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. 23504

(Jointly Administered)

URGENT CONSENSUAL MOTION FOR

FURTHER EXTENSION OF RESPONSE DEADLINES

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

The Commonwealth of Puerto Rico (the “Commonwealth”), and the Puerto Rico Public 

Buildings Authority (“PBA” and, together with the Commonwealth, the “Debtors”), by and 

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

as the sole Title III representative of the Debtors pursuant to section 315(b) of the Puerto Rico 

Oversight, Management, and Economic Stability Act (“PROMESA”),2 respectfully submit this 

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

 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 Buildings Authority (“PBA”) (Last Four 

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

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

2

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

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attached hereto as Exhibit A (the “Proposed Order”), extending the briefing deadlines established 

in the Order Granting Urgent Consensual Motion for Further Extension of Response Deadlines 

and Rescheduling of Hearing Date [ECF No. 23504] (the “Extension Order”), and state as follows:

Background

1. On January 18, 2022, the Court entered the Order and Judgment Confirming 

Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, 

the Employees Retirement System of the Government of the Commonwealth of Puerto Rico, and 

the Puerto Rico Public Buildings Authority [ECF No. 19813] (the “Confirmation Order”), 

confirming the Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth 

of Puerto Rico, et al., [ECF No 19784] (as amended, supplemented, or modified, the “Plan”).

3

 

2. On March 15, 2022, the Effective Date of the Plan occurred, and the Plan was 

substantially consummated [ECF No. 20349]. Pursuant to Section 1.51 and Article III of the Plan 

and decretal paragraph 44 of the Confirmation Order, the deadline for filing proofs of 

Administrative Expense Claims was June 13, 2022 (the “Administrative Claim Bar Date”). Id. 

3. The following motions seeking, among other things, allowance and payment of 

Administrative Expense Claims were filed on or before the Administrative Claim Bar Date and 

remain pending (collectively, the “Administrative Expense Motions”):

Motions for Which Debtors Seek Extension:

ECF 

No. Motion Party4 Status

21187 Evertec’s Motion for 

Allowance of an 

Evertec Group, LLC 

(“Evertec”)

Objection Deadline: March

10, 2023 at 4:00 p.m. (AST) 

 3 Unless otherwise defined herein, capitalized terms shall have the meanings ascribed thereto in the Plan. 

4 The parties below are collectively the “Movants”.

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ECF 

No. Motion Party4 Status

Administrative Expense 

Claim

Reply Deadline: March 17, 

2023 at 4:00 p.m. 

Hearing: June 7, 2023

[Extension Order, ECF No. 

23504]

21191

Ricoh Puerto Rico, Inc.’s 

Motion for Allowance and 

Payment of Administrative 

Expense Claim in the sum of 

$4,864,017.20

Ricoh Puerto Rico, 

Inc. (“Ricoh”)

Objection Deadline: March 

10, 2023 at 4:00 p.m. (AST) 

Reply Deadline: March 17, 

2023 at 4:00 p.m. 

Hearing: June 7, 2023 

[Extension Order, ECF No. 

23504]

21209

COSEY’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim

Corporacion De 

Servicios Eductativos 

De Yabucoa 

(“COSEY”)

Objection Deadline: March 

10, 2023 at 4:00 p.m. (AST) 

Reply Deadline: March 17, 

2023 at 4:00 p.m. 

Hearing: June 7, 2023 

[Extension Order, ECF No. 

23504]

Remaining Pending Motion:

ECF 

No. Motion Party Status

21192

Plaintiff Blanca Iris 

Marrero’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim

Blanca Iris Marrero Objection filed on August 

26, 2022. [ECF No. 21931].

Reply Deadline: March 24, 

2023 at 5:00 p.m. (AST)

Hearing: June 7, 2023 [ECF 

No. 23687].

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Request for Relief

4. Since the filing of the Administrative Expense Motions, the Oversight Board, 

together with AAFAF’s advisors, continue to review the substance and the validity of the claims 

asserted in the Administrative Expense Motions. This process requires obtaining voluminous 

amounts of background information from the Commonwealth, PBA, and its various agencies and 

departments (collectively, the “Government”). The Oversight Board requires additional time to 

complete the review process with respect to the following Administrative Expense Motions

(collectively, the “Applicable Motions”, and the parties below are collectively the “Applicable 

Movants”):

Applicable Motions for Extension Request and Rescheduling Hearing

ECF No. Motion Party

21187 Evertec’s Motion for Allowance of an Administrative 

Expense Claim Evertec

21191

Ricoh Puerto Rico, Inc.’s Motion for Allowance and 

Payment of Administrative Expense Claim in the sum of 

$4,864,017.20

Ricoh

21209 COSEY’s Motion for Allowance and Payment of 

Administrative Expense Claim COSEY

5. Furthermore, such additional time would allow the Oversight Board to work with 

the respective Movants to seek a consensual resolution to the Applicable Motions, if possible, and, 

at a minimum, to narrow any contested issues that may ultimately need to be brought before the 

Court.

6. Accordingly, and with the consent of the Applicable Movants, the Oversight Board 

proposes the following extensions to the dates set forth in the Hearing Order and the Extension

Order only for the Applicable Motions, docketed at ECF Nos. 21187, 21191, and 21209: 

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• The deadline to respond to the Applicable Motions be extended to April 7, 2023 at 

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

• The deadline for parties to file replies to an opposition, if any, be extended to April 

14, 2023 at 4:00 p.m. (Atlantic Standard Time).

7. For clarity, the Oversight Board is not seeking an extension of deadlines with 

respect to the following Administrative Expense Motion:

Extension Not Requested

ECF 

No. Motion Reply Deadline

Hearing 

Date

21192 Plaintiff Blanca Iris Marrero’s Motion for Allowance 

and Payment of Administrative Expense Claim 03/24/20235 06/07/2023

8. 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 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 issues presented in the Urgent Motion; and has made 

reasonable, good-faith communications in an effort to resolve or narrow the issues that are being 

brought to the Court.

Notice

9. 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 

 5 See Order Granting Plaintiff Blanca Iris Marrero’s Further Consented Motion for Extension of Time to File Reply 

or Otherwise Inform Agreement with Debtors [ECF No. 23687]. 

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Debtors’ bonds; (c) the entities on the list of creditors holding the 20 largest unsecured claims 

against the Debtors; (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;6 (i) the 

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

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

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

other or further notice need be given. 

[Remainder of Page Left Intentionally Blank]

 6 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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WHEREFORE the Debtors request the Court enter the Proposed Order and grant such 

other relief as is just and proper. 

Dated: March 9, 2023

 San Juan, Puerto Rico

PROSKAUER ROSE LLP

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice) 

Brian S. Rosen (pro hac vice) 

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

-and-

/s/ Luis F. del Valle-Emmanuelli

Luis F. del Valle-Emmanuelli 

USDC-PR No. 209514

P.O. Box 79897

Carolina, Puerto Rico 00984-9897 

Tel: (787) 647-3503

OF COUNSEL FOR

A&S LEGAL STUDIO, PSC

434 Avenida Hostos San Juan, PR 00918

Tel: (787) 751-6764 / 763-0565

Fax: (787) 763-8260

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

Re: ECF No. _____

(Jointly Administered)

ORDER GRANTING

URGENT CONSENSUAL MOTION FOR FURTHER EXTENSION

OF RESPONSE DEADLINES AND RESCHEDULING OF HEARING DATE

Through the Urgent Consensual Motion for Further Extension of Response Deadlines, dated 

March 9, 2023 (Docket Entry No. _____)2 (the “Extension Motion”),3 the Oversight Board 

requests the extension of briefing deadlines with respect to certain, but not all, of the 

 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 Buildings Authority (“PBA”) (Last Four 

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case 

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

software limitations).

2 All docket entry references are to entries in Case No. 17-3283, unless otherwise specified.

3 Capitalized terms used but not otherwise defined herein have the meanings given to them in

the Extension Motion.

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Administrative Expense Motions with respect to which briefing deadlines were previously 

extended and a hearing was scheduled by the Order Granting Urgent Consensual Motion for 

Further Extension of Response Deadlines and Rescheduling of Hearing Date (Docket Entry No. 

22818), with further extensions as to certain motion granted pursuant to, inter alia, Docket Entry 

No. 23241. For the sake of clarity, extensions of the briefing schedules and adjournments have 

been requested with respect to the following Administrative Expense Motions (the “Applicable 

Motions” and the movants thereto, the “Applicable Movants”):

Docket 

Entry No.

The Applicable Motions (Extension Requested by Docket Entry No. 

_____)

21187 Evertec’s Motion for Allowance of an Administrative Expense Claim4

21191 Ricoh Puerto Rico, Inc.’s Motion for Allowance and Payment of Administrative 

Expense Claim in the sum of $4,864,017.20

21209 COSEY’s Motion for Allowance and Payment of Administrative Expense Claim

Extensions and adjournments have not been requested with respect to the following 

Administrative Expense Motion: 

Docket 

Entry No. Extension Not Requested by Docket Entry No. _____

21192 Plaintiff Blanca Iris Marrero’s Motion for Allowance and Payment of 

Administrative Expense Claim

Accordingly, the Court having found that the Oversight Board provided adequate and 

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

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

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

 4 Docket Entry No. 317 in Case No. 19-5523.

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

ORDERED that:

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

2. The deadline to respond to the Applicable Motions shall be extended to April 7, 

2023 at 4:00 p.m. (Atlantic Standard Time).

3. The deadline for the Applicable Movants to file a reply shall be extended to April 

14, 2023 at 4:00 p.m. (Atlantic Standard Time).

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

SO ORDERED.

Dated: March ___, 2023

 

LAURA TAYLOR SWAIN

United States District Judge

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