Estimated Hearing Date: To be announced by Court

Objection Deadline: To be announced by Court 

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)

PLAINTIFF BLANCA IRIS MARRERO’S FURTHER 

CONSENTED MOTION FOR EXTENSION OF TIME TO FILE REPLY OR 

OTHERWISE INFORM AGREEMENT WITH DEBTORS

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).

Case:17-03283-LTS Doc#:23547 Filed:02/15/23 Entered:02/15/23 21:18:04 Desc: Main

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TO THE HONORABLE LAURA TAYLOR SWAIN,

UNITED STATES DISTRICT JUDGE:

COMES Now, State Court Plaintiff Blanca Iris Marrero (“claimant”), represented by the 

undersigned attorneys, and very respectfully avers and prays as follows:

1. On June 12, 2022 at ECF No. 21192 the appearing claimant filed her application for 

payment of administrative expenses on account of a civil tort claim filed at the Puerto Rico 

Court of First Instance, San Juan Superior Part.

2. On August 26, 2022 at ECF 21931 the Debtors Commonwealth of Puerto Rico

(“Commonwealth”) and Public Buildings Authority (“PBA”) filed their objection to 

claimant’s application.

3. As stated to this Honorable Court in previous motions, Counsel for the Commonwealth 

and the PBA, and the appearing creditor, after several conferences, have made substantial 

advances in the processing of this matter and have exchanged drafts of a proposed 

settlement agreement which will put to an end this contested matter.

4. The most recent draft stipulation agreement which would settle the pending controversy 

was sent by the appearing creditor to the Proskauer law firm, counsel for the 

Commonwealth and PBA. Counsel for the Commonwealth and PBA informed that they 

needed to discuss the same with the Commonwealth and PBA, and as a result had consented

that the appearing party be granted until February 10, 2023 to file her reply to their 

opposition to the application for payment of administrative expenses, or alternatively for 

the parties to this contested matter to file their stipulation.

5. Subsequently, brother counsel for Proskauer informed that they needed a further extension 

of time, lapsing on March 3, 2023, to address certain indemnity issues regarding the 

insurance policies in this matter. Through inadvertence, the undersigned put the February 

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10, 2023 date as February 20, 2023 in his calendar, instead of February 10, 2023, to wit, 

five (5) days ago. We apologize to thjs Honorable Court for the unintentional delay in 

filing this motion but no harm will be effected to the parties in granting the same. The 

communications between counsel have been professional and cordial and we believe we 

are close to solving this matter through a stipulation between the parties, as we have timely 

advised this Honorable Court previously.

6. In light of the above stated, counsel for the Commonwealth and PBA have amiably agreed 

to grant claimant herein until Friday March 3, 2023 to file any reply, if needed, to the 

opposition to claimant’s administrative claim, or alternatively to allow the stipulation to be 

filed, and also that the matter be moved to the next available hearing date in February or 

March, 2023, if necessary.

NOTICE

Notice of this Motion has hereby been served by CM/EF and on the Master Service List posted 

on the website of the Debtor’s Claims and Noticing Agent, by e-mail or by first-class mail.

No prior request for the relief sought herein has been made to this Court or to any other court.

WHEREFORE, the appearing Claimant offers her excuse for the five (5) day delay in filing 

this further motion, and respectfully requests that this Court allow movant herein to file her reply 

to ECF 21931, if needed, by Friday, March 3, 2023, and that the hearing on the issue be set for the

next available date on March, 2023 or later, if necessary, with any other appropriate relief.

RESPECTFULLY SUBMITTED.

Dated: February 15, 2023

Respectfully submitted,

 s/ Fernando Van Derdys, Esq.

Case:17-03283-LTS Doc#:23547 Filed:02/15/23 Entered:02/15/23 21:18:04 Desc: Main

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Estimated Hearing Date: To be announced by Court

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 USDC-PR 201913

 Law Offices of F. Van Derdys

 P.O. Box 9021888

 San Juan, PR 00902-1888

 Tel. 787.519.2211

 E-mail: fvanderdys@gmail.com 

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