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)

URGENT MOTION BY O’NEILL & BORGES LLC SEEKING AN EXTENSION OF 

THE DEADLINE TO RESPOND TO THE “MOTION TO DISQUALIFY THE LAW 

FIRM O’NEILL & BORGES, LLC FOR [PURPORTED] UNRESOLVABLE 

CONFLICTS OF INTEREST INCURRED IN VIOLATION OF THE PUERTO RICO 

RECOVERY ACCURACY IN DISCLOSURES ACT OF 2021, 48 U.S.C. 2101 ET SEQ.”

FILED BY R&D MASTER ENTERPRISES, INC. [ECF 23285]

To the United States District Court, Honorable Judge Laura Taylor Swain:

O’Neill & Borges LLC (“O&B”), as Puerto Rico counsel for the Financial Oversight and 

Management Board for Puerto Rico (the “Oversight Board”), as representative of 

the Commonwealth of Puerto Rico (“Commonwealth”), the Puerto Rico Sales Tax Financing 

Corporation (“COFINA”), the Puerto Rico Highways and Transportation Authority (“HTA”), the 

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

1 The Debtors in the jointly-administered 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 (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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Electric Power Authority (“PREPA”) and the Puerto Rico Public Buildings Authority jointly

(“PBA,” with the Commonwealth, COFINA, HTA, ERS and PREPA referred to as “Debtors”), 

as Title III debtors, by and through the Oversight Board, as the Debtors’ representative pursuant 

to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act

(“PROMESA”),2respectfully submit this motion (the “Motion”), for entry of an order, 

substantially in the form attached hereto as Exhibit A, extending the deadline for O&B to 

respond to the “Motion to Disqualify The Law Firm O’Neill & Borges, LLC For [Purported] 

Unresolvable Conflicts of Interest Incurred in Violation of The Puerto Rico Recovery Accuracy 

In Disclosures Act Of 2021, 48 U.S.C. 2101 et Seq.” (the “Motion to Disqualify”) filed By R&D 

Master Enterprises, Inc., Docket No. 23285. In support of this Motion, O&B respectfully 

represents as follows:

Relief Requested

1. By this Motion, O&B requests an order extending the deadline to file its response 

to the Motion to Disqualify until Monday, March 6, 2023. 

2. On January 19, 2023, R&D Master filed its Motion to Disqualify. Docket No. 

23285.

3. On January 20, 2023, the Honorable Court issued an order setting the briefing 

schedule for such motion as follows:

Responsive papers to the [Motion to Disqualify], if any, must be filed by 

February 2, 2023, at 5:00 p.m. (Atlantic Standard Time). Movant’s reply papers 

must be filed by February 9, 2023, at 5:00 p.m. (Atlantic Standard Time). The 

Court will thereafter take the [Motion to Disqualify] on submission unless the 

Court determines that a hearing is necessary.

2 PROMESA has been codified in 48 U.S.C. §§ 2101–2241.

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4. O&B is in the process of drafting its response to the Motion to Disqualify but in 

order file a comprehensive and thorough response thereto, O&B will require thirty (30)

additional days to finalize the same. 

5. Accordingly, O&B requests an extension of thirty (30) days from its current 

deadline of February 2, 2023 to submit its response, such that its response would be due on

Monday, March 6, 2023 at 5:00 p.m. (Atlantic Standard Time), and R&D Master’s 

corresponding reply would thus be due on Monday, March 13, 2023 at 5:00 p.m. (Atlantic 

Standard Time).

6. O&B sought the consent of R&D Master for this extension of time but was 

informed by its counsel that R&D Master does not consent to an extension of time.

7. O&B hereby certifies that there is a true need for urgent relief and that such 

urgency was not created through any lack of due diligence.

8. No prior request for the relief sought in this Motion has been made to this or any 

other court.

[Remainder of Page Intentionally Left Blank]

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WHEREFORE O&B respectfully requests the Court to enter the Proposed Order attached 

hereto as Exhibit A, granting the relief requested herein and all other relief that is just and 

proper. 

Dated: February 2, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Carla García Benítez

Carla García Benítez

USDC-PR No. 203708

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

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

-------------------------------------------------------------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)

ORDER EXTENDING O’NEILL & BORGES LLC’S DEADLINE TO RESPOND TO 

THE “MOTION TO DISQUALIFY THE LAW FIRM O’NEILL & BORGES, LLC FOR 

UNRESOLVABLE CONFLICTS OF INTEREST INCURRED IN VIOLATION OF THE 

PUERTO RICO RECOVERY ACCURACY IN DISCLOSURES ACT OF 2021, 48 U.S.C. 

2101 ET SEQ.” FILED BY R&D MASTER ENTERPRISES, INC. [ECF 23285]

Upon the Urgent Motion by O’Neill & Borges LLC Seeking an Extension of the Deadline 

to Respond to the “Motion to Disqualify the Law Firm O’Neill & Borges, LLC for [Purported] 

Unresolvable Conflicts of Interest Incurred in Violation of the Puerto Rico Recovery Accuracy in 

Disclosures Act of 2021, 48 U.S.C. 2101 et seq.” Filed by R&D Master Enterprises, Inc. [ECF

23285] (the “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 is proper pursuant to

1 The Debtors in the jointly-administered 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 (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).

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

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PROMESA section 307(a); and the Court having found that the relief requested in the Motion is 

in the best interests of the Debtors, their creditors, and other parties in interest, it is HEREBY 

ORDERED THAT:

1. The Motion is granted as set forth herein.

2. The deadline for O’Neill & Borges LLC to file its response the “Motion to 

Disqualify the Law Firm O’Neill & Borges, LLC For Unresolvable Conflicts of Interest Incurred 

on Violation of the Puerto Rico Recovery Accuracy In Disclosures Act Of 2021, 48 U.S.C. 2101 

et seq.” filed by movant R&D Master Enterprises, Inc. (“R&D Master”) at Docket No. 23285

shall be extended to Monday, March 6, 2023 at 5:00 p.m. (Atlantic Standard Time), and movant 

R&D Master’s corresponding reply would thus be due on Monday, March 13, 2023 at 5:00 p.m. 

(Atlantic Standard Time).

3. This Court retains exclusive jurisdiction with respect to all matters arising from or 

related to the implementation, interpretation, and enforcement of this Order.

4. This Order resolves docket entry no. .

SO ORDERED.

Dated: , 2022

San Juan, Puerto Rico LAURA TAYLOR SWAIN

United States District Judge

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