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. 21967

(Jointly Administered)

INFORMATIVE MOTION REGARDING EXECUTION OF 

STIPULATION IN CONNECTION WITH MOTION FOR RELIEF FROM STAY

To the Honorable United States District Judge Laura Taylor Swain:

The Financial Oversight and Management Board for Puerto Rico, as sole Title III 

representative of the Commonwealth of Puerto Rico (the “Commonwealth”) pursuant to section 

315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), 2

respectfully submits this informative motion (the “Informative Motion”) in connection with the 

Request for Comfort Order Pursuant 11 USC §362(j) [ECF No. 21967] (the “Motion”), filed by 

Aníbal Arroyo Bolerín, Rosa Idalia Orengo Rohena, Ada Norely López Santiago, Arinda Colón 

 1 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number listed as a 

bankruptcy case number due to software limitations and the last four (4) digits of each Debtor’s federal tax 

identification number, as applicable, are the (i) Commonwealth of Puerto Rico (the “Commonwealth”) 

(Bankruptcy Case No. 17-BK-3283 (LTS)) (Last Four Digits of Federal Tax ID: 3481), (ii) 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), (iii) Puerto Rico Highways and Transportation Authority 

(“HTA”) (Bankruptcy Case No. 17-BK-3567 (LTS)) (Last Four Digits of Federal Tax ID: 3808), (iv) Puerto Rico 

Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284 (LTS)) (Last Four Digits of 

Federal Tax ID: 8474), (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).

2

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

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Colón, and Jennifer Blest Quiroz (collectively, “Movants”), notifying the Court of the parties’ 

resolution of the Motion pursuant to the Stipulation and Agreed Order Resolving Request for 

Comfort Order Pursuant 11 USC §362(j), attached hereto as Exhibit A (the “Stipulation and 

Agreed Order”), and requesting the Court so order the Stipulation and Agreed Order.

Consensual Resolution of the Motion

1. On August 29, 2022, Movants filed the Motion, seeking a “comfort order” to allow 

for Movants to continue their collection efforts and/or defense of a judgment against the Puerto 

Rico Public Broadcasting Corporation3 in the Court of Appeals of the Commonwealth of Puerto 

Rico in the case captioned Blest Quiroz et al. v. Corporación de Puerto Rico para la Difusión 

Pública et al., Civil Case No. KDP 2010-1453. See Motion at 8.

2. On September 20, 2022, the Commonwealth and Movants reached a consensual 

resolution to the Motion, which was memorialized in the Stipulation and Agreed Order.

3. Therefore, the Commonwealth hereby informs that the Motion has been 

consensually resolved between the parties through the Stipulation and Agreed Order, and further 

requests that the Court so order the Stipulation and Agreed Order.

[Remainder of Page Left Intentionally Blank]

 3 The official name in Spanish of the public corporation is Corporación de Puerto Rico para la Difusión Pública. 

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WHEREFORE the Commonwealth requests the Court takes notice of this Informative 

Motion and of the consensual resolution of the Motion.

Dated: September 20, 2022

San Juan, Puerto Rico 

/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 Commonwealth of Puerto Rico

/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 Commonwealth of Puerto Rico

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Exhibit A

Stipulation and Agreed Order

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