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. 24400 

(Jointly Administered)

URGENT CONSENSUAL MOTION 

FOR FURTHER EXTENSION OF RESPONSE DEADLINES 

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. 

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attached hereto as Exhibit A (the “Proposed Order”), extending the briefing deadline established 

in the Order Grating Urgent Consensual Motion for Further Extension of Response Deadlines 

[ECF No. 24400] (the “Extension Order”), 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”):4

ECF 

No. Motion Party5 Status

21191 

Ricoh Puerto Rico, Inc.’s 

Motion for Allowance and 

Payment of Administrative 

Ricoh Puerto Rico, 

Inc. (“Ricoh”)

Objection Deadline: June 

30, 2023 at 4:00 p.m. (AST) 

3

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

4

 Evertec’s Motion for Allowance of an Administrative Expense Claim [ECF No. 21187] is fully briefed [ECF Nos. 

24395, 24481] and is scheduled to be heard at the omnibus hearing on August 30, 2023 [ECF No. 24136].

5

 The parties below are collectively the “Movants”.

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ECF 

No. Motion Party5 Status

Expense Claim in the sum of 

$4,864,017.20

Reply Deadline: July 7, 

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

Hearing: August 30, 2023 

[Extension Order, ECF No. 

24400] 

21209 

COSEY’s Motion for 

Allowance and Payment of 

Administrative Expense 

Claim

Corporacion De 

Servicios Eductativos 

De Yabucoa 

(“COSEY”)

Objection Deadline: June 

30, 2023 at 4:00 p.m. (AST) 

Reply Deadline: July 7, 

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

Hearing: August 30, 2023 

[Extension Order, ECF No. 

24400] 

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. The Oversight Board requires additional time to complete the review process with 

respect to the Administrative Expense Motions. 

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

the respective Movants to seek a consensual resolution to the Administrative Expense Motions, if 

possible, and, at a minimum, to narrow any contested issues that may ultimately need to be brought 

before the Court. 

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

the following extensions to the dates set forth in the Extension Order for the Administrative 

Expense Motions, docketed at ECF Nos. 21191 and 21209: 

• The deadline to respond to the Administrative Expense Motions be extended to

July 28, 2023 at 4:00 p.m. (Atlantic Standard Time). 

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

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

• The hearing date for the Administrative Expense Motions remain August 30, 2023 

at 9:30 a.m. AST.

7. 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; 

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

8. 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) 

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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 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/. 

9. 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. 

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

other relief as is just and proper. 

Dated: June 30, 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

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Exhibit A

Proposed Order

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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 

Through the Urgent Consensual Motion for Further Extension of Response Deadlines, dated 

June 30, 2023 (Docket Entry No. _____)

2

 (the “Extension Motion”),3 the Oversight Board requests 

the extension of briefing deadlines with respect to certain, but not all, of the Administrative 

Expense Motions with respect to which briefing deadlines were previously extended and a hearing 

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. 

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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 motions granted pursuant to, inter alia, Docket Entry No. 24400. 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 Motions (Extension Requested by Docket Entry No. _____) 

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 

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 

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 Administrative Expense Motions shall be extended 

to July 28, 2023 at 4:00 p.m. (Atlantic Standard Time). 

3. The deadline for the Movants to file a reply shall be extended to August 4, 2023

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

4. The hearing on the Administrative Expense Motions shall remain scheduled for 

the Omnibus Hearing scheduled for August 30, 2023, at 9:30 a.m. (Atlantic Standard Time). 

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5. This Order resolves Docket Entry No. _____ in Case No. 17-3283. 

SO ORDERED.

Dated: June ___, 2023 

 

LAURA TAYLOR SWAIN

United States District Judge

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