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. 22818, 23024 

(Jointly Administered) 

URGENT CONSENSUAL MOTION FOR FURTHER EXTENSION OF 

RESPONSE DEADLINES AND RESCHEDULING OF HEARING DATE 

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

The Commonwealth of Puerto Rico (the “Commonwealth”), and the Puerto Rico Public 

Buildings Authority (“PBA” and, together with the Commonwealth, the “Debtors”), by and 

through the Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), 

as the sole Title III representative of the Debtors pursuant to section 315(b) of the Puerto Rico 

Oversight, Management, and Economic Stability Act (“PROMESA”),2 respectfully submit this 

urgent consensual motion (the “Urgent Motion”) for entry of an order, substantially in the form 

 

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”) (Last Four 

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case No. 19-BK-5523-

LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations). 

2

 PROMESA is codified at 48 U.S.C. §§ 2101–2241. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 1 of 11
2 

attached hereto as Exhibit A (the “Proposed Order”), (i) rescheduling the February 1, 2023 hearing 

date established in the Order Granting Urgent Consensual Motion for Further Extension of 

Response Deadlines and Rescheduling of Hearing Date [ECF No. 22818] (the “Hearing Order”) 

and (ii) extending the briefing deadlines established in the Order Granting Urgent Consensual 

Motion for Further Extension of Response Deadlines and Rescheduling of Hearing Date [ECF No. 

23024] (the “Extension Order”) solely with respect to the Applicable Motions (as defined below), 

and state as follows: 

Background

1. On January 18, 2022, the Court entered the Order and Judgment Confirming 

Modified Eighth Amended Title III Joint Plan of Adjustment 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 [ECF No. 19813] (the “Confirmation Order”), 

confirming the Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth 

of Puerto Rico, et al., [ECF No 19784] (as amended, supplemented, or modified, the “Plan”).3 

2. On March 15, 2022, the Effective Date of the Plan occurred, and the Plan was 

substantially consummated [ECF No. 20349]. Pursuant to Section 1.51 and Article III of the Plan 

and decretal paragraph 44 of the Confirmation Order, the deadline for filing proofs of 

Administrative Expense Claims was June 13, 2022 (the “Administrative Claim Bar Date”). Id. 

3. The following motions seeking, among other things, allowance and payment of 

Administrative Expense Claims were filed on or before the Administrative Claim Bar Date and 

remain pending (collectively, the “Administrative Expense Motions”): 

 

3

 Unless otherwise defined herein, capitalized terms shall have the meanings ascribed thereto in the Plan. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 2 of 11
3 

Motions for Which Debtors Seek Extension: 

ECF 

No. Motion Party4 Status 

21187 

Evertec’s Motion for 

Allowance of an 

Administrative Expense 

Claim 

Evertec Group, LLC 

(“Evertec”) 

Objection Deadline: January 

11, 2023 at 4:00 p.m. (AST) 

Reply Deadline: January 18, 

2023 at 4:00 p.m. 

Hearing: February 1, 2023 

[Extension Order, ECF No. 

23024] 

21191 

Ricoh Puerto Rico, Inc.’s 

Motion for Allowance and 

Payment of Administrative 

Expense Claim in the sum of 

$4,864,017.20

Ricoh Puerto Rico, 

Inc. (“Ricoh”) 

Objection Deadline: January 

11, 2023 at 4:00 p.m. (AST) 

Reply Deadline: January 18, 

2023 at 4:00 p.m. 

Hearing: February 1, 2023 

[Extension Order, ECF No. 

23024] 

21209 

COSEY’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim 

Corporacion De 

Servicios Eductativos 

De Yabucoa 

(“COSEY”) 

Objection Deadline: January 

11, 2023 at 4:00 p.m. (AST) 

Reply Deadline: January 18, 

2023 at 4:00 p.m. 

Hearing: February 1, 2023 

[Extension Order, ECF No. 

23024] 

Remaining Pending Motion: 

ECF 

No. Motion Party Status 

21192 

Plaintiff Blanca Iris 

Marrero’s Motion for 

Allowance and Payment of 

Blanca Iris Marrero Objection filed on August 

26, 2022. [ECF No. 21931]. 

 

4

 The parties below are collectively the “Movants”. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 3 of 11
4 

ECF 

No. Motion Party Status 

Administrative Expense 

Claim 

Reply Deadline: January 20, 

2023 at 5:00 p.m. (AST) 

Hearing: February 1, 2023 

[ECF No. 23114]. 

Request for Relief 

4. Since the filing of the Administrative Expense Motions, the Oversight Board, 

together with AAFAF’s advisors, continue to review the substance and the validity of the claims 

asserted in the Administrative Expense Motions. This process requires obtaining voluminous 

amounts of background information from the Commonwealth, PBA, and its various agencies and 

departments (collectively, the “Government”). The Oversight Board requires additional time to 

complete the review process with respect to the following Administrative Expense Motions 

(collectively, the “Applicable Motions”, and the parties below are collectively the “Applicable 

Movants”): 

Applicable Motions for Extension Request and Rescheduling Hearing 

ECF No. Motion Party 

21187 Evertec’s Motion for Allowance of an Administrative 

Expense Claim Evertec 

21191 

Ricoh Puerto Rico, Inc.’s Motion for Allowance and 

Payment of Administrative Expense Claim in the sum of 

$4,864,017.20

Ricoh 

21209 COSEY’s Motion for Allowance and Payment of 

Administrative Expense Claim COSEY 

5. Furthermore, such additional time would allow the Oversight Board to work with 

the respective Movants to seek a consensual resolution to the Applicable Motions, if possible, and, 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 4 of 11
5 

at a minimum, to narrow any contested issues that may ultimately need to be brought before the 

Court. 

6. Accordingly, and with the consent of the Applicable Movants, the Oversight Board 

proposes the following extensions to the dates set forth in the Hearing Order and the Extension 

Order only for the Applicable Motions, docketed at ECF Nos. 21187, 21191, and 21209: 

 The deadline to respond to the Applicable Motions be extended to February 10, 

2023 at 4:00 p.m. (Atlantic Standard Time). 

 The deadline for parties to file replies to an opposition, if any, be extended to 

February 17, 2023 at 4:00 p.m. (Atlantic Standard Time). 

 The hearing date for the Applicable Motions be rescheduled for March 15, 2023 

at 9:30 a.m. AST. 

7. For clarity, the Oversight Board is not seeking an extension of deadlines with 

respect to the following Administrative Expense Motion: 

Extension Not Requested 

ECF 

No. Motion Reply Deadline 

Hearing 

Date 

21192 Plaintiff Blanca Iris Marrero’s Motion for Allowance 

and Payment of Administrative Expense Claim 01/20/20235

 02/01/2023 

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

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

Oversight Board 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; 

 

5

 See Order Granting Plaintiff Blanca Iris Marrero’s Further Consented Motion for Extension of Time to File Reply 

or Otherwise Inform Agreement with Debtors [ECF No. 23136]. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 5 of 11
6 

has made a bona fide effort to resolve the issues presented in the Urgent Motion; and has made 

reasonable, good-faith communications in an effort to resolve or narrow the issues that are being 

brought to the Court. 

Notice 

9. The Oversight Board 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 the Debtors; (d) counsel to the statutory committees appointed in these Title III cases; (e) 

the Office 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) the Other Interested Parties;6

 (i) the 

Applicable Movants; and (j) all parties filing a notice of appearance in these Title III cases. A copy 

of the motion is also available at https://cases.ra.kroll.com/puertorico/. 

10. The Oversight Board submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

[Remainder of Page Left Intentionally Blank] 

 

 

6

 The “Other Interested Parties” include the following: (i) counsel to certain of the insurers and trustees of the bonds 

issued or guaranteed by the Debtors; and (ii) counsel to certain ad hoc groups of holders of bonds issued or 

guaranteed by the Debtors. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 6 of 11
7 

WHEREFORE the Debtors request the Court enter the Proposed Order and grant such 

other relief as is just and proper. 

Dated: January 11, 2023 

 San Juan, Puerto Rico 

PROSKAUER ROSE LLP 

/s/ Brian S. Rosen 

Martin J. Bienenstock (pro hac vice) 

Brian S. Rosen (pro hac vice) 

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

-and- 

/s/ Luis F. del Valle-Emmanuelli 

Luis F. del Valle-Emmanuelli 

USDC-PR No. 209514 

P.O. Box 79897 

Carolina, Puerto Rico 00984-9897 

Tel: (787) 647-3503 

OF COUNSEL FOR 

A&S LEGAL STUDIO, PSC 

434 Avenida Hostos San Juan, PR 00918 

Tel: (787) 751-6764 / 763-0565 

Fax: (787) 763-8260 

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 7 of 11
Exhibit A 

Proposed Order

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 8 of 11
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 No. _____ 

(Jointly Administered) 

ORDER GRANTING 

URGENT CONSENSUAL MOTION FOR FURTHER EXTENSION 

OF RESPONSE DEADLINES AND RESCHEDULING OF HEARING DATE 

Through the Urgent Consensual Motion for Further Extension of Response Deadlines and 

Rescheduling of Hearing Date, dated January 11, 2023 (Docket Entry No. _____)2 (the “Extension 

Motion”),3 the Oversight Board requests the extension of briefing deadlines with respect to certain, 

 

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”) (Last Four 

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case 

No. 19-BK-5523-LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to 

software limitations). 

2

 All docket entry references are to entries in Case No. 17-3283, unless otherwise specified. 

3

 Capitalized terms used but not otherwise defined herein have the meanings given to them in 

the Extension Motion. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 9 of 11
2 

but not all, of the Administrative Expense Motions with respect to which briefing deadlines were 

previously extended and a hearing was scheduled by the Order Granting Urgent Consensual 

Motion for Further Extension of Response Deadlines and Rescheduling of Hearing Date (Docket 

Entry No. 22818), with further extensions as to certain motion granted pursuant to, inter alia, 

Docket Entry No. 23024. For the sake of clarity, extensions of the briefing schedules and 

adjournments have been requested with respect to the following Administrative Expense Motions 

(the “Applicable Motions” and the movants thereto, the “Applicable Movants”): 

Docket 

Entry No. 

The Applicable Motions (Extension Requested by Docket Entry No. 

_____) 

21187 Evertec’s Motion for Allowance of an Administrative Expense Claim4

21191 Ricoh Puerto Rico, Inc.’s Motion for Allowance and Payment of Administrative 

Expense Claim in the sum of $4,864,017.20

21209 COSEY’s Motion for Allowance and Payment of Administrative Expense Claim 

Extensions and adjournments have not been requested with respect to the following 

Administrative Expense Motion: 

Docket 

Entry No. Extension Not Requested by Docket Entry No. _____ 

21192 Plaintiff Blanca Iris Marrero’s Motion for Allowance and Payment of 

Administrative Expense Claim 

Accordingly, the Court having found that the Oversight Board 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 Extension Motion; and the Court having 

determined that the factual bases set forth in the Extension Motion establish just cause for the relief 

 

4

 Docket Entry No. 317 in Case No. 19-5523. 

Case:17-03283-LTS Doc#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 10 of 11
3 

granted herein; and after due deliberation and sufficient cause appearing therefor, it is hereby

ORDERED that: 

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

2. The deadline to respond to the Applicable Motions shall be extended to February 

10, 2023 at 4:00 p.m. (Atlantic Standard Time). 

3. The deadline for the Applicable Movants to file a reply shall be extended to 

February 17, 2023 at 4:00 p.m. (Atlantic Standard Time). 

4. The Applicable Motions will be heard in connection with the omnibus hearing 

scheduled for March 15, 2023. 

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#:23240 Filed:01/11/23 Entered:01/11/23 12:47:26 Desc: Main

Document Page 11 of 11