7295432.1

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

Case 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,

 Debtor.

PROMESA

Title III

Case No. 17-BK-04780-LTS

Court Filing Relates Only to 

PREPA and Shall Only be Filed

In Case No. 17-BK-04780-LTS and

Main Case 17-BK-3283-LTS

ARC AMERICAN, INC.’S MOTION TO INFORM REGARDING 

ATTENDANCE AND PARTICIPATION AT FEBRUARY 7, 2018 HEARING AND ANY 

SUBSEQUENTLY SCHEDULED HEARING DATES

TO THE HONORABLE LAURA TAYLOR SWAIN,

UNITED STATES DISTRICT JUDGE:

 

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 (Bankruptcy Case No. I7-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. I7-BK-3566(LTS)) (Last Four Digits of Federal Tax ID: 9686), (iii) Puerto Rico 

Highways and Transportation Authority ("HTA") (Bankruptcy Case No. I7-BK-3567 (LTS)) (Last Four Digits of 

Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation “COFINA”) (Bankruptcy Case No. I7-BK3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); and (v) Puerto Rico Electric Power Authority ("PREPA") 

(Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747).

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7295432.1

Arc American, Inc. (“Arc”), by and through its undersigned counsel, hereby submits this 

Informative Motion in response to this Court’s Order Regarding Procedures For Attendance, 

Participation And Observation Of February 7-8, 2018, Omnibus Hearing [Docket No. 2258, Main 

Case 17-BK-3283-LTS] (the “Order”), and respectfully states as follows:

1. Robert E. Nies, on behalf of Arc, will appear in person by video teleconference at the 

Hearing (as defined in the Order) in Courtroom 17C of the United States District Court for the Southern 

District of New York to present argument on the Limited Objection By And Reservation Of Rights Of 

Arc American, Inc. 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 Superpriority Administrative Expense Claims, (C) Modifying The 

Automatic Stay, (D) Scheduling A Final Hearing, And (E) Granting Related Relief, filed February 

1, 2018.

2. Jose L. Ramirez-Coll, co-counsel on behalf of Arc, will also attend the Hearing in 

the San Juan Courtroom, though he does not intend to present argument at the Hearing. 

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico on February 2, 2018.

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7295432.1

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 electronic notification of such filing 

to all counsel of record.

CHIESA SHAHINIAN & GIANTOMASI PC

By: /s/ Robert E. Nies

Robert E. Nies (pro hac vice applicant)

George A. Spadoro (pro hac vice applicant)

Marc R. Lepelstat (pro hac vice applicant)

Michael R. Caruso (pro hac vice applicant)

One Boland Drive

West Orange, New Jersey 07052

Telephone: (973) 530-2012

Facsimile: (973) 530-2022

Email: rnies@csglaw.com 

-andANTONETTI MONTALVO & RAMIREZ COLL

 

By: /s/Jose L. Ramirez-Coll

Jose L. Ramirez-Coll

P.O. Box 13128

Telephone: (787) 977-0303 

Facsimile: (787) 977-0323

Email: jramirez@amrclaw.com 

Attorneys for Arc American, Inc.

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