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

No. 17 BK 3283-LTS

(Jointly Administered)

Re: ECF Nos. 24103, 23621, 

23612, and 21326.

This filing relates only to HTA

MOTION OF THE PUERTO RICO HIGHWAYS AND TRANSPORTATION 

AUTHORITY FOR LEAVE TO SUBMIT A SPANISH LANGUAGE EXHIBIT AND 

FOR EXTENSION OF TIME TO FILE A CERTIFIED TRANSLATION

To the Honorable United States District Judge Laura Taylor Swain:

The Puerto Rico Highways and Transportation Authority (“HTA”), by and through the 

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

representative of HTA pursuant to section 315(b) of the Puerto Rico Oversight, Management, and 

Economic Stability Act (“PROMESA”)2, hereby submits this motion requesting the entry of an 

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 (the “Commonwealth”) (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”, and together with the Commonwealth, 

COFINA, HTA, ERS, and PREPA, the “Debtors”) (Bankruptcy Case No. 19-BK-5523-LTS) (Last 

Four Digits of Federal Tax ID: 3801) (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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order, substantially in the form of Exhibit A hereto (the “Proposed Order”), granting HTA leave 

to submit a Spanish-language exhibit in connection with the Objection (as defined below) being 

filed today and an extension of time to file a certified English-language translation, and in support 

thereof, respectfully alleges and prays as follows: 

1. Today, HTA filed The Puerto Rico Highways and Transportation Authority’s 

(1) Opposition to (A) Motion Requesting Payment of Severance Damages [ECF No. 23612], and 

(B) Amended Petition Requesting Payment of Severance Damages [ECF No. 24103], and (2) Reply 

to Response Filed by Claimant Adrían Mercado Jiménez [Ecf No. 21326] in Connection with the 

Four Hundred Fifty-Fourth Omnibus Objection (Non-Substantive) to Satisfied Claims (the 

“Objection”).

2. In support of the arguments in the Objection, HTA attached as Exhibit 2 thereto the 

Judgment dated May 31, 2019, issued by the Commonwealth Court of Appeals in connection with 

Case K EF2011-0240, which is in its original Spanish language (the “Judgment”). 

3. Despite diligent efforts, HTA was unable to obtain a certified English-language 

translation of the Judgment from its original Spanish language prior to today’s filing. Accordingly, 

HTA seeks leave from this Court to submit the Judgment in its original Spanish language and 

requests an extension of 3 business days, to and including May 10, 2023, to file a certified Englishlanguage translation of the Judgment pursuant to Local District Court Rule 5(g).

[Remainder of Page Intentionally Left Blank]

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WHEREFORE, HTA respectfully requests the Court enter the Proposed Order, attached 

hereto as Exhibit A, permitting it to file the judgments in its original Spanish language, granting 

it until May 10, 2023 to submit a certified English-language translation of the Judgment, and 

granting such other and further relief as is just and proper. 

Dated: May 5, 2023 Respectfully submitted,

San Juan, Puerto Rico

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla García-Benítez

USDC No. 203708

Gabriel A. Miranda

USDC No. 306704

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice)

Brian S. Rosen (pro hac vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial 

Oversight and Management Board 

for Puerto Rico, as representative of 

the Puerto Rico Highways and 

Transportation Authority 

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Exhibit A

Proposed Order

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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

No. 17 BK 3283-LTS

(Jointly Administered)

Re: ECF Nos. 24103, 23621, 

23612, and 21326.

This filing relates only to HTA

[PROPOSED] ORDER ON MOTION OF THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY FOR LEAVE TO SUBMIT A SPANISH 

LANGUAGE EXHIBIT AND FOR EXTENSION OF TIME TO FILE A CERTIFIED 

TRANSLATION

Upon consideration of the Motion of the Puerto Rico Highways and Transportation 

Authority for Leave to Submit a Spanish Language Exhibit and for Extension of Time to File a 

Certified Translation (the “Motion”), filed by the Puerto Rico Highways and Transportation 

Authority (“HTA”), by and through the Financial Oversight and Management Board for Puerto 

Rico (the “Oversight Board”), as sole representative of HTA pursuant to section 315(b) of 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 (the “Commonwealth”) (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”, and together with 

the Commonwealth, COFINA, HTA, ERS, and PREPA, the “Debtors”) (Bankruptcy Case No. 19-

BK-5523-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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Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”)2, and dated May 

5, 2023, for an order granting HTA leave to submit a Spanish-language version of a Judgment 

issued by the Commonwealth Court of Appeals dated May 31, 2019, which is in its original 

Spanish language (the “Judgment”), as Exhibit 2 to the Objection, and an extension of 3 business 

days, to and including May 10, 2023, to file a certified English translation of the Judgment, as 

more fully set forth in the Motion; and the Court having jurisdiction to consider the Motion and to 

grant the relief requested therein pursuant to PROMESA section 306(a); and venue being proper 

pursuant to PROMESA section 307(a); and notice of the Motion was adequate and proper under 

the circumstances, and no other or further notice being required; and finding good cause for the 

requested relief, it is hereby ORDERED that:

1. The Motion is GRANTED as set forth herein.

2. HTA is permitted to file a Spanish-language version of the Judgment.

3. HTA’s certified English-language translation of the Judgment shall be due on or 

before May 10, 2023.

4. The Court retains exclusive jurisdiction to hear and determine any and all disputes 

related to or arising from the implementation, interpretation and enforcement of this Order.

Dated: _________________________

___________________________

LAURA TAYLOR SWAIN 

United States District Judge 

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

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CERTIFICATE OF SERVICE

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 notifications of such filing to all CM/ECF 

participants in this case.

/s/ Hermann D. Bauer

Hermann D. Bauer

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