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.,

Debtors1

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 21738

(Jointly Administered)

URGENT CONSENSUAL MOTION FOR A FIFTH EXTENSION

TO RESPOND TO OBJECTION TO CLAIM ECF No. 21738

TO THE HONORABLE UNITED STATES DISTRICT COURT

JUDGE LAURA TAYLOR SWAIN:

COMES NOW, The Financial Oversight and Management Board for Puerto Rico (the

“FOMB”), as representative of the Title III Debtors, through the undersigned counsel, and 

respectfully requests a fifth extension of time for Rocket Learning LLC to file a response in 

connection with the Four Hundred Eighty-Eighth Omnibus Objection (Non-Substantive) of the

Commonwealth of Puerto Rico, the Employees’ Retirement System of the Government 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”) (Bankruptcy Case No. 19-

BK-5233-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as Bankruptcy Case 

numbers due to software limitations).

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 1 of 7
2

Commonwealth of Puerto Rico, and the Puerto Rico Public Buildings Authority to Deficient 

Claims (the “Omnibus Objection”), filed at ECF No. 21738, and for the FOMB to file a reply in 

support of the Omnibus Objection.

BACKGROUND

1. The Debtor filed the Four Hundred Eighty-Eighth Omnibus Objection (NonSubstantive) 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 To Deficient Claims on August 5, 2022, at ECF No. 21738 (“the Objection”).

2. Among the claims objected to is Claim Number 115471, filed by creditor Rocket 

Learning LLC. The claim includes supporting documents, however, the Debtor is contesting the 

creditor’s asserted liability and requesting additional supporting documents to validate the claim.

3. It has been conveyed to the FOMB that local counsel to Rocket Learning LLC, 

Ms. Maria Mercedes Figueroa y Morgade, is dealing with a pressing health issue, and consequently 

has been unable to file this Urgent Consensual Motion. In the meantime, representatives of Rocket 

Learning LLC are continuing to attempt to gather additional documentation to supplement their 

prior production of information to counsel for the FOMB, as noted below.

4. To continue promoting and pursuing a consensual resolution of the Objection to 

Claim 115471, Rocket Learning LLC previously requested four prior extensions to respond to the 

Objection to its claim filed at ECF No. 21738, each with the consent of the Debtor’s counsel. See 

ECF Nos. 22055 (Sept. 3, 2022), 22411 (Sept. 30, 2022), 22813 (Nov. 4, 2022), and 22981 (Dec. 

5, 2022). The Court granted each of the prior motions for extension. See ECF Nos. 22072 (Sept. 

6, 2022), 22414 (Sept. 30, 2022), 22841 (Nov. 10, 2022), and 22988 (Dec. 6, 2022).

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 2 of 7
3

5. Two more sources of supporting documents were sent to counsel for the FOMB

and are currently under review. 

6. Those two sources have documents that also evince the nature of the proof of claim 

and the amount. However, the sources are voluminous and extensive and its review is still ongoing.

REQUEST FOR RELIEF

7. As noted above, this Urgent Motion requesting a fifth consensual extension is filed 

with the consent of both the FOMB and Rocket Learning LLC. 

8. The parties jointly respectfully request an extension of time for Rocket Learning 

LLC to respond to the Objection, on or before February 10, 2023, and approximately two weeks

for the FOMB to reply on or before February 24, 2023.

9. No opposition to this Urgent Motion requesting an additional extension is 

anticipated.

10. Therefore, the FOMB and Rocket Learning LLC agree and propose the following 

briefing schedule with regards to the Objection and Claim No. 115471::

(a) The deadline for Rocket Learning LLC to respond to the Objection to claim 

shall be extended to February 10, 2023.

(b) The deadline for the FOMB to reply shall be extended to 

February 24, 2023.

(c) The Court will schedule a hearing on the Objection to claim.

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 3 of 7
4

Certification of Compliance with

Local Rule 9013-1 and the Sixteenth Amended Case Management Procedures

Pursuant to Paragraph I.H of the Sixteenth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 20190-1] (the “Case Management Procedures”), the FOMB 

hereby 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; it has made 

a bona fide effort to resolve the matter without a hearing; it has made reasonable, good-faith 

communications with Rocket Learning LLC in an effort to resolve or narrow the issues that are 

being brought to the Court, and Rocket Learning LLC consents to the relief requested herein.

WHEREFORE, the FOMB and Rocket Learning LLC respectfully request that the Court

grant this Urgent Consensual Motion and enter an Order consistent with the Proposed Order 

attached hereto.

WE HEREBY CERTIFY that the foregoing Urgent Consensual Motion for a Fifth 

Extension to Respond to Objection to Claim ECF No. 21738 was filed with the Clerk of the 

Bankruptcy Court for the District of Puerto Rico using the CM/ECF system, which will serve 

notice and a copy of this filing to all registered participants.

Respectfully submitted,

In San Juan, Puerto Rico, on January 20, 2023.

PROSKAUER ROSE LLP

/s/ Brian S. Rosen

Brian S. Rosen

(Admitted Pro Hac Vice)

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: Email: brosen@proskauer.com

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 4 of 7
5

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 for Puerto Rico, 

as Representative of the Title III Debtors

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Gabriel A. Miranda-Rivera

USDC No. 306704

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 5 of 7
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

----------------------------------------------------------

In re: PROMESA

Title III

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of No. 17 BK 3283-LTS

THE COMMONWEALTH OF PUERTO RICO (Jointly Administered)

et al.,

Debtors.1

----------------------------------------------------------

ORDER GRANTING URGENT CONSENSUAL MOTION FOR EXTENSION OF

DEADLINES TO RESPOND TO DEBTOR’S OBJECTION TO CLAIM

Upon the Urgent Consensual Motion For Extension Of Deadline To Respond To Debtor’s 

Objection To Claim (Docket Entry No_______ in Case No. 17-3283) (the “Urgent Motion”);2and 

the Court having found it has subject matter jurisdiction of this matter pursuant to PROMESA 

section 306; and it appearing that venue in this district is proper pursuant to PROMESA section 

307; and the Court having found that the relief requested in the Urgent Motion is in the best 

interests of the Commonwealth and movant; and the Court having found that the Debtor 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 Urgent Motion; and the Court 

having determined that the factual bases set forth in the Urgent Motion establish just cause for the

relief granted herein; it is hereby ORDERED that:

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 (the 

“Commonwealth”) (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- ETS) (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 Urgent Motion

In re:

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 6 of 7
2

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

2. The deadline for Rocket Learning LLC to respond to the Objection to claim shall 

be extended to February 10, 2023.

3. The deadline for the FOMB to reply shall be extended to February 24, 2023.

4. The Objection to claim will be heard in connection with the omnibus hearing to be 

scheduled.

5. This Order resolves Docket Entry No. ____ in Case No. 17-3283.

SO ORDERED.

Dated:

January ____, 2023

LAURA TAYLOR SWAIN

United States District Judge

Case:17-03283-LTS Doc#:23301 Filed:01/20/23 Entered:01/20/23 19:19:57 Desc: Main

Document Page 7 of 7