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)

NORTH SIGHT COMMUNICATIONS, INC.

v.

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

COMMONWEALTH OF PUERTO RICO,

Debtor.

PROMESA 

Title III 

This filing relates only to the 

Commonwealth and shall only be 

filed in Case No. 17-3283.

Re: ECF No. 23276

URGENT CONSENSUAL MOTION FOR EXTENSION OF DEADLINES REGARDING

NORTH SIGHT COMMUNICATIONS, INC.’S MOTION FOR ALLOWANCE

AND PAYMENT OF POST-PETITION ADMINISTRATIVE EXPENSE CLAIM

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 (“Commonwealth”) (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”) (Bankruptcy Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801)

(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 representative of the Commonwealth of Puerto Rico (the “Commonwealth” or the 

“Debtor”) in this Title III case pursuant to section 315(b) of the Puerto Rico Oversight, 

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

consensual motion for entry of an order (the “Urgent Motion”), substantially in the form attached 

hereto as Exhibit A (the “Proposed Order”), extending the deadlines in the Order Scheduling 

Briefing of North Sight Communications, Inc.’s Motion for Allowance and Payment of PostPetition Administrative Expense Claim [Case No. 17-3283, ECF No. 23276]

3

(the “Scheduling 

Order”) and states as follows:

REQUEST FOR RELIEF

1. On January 18, 2023, North Sight Communications, Inc. (“Movant”) filed North 

Sight Communications, Inc.’s Motion for Allowance and Payment of Post-petition Administrative 

Expense Claim [ECF No. 23269] (the “Motion”), seeking payment of certain asserted 

administrative expenses, as described further in the Motion. 

2. On January 19, 2023, the Court entered the Scheduling Order. Pursuant to the 

Scheduling Order, the deadline to file (i) responsive papers to the Motion is February 1, 2023 at 

5:00 p.m. (Atlantic Standard Time) (the “Response Deadline”) and (ii) the Movant’s reply papers 

is February 8, 2023 at 5:00 p.m. (Atlantic Standard Time) (the “Reply Deadline”). The Motion 

will thereafter be taken under submission, unless the Court determines a hearing is necessary. 

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.

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3. The Debtor is currently analyzing its books and records in an attempt to reconcile 

the assertions in the Motion. Accordingly, in order to permit the Debtor to complete its assessment,

the Oversight Board respectfully requests an extension of the (a) Response Deadline from February 

1, 2023 to March 3, 2023 at 5:00 p.m. (Atlantic Standard Time), and (b) Reply Deadline from

February 8, 2023 to March 17, 2023 at 5:00 p.m. (Atlantic Standard Time). Movant has been 

informed of and has no objection to the extension requested herein. 

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 

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 Movant consents

to the relief requested herein.

NOTICE

5. The Oversight Board has provided notice of this Urgent 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 entities on the list of creditors holding the 20 largest 

unsecured claims against COFINA; (c) counsel to the statutory committees appointed in these Title 

III cases; (d) the Office of the United States Attorney for the District of Puerto Rico; (e) counsel 

to the Oversight Board and AAFAF; (f) all parties filing a notice of appearance in these Title III 

cases; and (g) Movant. A copy of the motion is also available at 

https://cases.ra.kroll.com/puertorico/.

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6. The Oversight Board submits that, in light of the nature of the relief requested 

herein, 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 deemed just and proper.

Dated: January 30, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Brian S. Rosen

Martin J. Bienenstock

Brian S. Rosen

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: mbienenstock@proskauer.com

 brosen@proskauer.com

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Commonwealth

/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

Email: hermann.bauer@oneillborges.com

Co-Attorney for the Financial Oversight and 

Management Board as representative for the 

Commonwealth

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CERTIFICATE OF SERVICE

I hereby certify that, on this same date, I electronically filed the foregoing with the Clerk 

of the Court using the CM/ECF system, which will send notifications of such filing to all CM/ECF 

participants in this case.

/s/ Hermann D. Bauer

Hermann D. Bauer

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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)

NORTH SIGHT COMMUNICATIONS, INC.

v.

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

COMMONWEALTH OF PUERTO RICO,

Debtor. 

PROMESA 

Title III

ORDER GRANTING URGENT

CONSENSUAL MOTION FOR EXTENSION OF DEADLINES REGARDING

NORTH SIGHT COMMUNICATIONS, INC.’S MOTION FOR ALLOWANCE

AND PAYMENT OF POST-PETITION ADMINISTRATIVE EXPENSE CLAIM 

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 (“Commonwealth”) (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”) (Bankruptcy Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) 

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

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Upon the Urgent Consensual Motion for Extension of Deadlines Regarding North Sight 

Communications, Inc.’s Motion for Allowance and Payment of Post-Petition Administrative 

Expense Claim (Docket Entry No. ____ in Case No. 17-3283, the “Urgent Motion”);2and the 

Court having found it has subject-matter jurisdiction over this matter pursuant to PROMESA 

section 306(a); and it appearing that venue in this district is proper pursuant to PROMESA section 

307(a); and the Court having found the Oversight Board provided adequate and appropriate notice 

of the Urgent Motion under the circumstances and no other or further notice is required; and upon 

the record herein, after due deliberation thereon, the Court having found good and sufficient cause 

exists for the granting of the relief as set forth herein:

1. The Urgent Motion is GRANTED as set forth herein. 

2. The Scheduling Order shall be modified as provided herein.

3. The following briefing schedule shall apply:

• The deadline for parties to file responsive papers to the Motion shall be March 3, 

2023 at 5:00 p.m. (Atlantic Standard Time).

• The deadline for the Movant to file a reply to all oppositions and responses shall be

March 17, 2023 at 5:00 p.m. (Atlantic Standard Time).

4. The Court will thereafter take the Motion on submission.

5. The Court shall retain jurisdiction to hear and determine all matters arising from 

the implementation of this Order. 

Dated: ___________, 2023.

SO ORDERED:

_________________________________

 HONORABLE LAURA TAYLOR SWAIN

United States District Judge

2 Capitalized terms not otherwise defined herein shall have the meanings given to them in the Urgent Motion.

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