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)

Motion to Withdraw - ECF no. 24318, Motion submitting Part of Exhibit II of BDO Puerto 

Rico, PSC’s (now known as, Old Puerto Rico, PSC) Response to 570th Omnibus Objection

THE HONORABLE COURT:

COMES NOW BDO Puerto Rico PSC (now known as, Old Puerto Rico, PSC) 

represented by the undersigned attorney and respectfully states:

1. Today, Creditor BDO Puerto Rico, PSC (now known as Old Puerto Rico, PSC) 

filed a Motion submitting Part of Exhibit II of BDO Puerto Rico, PSC’s (now known as, Old Puerto 

Rico, PSC) Response to 570th Omnibus Objection (ECF No. 24318).

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 (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) 

Puerto Rico Highways and Transportation Authority (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 

(Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); and (v) Puerto Rico Electric 

Power Authority (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).

Case:17-03283-LTS Doc#:24320 Filed:05/25/23 Entered:05/25/23 13:45:45 Desc: Main

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2. With said motion, OLD inadvertently attached the wrong exhibit. Therefore, OLD 

respectfully requests that its Motion submitting Part of Exhibit II of BDO Puerto Rico, PSC’s 

(now known as, Old Puerto Rico, PSC) Response to 570th Omnibus Objection filed today (ECF 

No. 24318), be withdrawn. 

3. OLD will file, subsequent to the instant motion, another motion with the correct 

exhibit which is Exhibit II pages 1-73 of ECF no. 24317.

WHEREFORE, the Creditor OLD respectfully requests that its Motion submitting Part of 

Exhibit II of BDO Puerto Rico, PSC’s (now known as, Old Puerto Rico, PSC) Response to 570th 

Omnibus Objection filed Today (ECF No. 24318), be withdrawn.

RESPECTFULLY SUBMITTED.

CERTIFICATE OF SERVICE: In accordance with Fed. R. Bankr. P. 9014(b), Fed. R. 

Bankr. P. 7004(b), and the Court’s Sixteenth Amended Notice, Case Management and 

Administrative Procedures Order (Dkt. No. 20190-1) (the “CMP Order”), I hereby certify that a 

true and exact copy of the foregoing was sent by electronic mail upon all the parties listed in the 

Master Service List and to all the Standard Parties listed in the CMP Order.

 In Guaynabo, Puerto Rico, on May 25, 2023. 

Juan R. Rivera Font, LLC

27 González Giusti 

Ave.

Suite 602

Guaynabo, PR 00968

Tel: 787-250-8040

s/Juan R. Rivera Font

Juan R. Rivera-Font, Esq.

USDC-PR 221703

 juan@riverafont.com

Case:17-03283-LTS Doc#:24320 Filed:05/25/23 Entered:05/25/23 13:45:45 Desc: Main

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