IN THE UNITED STATES DISTRICT COURT 

FOR THE 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) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY 

(“PREPA”), 

 Debtor. 

 PROMESA 

 Title III 

 No. 17 BK 4780-LTS 

 This document relates to 

 PREPA Title III case only 

URGENT MOTION OF THE AD HOC GROUP OF GENERAL 

OBLIGATION BONDHOLDERS TO EXPEDITE CONSIDERATION 

OF THE AD HOC GROUP OF GENERAL OBLIGATION BONDHOLDERS’ 

URGENT CROSS-MOTION, IN THE ALTERNATIVE, TO INTERVENE 

 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); 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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The Ad Hoc Group of General Obligation Bondholders (the “GO Group”)2

 hereby moves 

for expedited consideration of its Urgent Cross-Motion, in the Alternative, To Intervene (the 

“Intervention Motion”), filed contemporaneously herewith, and in support thereof respectfully 

states as follows: 

RELIEF SOUGHT 

1. The GO Group requests entry of an order setting the objection deadline for the 

Intervention Motion on February 3, 2018, at 7:00 p.m. (Atlantic Standard Time), and setting 

the reply deadline on February 5, 2018, at 7:00 p.m. (Atlantic Standard Time). 

JURISDICTION AND VENUE 

2. This Court has jurisdiction pursuant to PROMESA § 306(a).3 Venue is proper in 

this district pursuant to PROMESA § 307(a). 

BASIS FOR RELIEF SOUGHT 

3. With exceptions not applicable, “when an act is required or allowed to be done at 

or within a specified time . . . by order of court, the court for cause shown may in its discretion 

. . . order the period reduced.” Fed. R. Bankr. P. 9006(c)(1). 

4. The Intervention Motion concerns the GO Group’s objection to the Urgent Joint 

Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico 

Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders 

(A) Authorizing Postpetition Secured Financing, (B) Granting Priming Liens and Providing 

 2

 Members of the GO Group file this motion exclusively on their own behalves and do not 

assume any fiduciary or other duties to any other creditor or person. 

3

 The Puerto Rico Oversight, Management, and Economic Stability Act, Pub. L. No. 

114-187, 130 Stat. 549 (2016) (codified at 48 U.S.C. §§ 2101-2241). 

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Superpriority Administrative Expense Claims, (C) Modifying the Automatic Stay, (D) Scheduling 

a Final Hearing, and (E) Granting Related Relief (the “Loan Motion”) (Dkt. 549).4

5. The Loan Motion was filed on January 27. The Court ordered that objections to 

the Loan Motion be filed by February 1, and that the Loan Motion would be considered at the 

omnibus hearing on February 7. Dkt. 548. 

6. The GO Group has filed an objection to the Loan Motion contemporaneously 

herewith. However, certain parties have advised the GO Group that, in their view, the GO Group 

lacks standing to object. The GO Group disagrees. However, in case the Court holds that the 

GO Group lacks standing to object, the GO Group included with its objection a cross-motion in 

the alternative to intervene for the purpose of objecting (i.e., the Intervention Motion). 

7. The Intervention Motion will be moot if the Court rules on the Loan Motion 

before reaching the Intervention Motion. The Court may rule on the Loan Motion as early as 

February 7. Thus, the GO Group submits that the Intervention Motion should be fully briefed 

and ripe for decision no later than February 7. 

8. The potential mootness of the Intervention Motion provides good cause to 

expedite consideration of the Intervention Motion. 

CERTIFICATION 

9. The GO Group certifies that it has attempted in good faith to resolve with the 

Oversight Board the issues raised in the Intervention Motion. The Oversight Board opposes both 

this motion for expedited consideration and the Intervention Motion. 

 4

 “Dkt.” refers to documents filed on the docket of Case No. 17 BK 4780-LTS. 

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10. The GO Group certifies that it has carefully examined the matter and concluded 

that there is a true need for expedition and that the GO Group has not created the urgency 

through any lack of due diligence. 

CONCLUSION 

11. The Court should enter an order, substantially in the form of the proposed order 

attached hereto, expediting consideration of the Intervention Motion. 

Dated: February 1, 2018 

/s/ Ramón Rivera Morales 

J. Ramón Rivera Morales 

USDC-PR Bar No. 200701 

Andrés F. Picó Ramírez 

USDC-PR Bar No. 302114 

JIMÉNEZ, GRAFFAM & LAUSELL

P.O. Box 366104 

San Juan, PR 00936 

Telephone: (787) 767-1030 

Facsimile: (787) 751-4068 

Email: rrivera@jgl.com 

Respectfully submitted, 

/s/ Mark T. Stancil 

Lawrence S. Robbins (admitted pro hac vice) 

Gary A. Orseck (admitted pro hac vice) 

Kathryn S. Zecca (admitted pro hac vice) 

Mark T. Stancil (admitted pro hac vice) 

Ariel N. Lavinbuk (admitted pro hac vice) 

Donald Burke (admitted pro hac vice) 

ROBBINS, RUSSELL, ENGLERT, ORSECK,

UNTEREINER & SAUBER LLP 

1801 K Street, N.W., Suite 411-L 

Washington, DC 20006 

Telephone: (202) 775-4500 

Facsimile: (202) 775-4510 

Email: mstancil@robbinsrussell.com 

/s/ Andrew N. Rosenberg 

Andrew N. Rosenberg (admitted pro hac vice) 

Richard A. Rosen (admitted pro hac vice) 

Walter Rieman (admitted pro hac vice) 

Kyle J. Kimpler (admitted pro hac vice) 

Karen R. Zeituni (admitted pro hac vice) 

PAUL, WEISS, RIFKIND, WHARTON 

& GARRISON LLP 

1285 Avenue of the Americas 

New York, NY 10019 

Telephone: (212) 373-3000 

Facsimile: (212) 757-3990 

Email: arosenberg@paulweiss.com 

Counsel to the Ad Hoc Group of General Obligation Bondholders 

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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/ Mark T. Stancil 

Mark T. Stancil 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE 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.5

 PROMESA 

 Title III 

 No. 17 BK 3283-LTS 

 (Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY 

(“PREPA”), 

 Debtor. 

 PROMESA 

 Title III 

 No. 17 BK 4780-LTS 

 This document relates to 

 PREPA Title III case only 

[PROPOSED] ORDER GRANTING THE 

URGENT MOTION OF THE AD HOC GROUP OF GENERAL 

OBLIGATION BONDHOLDERS TO EXPEDITE CONSIDERATION 

OF THE AD HOC GROUP OF GENERAL OBLIGATION BONDHOLDERS’ 

URGENT CROSS-MOTION, IN THE ALTERNATIVE, TO INTERVENE 

 5

 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); 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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Upon consideration of the Urgent Motion of the Ad Hoc Group of General Obligation 

Bondholders To Expedite Consideration of the Ad Hoc Group of General Obligation 

Bondholders’ Urgent Cross-Motion, in the Alternative, To Intervene (the “Motion to Expedite”), 

the Court hereby FINDS AND DETERMINES that (i) the Court has jurisdiction to consider the 

Motion to Expedite and the relief requested therein pursuant to PROMESA section 306(a);6

(ii) venue is proper before this Court pursuant to PROMESA section 307(a); (iii) cause exists to 

shorten briefing deadlines as requested in the Motion to Expedite; and (iv) proper notice of the 

Motion to Expedite has been provided under the circumstances and no other or further notice 

need be provided. Accordingly, 

IT IS HEREBY ORDERED: 

1. The Motion to Expedite is GRANTED as set forth herein. 

2. Objections or responses, if any, to The Ad Hoc Group of General Obligation 

Bondholders’ Urgent Cross-Motion, in the Alternative, To Intervene (the “Intervention Motion”) 

must be filed and served by February 3, 2018, at 7:00 p.m. (Atlantic Standard Time). 

3. Any reply in support of the Intervention Motion must be filed and served by 

February 5, 2018, at 7:00 p.m. (Atlantic Standard Time). 

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

Dated: February __, 2018 

 ________________________________ 

 LAURA TAYLOR SWAIN 

 United States District Judge 

 6

 The Puerto Rico Oversight, Management, and Economic Stability Act, Pub. L. No. 

114-187, 130 Stat. 549 (2016) (codified at 48 U.S.C. §§ 2101-2241). 

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