IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

IN RE: THE FINANCIAL OVERSIGHT 

AND MANAGEMENT BOARD FOR 

PUERTO RICO

AS A REPRESENTATIVE OF THE 

COMMONWEALTH OF PUERTO RICO 

CIVIL NO. 17-3283 (LTS)

TITLE III PROMESA 

URGENT MOTION REQUESTING EXTENSION OF TIME TO FILE A RESPONSE TO 

THE MOTION FOR RELIEF OF STAY

TO THE HONORABLE COURT: 

COMES NOW the State Insurance Fund Corporation (hereinafter, “SIFC”), the Defendant in

the matter of GARCÍA COLÓN V. STATE INSURANCE FUND CORPORATION, Civil No. 21-cv-01211 

(RAM) before the United District Court for the District of Puerto Rico, through its undersigned 

counsel, and very respectfully alleges, requests, and prays: 

1. On October 4, 2022, Keila García Colón (hereinafter, “Movant”) filed the MOTION FOR 

RELIEF FROM STAY (hereinafter, “MOTION FOR RELIEF”) [Docket No. 22501]. 

2. This Honorable Court set October 18, 2022, as the deadline for the SIFC to respond to 

said MOTION FOR RELIEF [Docket No. 22502]. 

3. Currently, the undersigned are in the process of preparing for trial. The trial is set to 

commence on October 26, 2022, and is scheduled to end on October 28, 2022, for Civ. Case 

Number 2018CV00967, at the Court of First Instance, Arecibo Region. 

4. On October 12, 2022, the SIFC file a MOTION REQUESTING EXTENSION OF TIME, until 

November 4, 2022, to file a Response to the MOTION FOR RELIEF. [Docket No. 22586]. 

Case:17-03283-LTS Doc#:22618 Filed:10/17/22 Entered:10/17/22 14:05:25 Desc: Main

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IN RE: THE FINANCIAL OVERSIGHTAND BOARD FOR PUERTO RICO

AS A REPRESENTANTIVE OF THE COMMONWEALTH OF PUERTO RICO. 

CIVIL NO. 17-3283 (LTS)

MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE TO THE MOTION FOR RELIEF TO STAY.

PAGE 2

5. On October 13, 2022, this Honorable Court DENIED the SIFC’s motion requesting

extension of time for failure to file pursuant to Case Management and Administrative Procedures 

(hereinafter, “Case Management Order”) on Docket No. 20190. [Docket No. 22604]. 

6. In compliance with the Order issued on October 13, 2022, the undersigned in good-faith 

communicated on that same date with the Movant through their legal representation, attorney 

Juan R. González-Muñoz, requesting extension of time to answer the MOTION FOR RELIEF.

7. The Movant has expressed no objection to the request of extension of time given the

circumstances. Her only petition is for the Court to allow the time for reply to be extended by the 

same amount of time granted in the original Order [Docket No. 22502], or until November 11, 

2022.

8. Similarly, the SIFC exchanged email communications with the legal representatives of 

the Commonwealth, and they also expressed no objection to the time extension request.

9. In light of the above, the undersigned requests an extension of time, until November 4, 

2022, to file a Response to the MOTION FOR RELIEF, as discussed with the Plaintiff and the

representatives of the Commonwealth.

10. In pursuant to the Case Management Order [Docket No. 20190], the undersigned 

accompanies this Motion with a Proposed Order. See Exhibit 2 of this Motion. 

11. The extension of time requested will not cause any undue delay or prejudice to the 

Plaintiffs. 

12. Pursuant to Paragraph I.H of the Case Management Order [Docket No. 20190], the 

undersigned hereby certifies that after a thorough review there is a definite need for an urgent 

motion; this petition is made without the absence of due diligence, after righteous efforts and 

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IN RE: THE FINANCIAL OVERSIGHTAND BOARD FOR PUERTO RICO

AS A REPRESENTANTIVE OF THE COMMONWEALTH OF PUERTO RICO. 

CIVIL NO. 17-3283 (LTS)

MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE TO THE MOTION FOR RELIEF TO STAY.

PAGE 3

good faith communications with Movant’s legal counsel and the representatives of the 

Commonwealth to resolve or narrow the issues that are being brought to the court. 

 WHEREFORE, it is respectfully requested that this Honorable Court take notice of the 

forgoing and grant until November 4, 2022, for the SIFC to file a Response to the MOTION FOR 

RELIEF; and grant allow the time for the Movant’s reply to be extended by the same amount of 

time granted in the original Order or until November 11, 2022. 

 IT IS HEREBY CERTIFIED that the foregoing Motion for Extension of Time was 

electronically filed with the Clerk of the Court using the CM/ECF system, which will send 

notification of such filing to all counsel of record participating in the same.

 RESPECTFULLY SUBMITTED in San Juan, Puerto Rico, on October 17, 2022.

 WEINSTEIN-BACAL, MILLER & VEGA, P.S.C.

 González Padín Building-Penthouse

 154 Rafael Cordero Street, Plaza de Armas 

 Old San Juan, Puerto Rico 00901

 Telephone: (787) 977-2550 

 Telecopier: (787) 977-2559

 E-mail: pwm@wbmvlaw.com

 moa@wbmvlaw.com

 S/Peter W. Miller

U.S.D.C. No. 213609 

 S/Myriam C. Ocasio-Arana 

 U.S.D.C. No. 228111 

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