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. 21302

(Jointly Administered) 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al., 

Movants,

-againstRICOH PUERTO RICO INC. AND RAMHIL 

DEVELOPERS, INC.

Respondents.

SEVENTH URGENT CONSENSUAL MOTION FOR

EXTENSION OF DEADLINES AND ADJOURNMENT OF 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 Building Authority (“PBA”) (Bankruptcy 

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

limitations).

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

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

as sole Title III representative of the Commonwealth of Puerto Rico (the “Commonwealth”), the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”), 

and the Puerto Rico Public Buildings Authority (“PBA” and, collectively with the Commonwealth 

and ERS, the “Debtors”), pursuant to section 315(b) of the Puerto Rico Oversight, Management, 

and Economic Stability Act (“PROMESA”),2respectfully submits this seventh urgent consensual 

motion for entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed 

Order”), extending the deadlines and adjourning the hearing scheduled in the Order Granting the 

Sixth Urgent Consensual Motion for Extension of Deadlines and Adjournment of Hearing [Case 

No. 17-3283, ECF No. 21302]

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(the “Extension Order”) and states as follows:

Request for Relief

1. On November 21, 2021, the Oversight Board filed the Second Amended Plan 

Supplement and Plan Related Documents of the Commonwealth of Puerto Rico, et al. [ECF No. 

19326] (the “Second Amended Plan Supplement”).4 Attached to the Second Amended Plan 

Supplement as Exhibit E is a schedule of Executory Contracts and Unexpired Leases (the 

“Schedule”). Pursuant to Section 76.1 of the Plan, the Debtors intend to assume, as of the Effective 

Date of the Plan, the Executory Contracts and Unexpired Leases listed in the Schedule.

 

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

3 Unless otherwise stated, all ECF Nos. shall refer to the docket in Case No. 17-3283.

4 All capitalized terms used but not otherwise defined herein shall have the meanings given to them in the Modified 

Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, et al., dated January 14, 

2022 [ECF No. 19784] (as may be amended, modified, or supplemented, the “Plan”) or the Original Notice (as 

defined below), as applicable.

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2. On November 23, 2021, the Oversight Board filed the Notice of Executory 

Contracts and Unexpired Leases to be Assumed Pursuant to Title III Plan of Adjustment [Case 

No. 17-BK-3283-LTS, ECF No. 19353; Case No. 19-BK-05523-LTS, ECF No. 244; Case No. 17-

BK-03566-LTS, ECF No. 1272] (the “Original Notice”), which provided that the deadline for 

parties in interest to object to the proposed Cure Costs or the assumption of the Executory 

Contracts or Unexpired Leases was December 13, 2021, at 5:00 p.m. (prevailing Atlantic Standard 

Time) (the “Original Objection Deadline”).

3. On December 12, 2021, Ricoh Puerto Rico Inc. (“Ricoh”) filed the Ricoh Puerto 

Rico Inc.’s Motion Objecting Docket No. 19353 and Informing Cure Amounts for Executory 

Contracts or Unexpired Leases to be Assumed Pursuant to Title III Plan of Adjustment [ECF No. 

19498] (the “Ricoh Objection”).

4. On December 13, 2021, Orlando Santiago Amador (“Amador”) filed the Motion 

Objecting Docket No. 19353 and Informing Cure Amounts for Executory Contracts or Unexpired 

Leases to be Assumed with Servicentro Ciales, Inc. Pursuant to Title III Plan Of Adjustment [ECF 

No. 19501] (the “Amador Objection”), and FISA SE (“FISA”) filed the Objection to Cure Amount

[ECF No. 19505] (the “FISA Objection”).5

5. On January 18, 2022, Ramhil Developers, Inc. (“Ramhil”) filed Ramhil Developers 

Inc.’s Objection to Docket No. 19353 and Informing Cure Amounts for Executory Contracts or 

Unexpired Leases To Be Assumed Pursuant to Title III Plan of Adjustment [ECF No. 19807] (the 

 

5 On December 21, 2021, the Oversight Board also filed the Supplemental Notice Regarding Limited Extension of 

Time to Object to Executory Contracts and Unexpired Leases to be Assumed Pursuant to Title III Plan of 

Adjustment (the “Supplemental Notice”) [ECF No. 19585], to extend the Original Objection Deadline solely for 

certain counterparties to the Executory Contracts and Unexpired Leases listed on the schedule attached thereto as 

Exhibit A to January 10, 2022, at 5:00 p.m. (Atlantic Standard Time) (the “Extended Objection Deadline”). No 

objections were filed by the Extended Objection Deadline with respect to such Executory Contracts and Unexpired 

Leases.

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“Ramhil Objection,” and together with the Amador Objection, the FISA Objection, and the Ricoh 

Objection, the “Objections”).

6. The Oversight Board reached a resolution to the Amador Objection, as reflected in 

the revised Schedule filed with the Fourth Amended Plan Supplement and Plan Related 

Documents of the Commonwealth of Puerto Rico, et al. [ECF No. 20353]. Accordingly, the 

Amador Objection was withdrawn pursuant to the Joint Notice of Withdrawal of Motion Objecting 

Docket No. 19353 and Informing Cure Amounts for Executory Contracts or Unexpired Leases to 

Be Assumed with Servicentro Ciales, Inc. Pursuant to Title III Plan of Adjustment [ECF No. 

19501], dated March 16, 2022 [ECF No. 20372].

7. The Oversight Board also reached a resolution to the FISA Objection. Accordingly, 

the FISA Objection was withdrawn pursuant to the Motion to Withdraw FISA SE’s Objection to 

Cure Amount, dated April 21, 2022, [ECF No. 20583].

8. Pursuant to the Extension Order, dated June 22, 2022, the Ramhil Objection and 

Ricoh Objection will be heard at the August 17, 2022 omnibus hearing (the “Hearing”). 

9. The deadline for replies to the Ramhil Objection and Ricoh Objection is August 10, 

2022, at 4:00 p.m. (Atlantic Standard Time) (the “Reply Deadline”). Extension Order ¶ 2.

10. The Oversight Board is continuing to finalize its consensual resolution with respect 

to the Ramhil Objection. Furthermore, the Oversight Board is continuing the process of 

investigating and evaluating the claims set forth in the Ricoh Objection, and discussing the same 

with Ricoh, to seek consensual resolutions, if possible. Accordingly, the Oversight Board 

respectfully requests (a) an extension of the Reply Deadline with respect to the Ramhil Objection 

and the Ricoh Objection from August 10, 2022 to September 14, 2022 at 4:00 p.m. (Atlantic 

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Standard Time), and (b) adjournment of the Hearing to consider the Ramhil Objection and the 

Ricoh Objection from August 17, 2022 to the September 21, 2022 omnibus hearing. 

11. 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 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, good-faith communications 

in an effort to resolve or narrow the issues that are being brought to the Court, and Ricoh and 

Ramhil consent to the relief requested herein. 

Notice

12. 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 Commonwealth; (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) all parties filing a notice of appearance in these Title III cases; (j) Ricoh; and (k) Ramhil. A 

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

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

other or further notice need be given. 

 

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 Oversight Board requests the Court enter the Proposed Order and 

grant such other relief as is just and proper. 

Dated: August 8, 2022

San Juan, Puerto Rico

Respectfully submitted,

/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 as representative for the 

Debtors

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-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 

(Jointly Administered) 

ORDER GRANTING THE SEVENTH

URGENT CONSENSUAL MOTION FOR 

EXTENSION OF DEADLINES AND ADJOURNMENT OF HEARING

Upon the Seventh Urgent Consensual Motion for Extension of Deadlines and Adjournment 

of Hearing (ECF No. _____, the “Seventh Extension Motion”);2and the Court having found that 

the relief requested in the Seventh Extension Motion is in the best interests of the Oversight Board, 

Ricoh, and Ramhil; and the Court having found that the Oversight Board provided adequate and 

appropriate notice of the Seventh Extension Motion under the circumstances and that no other or 

further notice is required; and the Court having reviewed the Seventh Extension Motion; and the 

Court having determined that the factual bases set forth in the Seventh Extension Motion establish 

 

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 Building Authority (“PBA”) (Bankruptcy 

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

limitations).

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

Motion.

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just cause for the relief granted herein; and after due deliberation and sufficient cause appearing 

therefor, it is HEREBY ORDERED THAT:

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

2. Replies to the Ricoh Objection and Ramhil Objection, if any, must be filed by 

September 14, 2022, at 4:00 p.m. (Atlantic Standard Time). 

3. The Ricoh Objection and Ramhil Objection will be heard at the September 21, 

2022 omnibus hearing. 

4. This Order resolves Docket Entry No. _____ in Case No. 17-13283. 

SO ORDERED.

Dated: August _____, 2022

 

LAURA TAYLOR SWAIN

United States District Judge

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