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. 22416

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY,

Debtor.

PROMESA

Title III

No. 17 BK 3567-LTS

Re: ECF Nos. 1411, 1412

URGENT MOTION FOR EXTENSION OF DEADLINES

To the Honorable United States District Judge Laura Taylor Swain:

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).

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

of the Puerto Rico Highways and Transportation Authority (“HTA”), 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 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. 1412] 

(the “Scheduling Order”).2

Request for Relief

1. On September 30, 2022, Carlos E. Iturregui Margarida, Pedro J. Iturregui 

Margarida, Ana I. Iturregui Margarida, José A. Iturregui Margarida, Isabelita A. Iturregui, Ana 

Isabel Iturregui Álvarez, Dayren R. Iturregui Álvarez (collectively, “Movants”) filed a Motion for 

Relief from Stay [ECF No. 1411] (the “Motion”), requesting this Court grant Movants “relief from 

the automatic stay of 11 U.S.C. § 362(a)(1) for movants to proceed with civil rights violations and 

inverse condemnation proceedings against HTA in Federal Court for the taking of movants’ 

property without compensation,” in connection with a case filed by Movants in the United States 

District Court for the District of Puerto Rico (the “District Court”) under Civil Case no. 22-cv01227 (RAM). See Motion at 7. 

2. On the same day, the Court entered the Scheduling Order, which provides that 

responses to the Motion must be filed by October 14, 2022, and Movants’ reply by October 21, 

2022.

2

 The Financial Oversight and Management Board for Puerto Rico, as HTA’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 HTA.

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3. Since the filing of the Motion, HTA has been expeditiously working to gather the 

necessary information to properly evaluate the allegations included in the Motion in order to 

properly respond to same. Nevertheless, HTA needs additional time to complete this process. HTA 

reached out to Movants regarding a two-week proposed extension, but Movants did not consent to 

the same. Accordingly, HTA proposes the following brief extensions of the deadlines set forth in 

the Scheduling Order: 

• The deadline to respond to the Motion shall be extended to October 19, 2022. 

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

October 26, 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”), the 

Commonwealth 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 and has made reasonable, goodfaith communications in an effort to resolve or narrow the issues that are being brought to the 

Court.

Notice

5. HTA 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; 

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(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) Movants. A copy of the motion is also available on HTA’s case website at 

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

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

notice need be given. 

WHEREFORE HTA requests the Court enter the Proposed Order and grant such other 

relief as is just and proper. 

Dated: October 14, 2022

San Juan, Puerto Rico 

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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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