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. 19525, 19760

(Jointly Administered)

THIRD URGENT CONSENTED 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 Commonwealth of Puerto Rico (the “Commonwealth”), pursuant to the authority granted to 

it under the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, 

respectfully submits this urgent consented 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 Granting Urgent Consented Motion for Extension of Deadlines

[ECF No. 19760] (the “Amended 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-BK3567-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 the Commonwealth’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 the Commonwealth.

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Request for Relief

1. On December 15, 2021, Juan Manuel Cruzado-Laureano (“Movant”) filed a motion 

titled Inquire About the Commonwealth of PR Agencies Covered by the PROMESA “Stay” [ECF 

No. 18404] (the “Motion”), requesting that this Court “give its Opinion on whether the automatic 

stay of PROMESA applies to any economic responsibility of the Office of the Comptroller of 

Puerto Rico” in connection with a case filed by Movant against the Office of the Comptroller of 

Puerto Rico, which is currently pending before the United States Court of Appeals for the First 

Circuit under Case No. 21-1472. See Motion at 8. 

2. On January 13, 2022, the Court entered the Amended Scheduling Order which 

provides that responses to the Motion must be filed by January 24, 2022 and Movant’s reply by 

January 31, 2022. 

3. Since the filing of the Motion, the Commonwealth worked diligently to gather the 

necessary information in order to properly assess the Motion and attempted to seek a consensual 

resolution of the same with Movant. Unfortunately, after discussing the matters set forth in the 

Motion, the parties could not reach an agreement and the Commonwealth requires additional time 

to finalize its response thereto. 

4. Accordingly, the Commonwealth, with Movant’s consent, proposes the following 

extensions of the deadlines set forth in the Amended Scheduling Order: 

• The deadline to respond to the Motion shall be extended to January 31, 2022. 

• The deadline for Movant to file a reply to a response shall be extended to February 7, 

2022.

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

that a hearing is necessary.

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5. Pursuant to Paragraph I.H of the Fifteenth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 17127-1] (the “Case Management Procedures”), the 

Commonwealth hereby certifiesthat 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, goodfaith communications in an effort to resolve or narrow the issues that are being brought to the 

Court, and no party opposes the relief requested herein.

Notice

6. The Commonwealth 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 the Commonwealth’s case 

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

7. The Commonwealth submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

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WHEREFORE, the Commonwealth requests the Court enter the Proposed Order and 

grant such other relief as is just and proper. 

Dated: January 24, 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

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Exhibit A

Proposed Order

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