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. 21790

(Jointly Administered) 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al., 

Movants,

-againstRAMHIL DEVELOPERS, INC.,

Respondent.

NINTH URGENT CONSENSUAL MOTION FOR

EXTENSION OF DEADLINES AND ADJOURNMENT OF HEARING

 

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 Building Authority (“PBA”) (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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To the Honorable United States District Court Judge Laura Taylor Swain:

The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), 

as sole Title III representative of the Commonwealth of Puerto Rico (the “Commonwealth”), the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”), 

and the Puerto Rico Public Buildings Authority (“PBA” and, collectively with the Commonwealth 

and ERS, the “Debtors”), pursuant to section 315(b) of the Puerto Rico Oversight, Management, 

and Economic Stability Act (“PROMESA”),2respectfully submits this ninth urgent consensual 

motion for entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed 

Order”), extending the deadlines and adjourning the hearing scheduled in the Order Granting the 

Eighth Urgent Consensual Motion for Extension of Deadlines and Adjournment of Hearing [Case 

No. 17-3283, ECF No. 22179]

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(the “Extension Order”) and states as follows:

Request for Relief

1. On November 21, 2021, the Oversight Board filed the Second Amended Plan 

Supplement and Plan Related Documents of the Commonwealth of Puerto Rico, et al. [ECF No. 

19326] (the “Second Amended Plan Supplement”).4 Attached to the Second Amended Plan 

Supplement as Exhibit E is a schedule of Executory Contracts and Unexpired Leases (the 

“Schedule”). Pursuant to Section 76.1 of the Plan, the Debtors intend to assume, as of the Effective 

Date of the Plan, the Executory Contracts and Unexpired Leases listed in the Schedule.

 

2 PROMESA is codified at 48 U.S.C. §§ 2101-2241.

3 Unless otherwise stated, all ECF Nos. shall refer to the docket in Case No. 17-3283.

4 All capitalized terms used but not otherwise defined herein shall have the meanings given to them in the Modified 

Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, et al., dated January 14, 

2022 [ECF No. 19784] (as may be amended, modified, or supplemented, the “Plan”) or the Original Notice (as 

defined below), as applicable.

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2. On November 23, 2021, the Oversight Board filed the Notice of Executory 

Contracts and Unexpired Leases to be Assumed Pursuant to Title III Plan of Adjustment [Case 

No. 17-BK-3283-LTS, ECF No. 19353; Case No. 19-BK-05523-LTS, ECF No. 244; Case No. 17-

BK-03566-LTS, ECF No. 1272].

3. On January 18, 2022, Ramhil Developers, Inc. (“Ramhil”) filed Ramhil Developers 

Inc.’s Objection to Docket No. 19353 and Informing Cure Amounts for Executory Contracts or 

Unexpired Leases To Be Assumed Pursuant to Title III Plan of Adjustment [ECF No. 19807] (the 

“Ramhil Objection”).

4. Pursuant to the Extension Order, the deadline to file replies to the Ramhil Objection 

is October 26, 2022, at 4:00 p.m. (Atlantic Standard Time) (the “Reply Deadline”), and the Ramhil 

Objection will be heard at the November 2, 2022 omnibus hearing (the “Hearing”). 

5. The Oversight Board is continuing to finalize its consensual resolution with respect 

to the Ramhil Objection. Accordingly, the Oversight Board respectfully requests (a) an extension 

of the Reply Deadline from October 26, 2022 to December 7, 2022 at 4:00 p.m. (Atlantic 

Standard Time), and (b) adjournment of the Hearing to consider the Ramhil Objection from 

November 2, 2022 to the December 14, 2022 omnibus hearing. 

6. Pursuant to Paragraph 1.H of the Sixteenth Amended Notice, Case Management and 

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

Oversight Board 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; has made reasonable, good-faith communications 

in an effort to resolve or narrow the issues that are being brought to the Court, and Ramhil consents

to the relief requested herein. 

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Notice

7. The Oversight Board 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 the Commonwealth; (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) the Other Interested Parties;5

(i) all parties filing a notice of appearance in these Title III cases; and (j) Ramhil. A copy of the 

motion is also available at https://cases.ra.kroll.com/puertorico/. 

8. The Oversight Board submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

WHEREFORE the Oversight Board requests the Court enter the Proposed Order and 

grant such other relief as is just and proper. 

[Remainder of Page Left Intentionally Blank]

 

5 The “Other Interested Parties” include the following: (i) counsel to certain of the insurers and trustees of the bonds 

issued or guaranteed by the Debtors; and (ii) counsel to certain ad hoc groups of holders of bonds issued or 

guaranteed by the Debtors. 

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Dated: October 25, 2022

San Juan, Puerto Rico

Respectfully submitted,

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice)

Brian S. Rosen (pro hac vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

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Exhibit A

Proposed Order

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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 

(Jointly Administered) 

ORDER GRANTING THE NINTH

URGENT CONSENSUAL MOTION FOR 

EXTENSION OF DEADLINES AND ADJOURNMENT OF HEARING

Upon the Ninth Urgent Consensual Motion for Extension of Deadlines and Adjournment of 

Hearing (ECF No. _____, the “Ninth Extension Motion”);2and the Court having found that the 

relief requested in the Ninth Extension Motion is in the best interests of the Oversight Board and 

Ramhil; and the Court having found that the Oversight Board provided adequate and appropriate 

notice of the Ninth Extension Motion under the circumstances and that no other or further notice 

is required; and the Court having reviewed the Ninth Extension Motion; and the Court having 

determined that the factual bases set forth in the Ninth Extension Motion establish just cause for 

 

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 Building Authority (“PBA”) (Bankruptcy 

Case No. 19-BK-5523-LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to software 

limitations).

2 Capitalized terms used but not otherwise defined herein have the meanings given to them in the Ninth Extension 

Motion.

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the relief granted herein; and after due deliberation and sufficient cause appearing therefor, it is 

HEREBY ORDERED THAT:

1. The Ninth Extension Motion is granted as set forth herein.

2. Replies to the Ramhil Objection, if any, must be filed by December 7, 2022, at 

4:00 p.m. (Atlantic Standard Time). 

3. The Ramhil Objection will be heard at the December 14, 2022 omnibus hearing. 

4. This Order resolves Docket Entry No. _____ in Case No. 17-3283. 

SO ORDERED.

Dated: October _____, 2022

 

LAURA TAYLOR SWAIN

United States District Judge

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