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 

Re: ECF Nos. 17134, 17146, 17138, 

17793, 17797, 18011, 18019, 18071, 

18090, 18183, 18186, 18282, 18316, 

18414, 18422, 19089, 19092, 19419, 

19421, 19590, 19614

(Jointly Administered)

URGENT CONSENTED MOTION FOR EXTENSION OF DEADLINES

To the Honorable United States District Judge Laura Taylor Swain:

The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”), on behalf

of the Commonwealth of Puerto Rico (the “Commonwealth”), pursuant to the authority granted to 

it under the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, 

respectfully submits this urgent consented motion (the “Urgent Motion”) for entry of an order, 

substantially in the form attached hereto as Exhibit A (the “Proposed Order”), extending 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-BK3567-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).

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deadlines set forth in the Order Granting Urgent Consented Motion for Extension of Deadlines

[ECF No. 19614] (the “Scheduling Order”)2.

Request for Relief

1. On June 22, 2021, forty-four (44) correction officers (the “Movants”) of the 

Department of Corrections and Rehabilitation of the Commonwealth of Puerto Rico (“DCR”), an 

entity of the Commonwealth, filed a Motion Requesting Order for Allowance of Administrative 

Expense Priority Claim and Request for Immediate Payment Filed by Forty-Four Correction 

Officers of the Department of Correction and Rehabilitation of the Commonwealth of Puerto Rico

[ECF No. 17134] (the “Motion”), requesting that the Court enter an order (i) for “the allowance of 

the amounts claimed by the Movants as an administrative expense priority from the date of the 

filing of the Title III Commonwealth case and from then on”, (i) directing the Commonwealth to

pay such amounts in “full, and final satisfaction” within sixty (60) days of entry of such order, (iii) 

directing the Debtor to continue issuing payments on a monthly basis, and (iv) ordering the Trial 

Court of Aguadilla, in connection with certain state court litigations related to Movants’ request in 

their Motion, to “make the necessary adjustment to the ‘KRONOS’ time register system to register 

as overtime the 30 minute hour work during mealtime periods”. See, Motion at p. 17-18. 

2. On December 27, 2021, the Court entered the Scheduling Order which provides 

that oppositions to the Motion must be filed by February 4, 2022, and Movants’ reply by February 

19, 2022. 

3. Since the entry of the Scheduling Order, the Commonwealth has continued working 

diligently to gather the necessary information in order to properly assess the Motion and evaluate 

2

 The Financial Oversight and Management Board for Puerto Rico, as the Commonwealth’s representative pursuant 

to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), has 

authorized AAFAF to file this Urgent Motion on behalf of the Commonwealth.

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a possible consensual resolution of the same. Although substantial progress has been made in such 

endeavors, the Commonwealth needs additional time to finalize its analysis. The Commonwealth

reached out to Movants’ counsel who has consented to the requested extension. 

4. Accordingly, the Commonwealth, with Movants’ consent, proposes the following 

extensions of the deadlines set forth in the Scheduling Order: 

• The deadline to respond to the Motion shall be extended to February 28, 2022. 

• The deadline for Movants to file a reply to an opposition, if any, shall be extended to

March 15, 2022.

• The Court will thereafter take the Motion on submission, unless the Court determines 

that a hearing is necessary.

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

Administrative Procedures [ECF No. 17127-1] (the “Case Management Procedures”), the 

Commonwealth 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; 

has made a bona fide effort to resolve the matter without a hearing; has made reasonable, goodfaith communications in an effort to resolve or narrow the issues that are being brought to the 

Court, and no party opposes the relief requested herein.

Notice

6. The Commonwealth has provided notice of this motion in accordance with the Case 

Management Procedures to the following parties: (a) the Office of the United States Trustee for 

the District of Puerto Rico; (b) the indenture trustees and/or agents, as applicable, for the Debtors’ 

bonds; (c) the entities on the list of creditors holding the 20 largest unsecured claims against 

COFINA; (d) counsel to the statutory committees appointed in these Title III cases; (e) the Office 

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of the United States Attorney for the District of Puerto Rico; (f) counsel to the Oversight Board; 

(g) the Puerto Rico Department of Justice; (h) all parties filing a notice of appearance in these Title 

III cases; and (i) Movants. A copy of the motion is also available on the Commonwealth’s case 

website at https://cases.primeclerk.com/puertorico/.

7. The Commonwealth submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

WHEREFORE, the Commonwealth requests the Court enter the Proposed Order and 

grant such other relief as is just and proper. 

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Dated: February 3, 2022

San Juan, Puerto Rico 

Respectfully submitted, 

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Email: lmarini@mpmlawpr.com

/s/ Carolina Velaz-Rivero

Carolina Velaz-Rivero

USDC No. 300913

Email: cvelaz@mpmlawpr.com

MARINI PIETRANTONI MUÑIZ LLC

250 Ponce de León Ave.

Suite 900

San Juan, Puerto Rico 00918

Tel: (787) 705-2171

Fax: (787) 936-7494

Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

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Exhibit A

Proposed Order

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