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) 

Re: ECF Nos. 18602, 21005, 21006, 

21461 

URGENT CONSENSUAL MOTION FOR EXTENSION OF DEADLINES 

To the Honorable United States District Court Judge Laura Taylor Swain: 

COMES NOW, Community Health Foundation of P.R. Inc. (hereinafter “Movant”), 

through the undersigned attorney and very respectfully submits this urgent consensual motion for 

entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), 

extending the dates and deadlines established in the Order Granting Urgent Consensual Motion 

for Extension of Deadlines [ECF No. 21461] (the “Scheduling Order”), and states as follows:

Request for Relief 

1. On October 19, 2021, Community Health Foundation of P.R. Inc. (“Movant”) filed 

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 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).

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the Community Health Foundation of P.R. Inc.’s Motion for Allowance and Payment of 

Administrative Expense [ECF No. 18602] (the “Administrative Expense Motion”) seeking, 

among other things, (i) allowance and payment of certain post-petition wraparound 

payments and (ii) an order requiring the Commonwealth to prospectively make all 

wraparound payments to Movant. 

2. The Administrative Expense Motion requested a hearing for the Court to consider 

the Administrative Expense Motion (the “Hearing”) to be established for December 15, 

2021, at 9:30 a.m. (A.S.T.) and the deadline to object to the Administrative Expense 

Motion (“Objection Deadline”) to be November 30, 2021, at 4:00 p.m. (A.S.T.). 

3. Thereafter, with Movant’s consent, the Financial Oversight and Management 

Board for Puerto Rico (the “Oversight Board”) moved for several extensions of the 

deadlines set forth above to, among other things, allow Movant to furnish to the Oversight 

Board certain requested documentation in support of its claim and for the Oversight Board 

to evaluate said documentation and investigate the claim. 

4. On April 13, 2022, upon the motion of the Oversight Board requesting an extension 

of the schedule proposed in the Administrative Expense Motion [ECF No. 20556], the 

Court entered an Order (the “Extension Order”), pursuant to which it set the Objection 

Deadline for May 25, 2022, at 4:00 p.m. (A.S.T.) and the deadline for Movant’s reply 

papers (the “Reply Deadline”), if any, for June 8, 2022, at 4:00 p.m. (A.S.T.). The Hearing 

was scheduled for the June 29, 2022, omnibus hearing. See Order Granting Urgent 

Consensual Motion Seeking Adjournment of Hearing [ECF No. 20568] ¶ 2. 

5. On May 25, 2022, the Oversight Board filed the Objection of the Financial 

Oversight and Management Board for Puerto Rico to the Motion of Community Health 

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Foundation of P.R. Inc. for Allowance and Payment of Administrative Expense [ECF No. 

21005] (the “Objection”) and a separate supporting Declaration of Felmarie Cruz Morales 

in Respect of Objection of the Financial Oversight and Management Board for Puerto Rico 

[ECF No. 21006] (the “Cruz Declaration”). 

6. On June 6, 2022, upon the motion of Movant requesting an extension of the 

schedule proposed in the Extension Order [ECF No. 21110], the Court entered the 

Scheduling Order (the “Second Extension Order”), which set the Reply Deadline for July 

8, 2022, at 4:00 p.m. (A.S.T.) and scheduled the Hearing on the Administrative Expense 

Motion for the August 10, 2022, omnibus hearing. See Order Granting Urgent Consensual 

Motion for Extension of Deadlines [ECF No. 21116], ¶¶ 2 and 3. 

7. On July 7, 2022, upon the motion of Movant requesting an extension of the 

schedule proposed in the Second Extension Order [ECF No. 21461], the Court entered the 

Scheduling Order, which set the Reply Deadline for August 8, 2022, at 4:00 p.m. (A.S.T.) 

and scheduled the Hearing on the Administrative Expense Motion for the September 21, 

2022, omnibus hearing. See Order Granting Urgent Consensual Motion for Extension of 

Deadlines [ECF No. 21461], ¶¶ 2 and 3. 

8. Movant continues to work on obtaining and organizing the data requested by the 

Oversight Board and addressing other aspects raised in the Objection and in the Cruz 

Declaration. Certain data and information required to respond to the Objection has been 

obtained from the health insurance companies and is being reconciled and organized by 

Movant. Movant requires additional time to reconcile the data provided with its own data 

and to organize it in a presentable manner. As Movant will not be able to file its reply to 

the Objection by August 8, 2022, it respectfully requests an extension of the deadlines 

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relating to the Administrative Expense Motion as follows: 

 Reply Deadline: September 7, 2022, at 4:00 p.m. A.S.T. 

 Hearing on the Administrative Expense Motion: November 2, 2022, at 9:30 

a.m. A.S.T. 

The Oversight Board has consented to this extension. 

9. Pursuant to Paragraph 1.H of the Sixteenth Amended Notice, Case Management and 

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

Movant 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; has made reasonable, goodfaith communications in an effort to resolve or narrow the issues that are being brought to 

the Court, and the Oversight Board consents to the relief. 

WHEREFORE, Community Health Foundation of P.R. Inc. respectfully requests the Court 

to enter the Proposed Order and to grant any further relief as is just and proper. 

RESPECTFULLY SUBMITTED. 

In San Juan, Puerto Rico, on this 5th day of August 2022. 

CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that on this date, I electronically filed the foregoing with the Clerk 

of the Court using the CM/ECF system, which will notify all parties registered through their 

attorneys of record, including the Standard Parties and the Affected Parties; and have served a 

copy of the foregoing to the U.S. Trustee by U.S. mail. 

CORDOVA-AYUSO LAW OFFICE LLC 

P.O. BOX 194021 

SAN JUAN, PR 00919-4021 

TEL.: (787) 230-0463 

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EMAIL: lac@calawpr.com 

/s/ Lucas A. Córdova-Ayuso 

Lucas A. Córdova-Ayuso, Esq. 

USDC-PR No. 226805 

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Exhibit A 

Proposed Order 

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