Hearing Date: February 7, 2018, 9:30 a.m. (Atlantic Standard Time) 

Objection Deadline: January 23 , 2018, 4:00 p.m. (Atlantic Standard Time) 

UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO 

-------------------------------------------------------------x 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

THE COMMONWEALTH OF PUERTO RICO, et 

al., 

 Debtors.1

-------------------------------------------------------------x 

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

THE COMMONWEALTH OF PUERTO RICO,

 Debtor. 

-------------------------------------------------------------x 

PROMESA 

Title III 

No. 17 BK 3283-LTS 

NOTICE OF MOTION 

PLEASE TAKE NOTICE, that the American Federation of State, County and 

Municipal Employees International Union, AFL-CIO (“AFSCME”) and the American 

Federation of Teachers, AFL-CIO (“AFT”), International Union, on behalf of themselves, their 

local affiliates in Puerto Rico and their members (collectively, the “Unions” or “CBA 

Counterparties”), through their undersigned counsel, will move this Court before the Honorable 

Laura Taylor Swain, United States District Judge, at the United States District Court for the 

District of Puerto Rico, José V. Toledo Federal Building and United States Courthouse, 300 

 

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 (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); 

(iii) Puerto Rico Highways and Transportation Authority (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 (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); and (v) Puerto Rico 

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 

3747) (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations). 

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Recinto Sur Street, San Juan, PR 00901, on February 7, 2018 at 9:30 a.m. Atlantic Standard 

Time, or as soon thereafter as counsel may be heard, for an Order pursuant to 11 U.S.C. §§ 105 

and 362 with respect to the processing through resolution of employment arbitration and 

grievance proceedings and granting such other relief as the Court deems proper and just.

 PLEASE TAKE FURTHER NOTICE that any responses or objections to the Motion

shall (i) be made in writing; (ii) conform to the Bankruptcy Rules and the Local Rules for the 

United States District Court for the District of Puerto Rico; (iii) set forth the basis for the 

objections and the specific grounds therefor; (iv) be filed with this Court with copies to the 

chambers of the Honorable Laura Taylor Swain, together with proof of service thereof; and (v) 

be served in a manner as to be received by the undersigned counsel by 4:00 p.m. Atlantic 

Standard Time seven (7) days prior to the hearing date. 

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Dated: January 16, 2018 /s/ Curtis C. Mechling 

Curtis C. Mechling (USDC CM5957) 

Sherry J. Millman (USDC CM6105) 

Stroock & Stroock & Lavan LLP 

180 Maiden Lane, New York, NY 10038 

(212) 806-5434 

cmechling@stroock.com 

smillman@stroock.com 

and 

/s/ José Luis Barrios-Ramos 

José Luis Barrios-Ramos (USDC 223611) 

McLeary Ave., Suite #303 

San Juan, Puerto Rico 00936-8006 

(787) 593-6641 

Barrios.jl@outlook.com

For American Federation of Teachers, 

AFL-CIO, as authorized agent for the 

Asociación de Maestros de Puerto 

Rico-Local Sindical

/s/ Sharon L. Levine 

Sharon L. Levine 

Dipesh Patel 

Saul Ewing LLP 

1037 Raymond Blvd. 

Suite 1520 

Newark, NJ 07102 

(973) 286-6713 

slevine@saul.com

and 

Judith Rivlin 

Teague P. Paterson 

Matthew S. Blumin 

American Federation of State, County and 

Municipal Employees 

1101 17th Street NW, Suite 900 

Washington, DC 20011 

(202) 775-5900 

For the American Federation of State, 

County and Municipal Employees

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CERTIFICATE OF SERVICE 

 I hereby certify that on this 16th day of January, 2018, I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF System, which will notify all counsel of record 

and caused to be mailed or emailed a copy, as provided in the Court-approved Case Management 

Procedures in this case. 

Dated: January 16, 2018 

 /s/José Luis Barrios-Ramos 

 José Luis Barrios-Ramos 

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