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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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. 24050

 

INTERNATIONAL TRAFFIC SYSTEMS, LLC’S UNCONTESTED URGENT MOTION TO 

EXTEND DEADLINE TO FILE A RESPONSE TO THE FIVE HUNDRED SEVENTIETH

OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO 

RICO, THE EMPLOYEES RETIREMENT SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO, THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY, AND PUERTO RICO PUBLIC BUILDINGS 

AUTHORITY TO CLAIMS FOR WHICH THE DEBTORS ARE NOT LIABLE

COMES NOW, International Traffics Systems, LLC (“ITS”), by and through the 

undersigned legal counsel, and after meeting and conferring with Debtors’ counsel respectfully 

submits this urgent uncontested motion (the “Urgent Motion”) to extend the deadline for ITS to 

file a response to the Five Hundred Seventieth Omnibus Objection (Substantive) Of The 

Commonwealth Of Puerto Rico, The Employees Retirement System Of The Government Of The 

Commonwealth Of Puerto Rico, The Puerto Rico Highways And Transportation Authority, And 

1 The Debtors in these 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 (the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283 

(LTS)) (Last Four Digits of Federal Tax ID: 3481), (ii) 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), (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567 

(LTS)) (Last Four Digits of Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) 

(Bankruptcy Case No. 17-BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric 

Power Authority (“PREPA”) (Bankruptcy Case No. 17-4780 (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).

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Puerto Rico Public Buildings Authority To Claims For Which The Debtors Are Not Liable (the 

“Five Hundred Seventieth Omnibus Objection”). Dkt. No. 24050.

BACKGROUND

1. ITS filed its Proof of Claim asserting in the amount of $8,194,673.75 on June 29, 

2018 (the “Proof of Claim”). See Claim Number 79073. 

2. On April 20, 2023, Debtors filed the Five Hundred Seventieth Omnibus Objection

requesting the disallowance of ITS’ Proof of Claim. See Dkt. No. 24050.

3. ITS deadline to respond to the Five Hundred Seventieth Omnibus Objection is due 

on Monday, May 22, 2023 (the “Response Deadline”). See Id. at 1. 

RELIEF REQUESTED

1. The undersigned received extensive documentation from ITS related to the Proof 

of Claim on Monday, May 15, 2023. 

2. Upon receipt of this documentation, ITS met and conferred with counsel for 

Debtors yesterday, May 17, 2023, to inform that it would be filing the instant Urgent Motion to 

ascertain whether they had an objection to a 30-day extension to file a response to the Five 

Hundred Seventieth Omnibus Objection. Debtors’ counsel informed that they did not.

3. ITS therefore submits this Urgent motion to request an extension of the Response

Deadline to permit ITS to file an adequate response to the Five Hundred Seventieth Omnibus 

Objection. ITS respectfully requests, on an urgent basis, that the Court grant it a 30-day 

extension to file its response, which extension shall commence from the Response Deadline of 

May 22, 2023, and would be due on June 22, 2023.

COMPLIANCE WITH CASE MANAGEMENT PROCEDURES

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

and Administrative Procedures Order (Docket No. 20190-2 of Case No. 17-03283 (LTS)) (the 

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“CMP Order”), ITS hereby certifies that it has (a) carefully examined the matter and concluded 

that there is a true need for an urgent decision; (b) not created the urgency through any lack of 

due diligence; and (c) reasonable, good-faith communications took place with the parties to this 

adversary proceeding to resolve or narrow the issues before the Court. Specifically, counsel for 

ITS reached out to counsel for Debtors on May 17, 2023, who informed that they did not have 

an objection to ITS’ 30-day extension request. In addition, ITS certifies that no prior request for 

the relief sought herein has been made.

WHEREFORE, ITS hereby requests, on an urgent basis, that the Court (i) enter an order 

substantially in the form attached hereto as Exhibit A granting it a 30-day extension, until June

22, 2023, to file its response to Five Hundred Seventieth Omnibus Objection; and (ii) enter any 

other relief that is just or appropriate given the circumstances. 

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 18th day of May 2023.

CERTIFICATE OF SERVICE: In accordance with Fed. R. Bankr. P. 9014(b), Fed. R. 

Bankr. P. 7004(b), and the Court’s CMP Order, we hereby certify that a true and exact copy of 

the foregoing was sent by electronic mail upon all the parties listed in the Master Service List and 

by U.S. mail upon all the Standard Parties listed in the CMP Order.

MCCONNELL VALDÉS LLC

270 Muñoz Rivera Avenue, Suite 7

Hato Rey, Puerto Rico 00918

P.O. Box 364225

San Juan, PR 00936-4225

Tel: 787-250-5632

Fax: 787-759-9225

By: /s/ Nayuan Zouairabani Trinidad

Nayuan Zouairabani Trinidad

USDC No. 226411

E-mail: nzt@mcvpr.com

By: /s/ Victoria Rivera Lloréns

 Victoria Rivera Llorens

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USDC No. 307808

E-mail: vrll@mcvpr.com

Attorneys for International Traffic Systems, LLC

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