Case No. 17 BK-3283-LTS/Ramhil Developers, Inc./Contract No. 2011-0002444

From <elrc@rclopr.com>

To <Hermann.Bauer@oneillborges.com>

Cc <lstafford@proskauer.com>

Bcc 'Lisandra Navarro' <lnr@rclopr.com>, 'Lisandra Navarro' <lisandra359@gmail.com>, <elrc@rclopr.com>

Date 2021-12-27 11:29

 letter h.bauer re ramhil-12-27-2021(Final).pdf(~168 KB)

Hemann:

As discussed earlier today, please see the attached let

Edgardo L. Rodríguez-Cardé, Esq, JD, LLM, PE, BSChE

PO Box 365061

San Juan, PR 00936-5061

Telefono: 787-772-9911

Fax: 787-281-7816

Email: elrc@rclopr.com

---CONFIDENTIALITY NOTE: This communication contains information belonging to the suscriber, which is confidential and/or legally privileged. The information i

only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distributio

taking of any action in reliance on the contents of said information is strictly prohibited. If you have received this communication by error, please delete it fro

computer and notify us immediate

Case:17-03283-LTS Doc#:19807-3 Filed:01/18/22 Entered:01/18/22 13:06:57 Desc:

Exhibit Exhibit 3 FOMB Authorization to file objection Page 1 of 6
RCRODRIGUEZ-CARDÉ LAW OFFICES, P.S.C.

416 Ponce De León Avenue/Union Plaza/Suite 1503/ San Juan, P.R. 00918

Phone (787) 772-9911 / Fax ( 787) 281-7816/ Email: elrc@prtc.net

Via email: Hermann.bauer@oneillborges.com

Hermann Bauer

O'Neill & Borges LLC

250 Muñoz Rivera Avenue

Suite 800

San Juan, PR 00918-1813

RE: PROMESA Title III

 Case No. 17 BK-3283-LTS

 Ramhil Developers, Inc.

 Contract No.: 2011-000244

Dear Mr. Bauer:

We write on behalf of Ramhil Developers, Inc. ("Ramhil")

concerning the lease agreement between Ramhil and the Office of 

Courts Administration of Puerto Rico (the "OCA") for the Caguas 

Judicial Center, identified as Contract No. 2011-000244 (the

"Contract").

Recently, after December 13, 2021, Ramhil became aware of a

document entitled Notice of Executory Contracts and Unexpired 

Leases to be Assumed Pursuant to the Tittle III Plan of 

Adjustment, dated November 23, 2021 (the "Notice").1 Through the 

Notice, Ramhil is advised of the proposed cure costs under the 

Contract as well as its right to file a written objection

regarding the proposed cure costs and/or the assumption of the 

Contract. The term provided to file objections was set to 

December 13, 2021.

The Notice was sent to an address that does not belong to 

Ramhil. Ramhil's postal address is PO BOX 7186, Caguas, PR. 

00726. However, as you can realize from the document included as 

Annex 1, the Notice was sent to PO Box 491, Caguas, PR 00726-

0491 (the "Wrong Address"). Likewise, the Wrong Address arises 

from the Schedule included as part of the Notice.2 We conducted a 

1 Case No. 17 BK-3283-LTS, Doc# 19,353.

2 See Id., Schedule, pg. 25, row 11.

Case:17-03283-LTS Doc#:19807-3 Filed:01/18/22 Entered:01/18/22 13:06:57 Desc:

Exhibit Exhibit 3 FOMB Authorization to file objection Page 2 of 6
Matter: Contract No. 2011-000244

Ramhil Developers, Inc.

Page 2

preliminary search, and it appears that the Wrong Address 

belongs to the OCA itself. For reasons unknown to Ramhil, the 

Notice was placed in its mailbox after December 13, 2021.

Ramhil intends to exercise its right to properly respond to the 

Notice in accordance with the applicable provisions of PROMESA, 

the Bankruptcy Code, the Bankruptcy Rules, the Local Bankruptcy 

Rules, and the orders governing the administration of the 

referenced Title III Case. Therefore, considering the 

circumstances described above, we deem appropriate that the 

Notice be re-sent and a reasonable period to respond be granted.

We present this communication in accordance with the Bankruptcy 

Rules, Local Bankruptcy Rules and the orders governing the 

administration of the referenced Title III Case, to reach a 

solution to his matter before requesting the Court's 

intervention. Given the circumstances, we would appreciate your 

prompt response to his matter.

Cordially,

f/ Edgardo L. Rodríguez Cardé

Edgardo L. Rodríguez Cardé

Case:17-03283-LTS Doc#:19807-3 Filed:01/18/22 Entered:01/18/22 13:06:57 Desc:

Exhibit Exhibit 3 FOMB Authorization to file objection Page 3 of 6
Annex 1

Case:17-03283-LTS Doc#:19807-3 Filed:01/18/22 Entered:01/18/22 13:06:57 Desc:

Exhibit Exhibit 3 FOMB Authorization to file objection Page 4 of 6
RE: Case No. 17 BK-3283-LTS/Ramhil Developers, Inc./Contract No. 2011-0002444

From <elrc@rclopr.com>

To <Hermann.Bauer@oneillborges.com>

Cc <lstafford@proskauer.com>

Bcc 'Lisandra Navarro' <lnr@rclopr.com>, 'Lisandra Navarro' <lisandra359@gmail.com>, <elrc@rclopr.com>

Date 2021-12-28 05:50

Herman/Laura:

Please note that although the letter attached to the email sent yesterday does not include a date it was issued by the subscriber yesterday (December 27, 20

Regards,

Edgardo L. Rodríguez-Cardé, Esq, JD, LLM, PE, BSChE

PO Box 365061

San Juan, PR 00936-5061

Telefono: 787-772-9911

Fax: 787-281-7816

Email: elrc@rclopr.com

---CONFIDENTIALITY NOTE: This communication contains information belonging to the suscriber, which is confidential and/or legally privileged. The information i

only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distributio

taking of any action in reliance on the contents of said information is strictly prohibited. If you have received this communication by error, please delete it fro

computer and notify us immediate

From: elrc@rclopr.com <elrc@rclopr.com>

Sent: Monday, December 27, 2021 3:30 PM

To: 'Hermann.Bauer@oneillborges.com' <Hermann.Bauer@oneillborges.com>

Cc: 'lstafford@proskauer.com' <lstafford@proskauer.

Subject: Case No. 17 BK-3283-LTS/Ramhil Developers, Inc./Contract No. 2011-0002444

Hemann:

As discussed earlier today, please see the attached let

Edgardo L. Rodríguez-Cardé, Esq, JD, LLM, PE, BSChE

PO Box 365061

San Juan, PR 00936-5061

Telefono: 787-772-9911

Fax: 787-281-7816

Email: elrc@rclopr.com

---CONFIDENTIALITY NOTE: This communication contains information belonging to the suscriber, which is confidential and/or legally privileged. The information i

only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distributio

taking of any action in reliance on the contents of said information is strictly prohibited. If you have received this communication by error, please delete it fro

computer and notify us immediate

Case:17-03283-LTS Doc#:19807-3 Filed:01/18/22 Entered:01/18/22 13:06:57 Desc:

Exhibit Exhibit 3 FOMB Authorization to file objection Page 5 of 6
Re: Case No. 17 BK-3283-LTS/Ramhil Developers, Inc./Contract No. 2011-0002444

From Hermann Bauer <Hermann.Bauer@oneillborges.com>

To elrc@rclopr.com <elrc@rclopr.com>

Cc lstafford@proskauer.com <lstafford@proskauer.com>

Date 2021-12-28 13:56

Saludos, Edgardo.

This confirms that we are in agreement to extend the deadline for Ramhil to respond to the Notice of Assumption until January 1

I wish Yarymar and you a very Happy and Prosperous 2022!

Abrazo,

Hermann

From: elrc@rclopr.com <elrc@rclopr.com>

Sent: Tuesday, December 28, 2021 9:50 AM

To: Hermann Bauer <Hermann.Bauer@oneillborges.com>

Cc: lstafford@proskauer.com <lstafford@proskauer.

Subject: RE: Case No. 17 BK-3283-LTS/Ramhil Developers, Inc./Contract No. 2011-0002444

Herman/Laura:

Please note that although the letter attached to the email sent yesterday does not include a date it was issued by the subscriber yesterday (December 27, 20

Regards,

Edgardo L. Rodríguez-Cardé, Esq, JD, LLM, PE, BSChE

PO Box 365061

San Juan, PR 00936-5061

Telefono: 787-772-9911

Fax: 787-281-7816

Email: elrc@rclopr.com

---CONFIDENTIALITY NOTE: This communication contains information belonging to the suscriber, which is confidential and/or legally privileged. The information i

only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distributio

taking of any action in reliance on the contents of said information is strictly prohibited. If you have received this communication by error, please delete it fro

computer and notify us immediate

From: elrc@rclopr.com <elrc@rclopr.com>

Sent: Monday, December 27, 2021 3:30 PM

To: 'Hermann.Bauer@oneillborges.com' <Hermann.Bauer@oneillborges.com>

Cc: 'lstafford@proskauer.com' <lstafford@proskauer.

Subject: Case No. 17 BK-3283-LTS/Ramhil Developers, Inc./Contract No. 2011-0002444

Hemann:

As discussed earlier today, please see the attached let

Edgardo L. Rodríguez-Cardé, Esq, JD, LLM, PE, BSChE

PO Box 365061

San Juan, PR 00936-5061

Telefono: 787-772-9911

Fax: 787-281-7816

Email: elrc@rclopr.com

---CONFIDENTIALITY NOTE: This communication contains information belonging to the suscriber, which is confidential and/or legally privileged. The information i

only for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distributio

taking of any action in reliance on the contents of said information is strictly prohibited. If you have received this communication by error, please delete it fro

computer and notify us immediate

Case:17-03283-LTS Doc#:19807-3 Filed:01/18/22 Entered:01/18/22 13:06:57 Desc:

Exhibit Exhibit 3 FOMB Authorization to file objection Page 6 of 6