order: 

• The deadline to respond to the Motion shall be extended to October 28, 2022. 

• The deadline for Movants to file a reply to a response, if any, shall be extended to

November 4, 2022.

• The Court will thereafter take the Motion on submission, unless the Court determines 

that a hearing is necessary.

4. Pursuant to Paragraph I.H of the Sixteenth Amended Notice, Case Management and 

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

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 matter without a hearing; has made reasonable, good-faith 

Case:17-03283-LTS Doc#:22554 Filed:10/07/22 Entered:10/07/22 15:21:48 Desc: Main

Document Page 2 of 5
communications in an effort to resolve or narrow the issues that are being brought to the Court, 

and Movant consents to the request in this Urgent Motion.

Notice

5. ERS 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 COFINA; 

(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) all parties filing a notice of appearance in these Title III

cases; and (i) Movant. A copy of the motion is also available on ERS’s case website at 

https://cases.primeclerk.com/puertorico/.

6. ERS submits that, in light of the nature of the relief requested, no other or further 

notice need be given. 

[Remainder of Page Left Intentionally Blank]

Case:17-03283-LTS Doc#:22554 Filed:10/07/22 Entered:10/07/22 15:21:48 Desc: Main

Document Page 3 of 5
WHEREFORE ERS requests the Court enter the Proposed Order and grant such other 

relief as is just and proper. 

Dated: October 7, 2022

San Juan, Puerto Rico 

Respectfully submitted, 

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Email: lmarini@mpmlawpr.com

/s/ Carolina Velaz-Rivero

Carolina Velaz-Rivero

USDC No. 300913

Email: cvelaz@mpmlawpr.com

MARINI PIETRANTONI MUÑIZ LLC

250 Ponce de León Ave.

Suite 900

San Juan, Puerto Rico 00918

Tel: (787) 705-2171

Fax: (787) 936-7494

Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

Case:17-03283-LTS Doc#:22554 Filed:10/07/22 Entered:10/07/22 15:21:48 Desc: Main

Document Page 4 of 5
Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:22554 Filed:10/07/22 Entered:10/07/22 15:21:48 Desc: Main

Document Page 5 of 5