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. 2245, 2585, 2652

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO,

Debtor.

PROMESA

Title III

No. 17 BK 3283-LTS

This Notice relates only to the 

Commonwealth and shall only be 

filed in the lead Case No. 17 BK 

3283-LTS

NOTICE OF FILING REVISED PROPOSED ORDER RESOLVING MOTION FOR 

AN ORDER TO PERMIT THE PROCESSING THROUGH RESOLUTION OF

EMPLOYMENT ARBITRATION AND GRIEVANCE PROCEEDINGS

PLEASE TAKE NOTICE that on January 16, 2018, the American Federation of State, 

County and Municipal Employees International Union, AFL-CIO and the American Federation of 

 

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); and (v) Puerto Rico Electric Power Authority (“PREPA”) (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).

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Teachers, AFL-CIO, on behalf of themselves, their local affiliates in Puerto Rico and their 

members (collectively, the “Unions”), filed the Joint Motion of American Federation of State, 

County and Municipal Employees, AFL-CIO and American Federation of Teachers, AFL-CIO, for 

an Order to Permit the Processing Through Resolution of Employment Arbitration and Grievance 

Proceedings [ECF No. 2245] (the “Motion”), requesting entry of an order allowing prepetition 

grievances and arbitrations to proceed through the claim and grievance handling process, or, 

alternatively, lifting the automatic stay as to discharge and disciplinary matters so that urgent 

matters may proceed in the normal course through resolution.

PLEASE TAKE FURTHER NOTICE that on February 23, 2018, the Commonwealth of 

Puerto Rico (the “Commonwealth”) filed the Response of the Commonwealth of Puerto Rico to 

the CBA Counterparties’ Motion for an Order to Permit the Processing Through Resolution of 

Employment Arbitration and Grievance Proceedings [ECF No. 2585] (the “Response”).

PLEASE TAKE FURTHER NOTICE that on March 2, 2018, the Unions filed the Reply 

in Further Support of Joint Motion of American Federation of State, County and Municipal 

Employees, AFL-CIO and American Federation of Teachers, AFL-CIO for an Order to Permit the 

Processing Through Resolution of Employment Arbitration and Grievance Proceedings [ECF No. 

2652] (the “Reply”).

PLEASE TAKE FURTHER NOTICE that the Commonwealth and the Unions have met 

and conferred and have successfully resolved the Motion, Response, and Reply pursuant to the 

terms set forth in the Stipulation Between the Commonwealth of Puerto Rico and CBA 

Counterparties Regarding Certain Grievance and Arbitration Procedures (the “Stipulation”).

2

 

2 As of the filing of this Notice, the Service Employees International Union and International Union and the United 

Automobile, Aerospace and Agricultural Implement Workers of America (UAW) (collectively, the “Non-Moving

Parties”) have not agreed to the terms of the Stipulation. Because the Motion was filed only by the Unions and

the parties have resolved the relief requested in the Motion pursuant to the Stipulation, the Commonwealth asserts

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PLEASE TAKE FURTHER NOTICE that attached hereto as Exhibit A is a revised 

proposed order (the “Revised Proposed Order”), resolving the Motion and approving the 

Stipulation attached thereto as Exhibit 1.

PLEASE TAKE FURTHER NOTICE that copies of the Motion, the Revised Proposed

Order, the Stipulation, and all other documents filed in these Title III Cases are available (a) free 

of charge by visiting https://cases.primeclerk.com/puertorico or by calling +1 (844) 822-9231, and 

(b) on the Court’s website at http://www.prd.uscourts.gov, subject to the procedures and fees set 

forth therein.3

PLEASE TAKE FURTHER NOTICE that the Unions and the Commonwealth 

respectfully request that the Court consider and enter the attached Revised Proposed Order 

granting the relief requested therein. 

Remainder of Page Intentionally Left Blank

 

that the Non-Moving Parties’ (i) Joinder of Service Employees International Union and International Union,

United Automobile, Aerospace and Agricultural Implement Workers of America (UAW) to Joint Motion of 

American Federation of State, County and Municipal Employees, AFL-CIO, and American Federation Of 

Teachers, AFL-CIO, for an Order to Permit the Processing Through Resolution of Employment Arbitration and 

Grievance Proceedings [ECF No. 2249] and (ii) Reply Memorandum of Service Employees International Union 

and International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW) 

in Support of Motion for an Order to Permit the Processing Through Resolution of Employment Arbitration and 

Grievance Proceedings [ECF No. 2650] are moot and need not be considered at the hearing scheduled for March 

7, 2018 at 9:30 a.m. (Atlantic Standard Time). 

3 The Financial Oversight and Management Board for Puerto Rico, as the Debtors’ representative pursuant to 

section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act, has authorized the Puerto 

Rico Fiscal Agency and Financial Advisory Authority to file this Notice on behalf of the Commonwealth. 

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Dated: March 6, 2018

New York, New York

Respectfully submitted, 

/s/ Peter Friedman

John Rapisardi

Suzzanne Uhland 

Peter Friedman

Diana M. Perez

(Admitted Pro Hac Vice) 

O’MELVENY & MYERS LLP

7 Times Square

New York, NY 10036

Tel: (212) 326-2000

Fax: (212) 326-2061

Attorneys for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority 

/s/ Mohammad S. Yassin

Mohammad S. Yassin

USDC-PR Bar No. 302909

PUERTO RICO FISCAL AGENCY AND 

FINANCIAL ADVISORY AUTHORITY

Robert Sánchez Vilella (Minillas)

Government Center

De Diego Avenue, Stop 22

San Juan, Puerto Rico 00907

Tel: (787) 722-2525

Fax: (787) 721-1443

Chief Legal & Regulatory Officer 

/s/ José Luis Barrios-Ramos

José Luis Barrios-Ramos, Esq.

McLeary Ave., Suite #303

San Juan, Puerto Rico 00936-8006

Tel.: (787) 593-6641

Barrios.jl@outlook.com

and

/s/ Curtis C. Mechling

Curtis C. Mechling

Sherry J. Millman

Stroock & Stroock & Lavan LLP

180 Maiden Lane, New York, NY 10038

(212) 806-5434

smillman@stroock.com

For American Federation of Teachers,

AFL-CIO, as authorized agent for the

Asociación de Maestros de Puerto

Rico-Local Sindical

/s/ Sharon L. Levine

Sharon L. Levine

Dipesh Patel

Saul Ewing LLP

1037 Raymond Blvd.

Suite 1520

Newark, NJ 07102

(973) 286-6713

slevine@saul.com

For the American Federation of State,

County and Municipal Employees

Judith Rivlin

Teague P. Paterson

Matthew S. Blumin

American Federation of State, County and 

Municipal Employees

1101 17th Street NW, Suite 900

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Washington, DC 20011

(202) 775-5900

For the American Federation of State,

County and Municipal Employees

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