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) 

Re: ECF Nos. 18602, 21005, 21006, 

22093 

URGENT MOTION FOR EXTENSION OF DEADLINE 

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

COMES NOW, Community Health Foundation of P.R. Inc. (hereinafter “Movant”), 

through the undersigned attorney and very respectfully submits this urgent consensual motion for 

entry of an order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), 

extending the dates and deadlines established in the Order Granting Urgent Consensual Motion 

for Extension of Deadlines [ECF No. 21782] (the “Scheduling Order”), and states as follows:

Request for Relief 

1. On October 19, 2021, Community Health Foundation of P.R. Inc. (“Movant”) filed 

the Community Health Foundation of P.R. Inc.’s Motion for Allowance and Payment 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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Administrative Expense [ECF No. 18602] (the “Administrative Expense Motion”) seeking, 

among other things, (i) allowance and payment of certain post-petition wraparound 

payments and (ii) an order requiring the Commonwealth to prospectively make all 

wraparound payments to Movant. 

2. The Administrative Expense Motion requested a hearing for the Court to consider 

the Administrative Expense Motion (the “Hearing”) to be scheduled for December 15, 

2021, at 9:30 a.m. (A.S.T.) and established the deadline to object to the Administrative 

Expense Motion (“Objection Deadline”) for November 30, 2021, at 4:00 p.m. (A.S.T.). 

3. Thereafter, with Movant’s consent, the Financial Oversight and Management 

Board for Puerto Rico (the “Oversight Board”) moved for several extensions of the 

deadlines set forth above to, among other things, allow Movant to furnish to the Oversight 

Board certain requested documentation in support of its claim and for the Oversight Board 

to evaluate said documentation and investigate the claim. 

4. On April 13, 2022, upon the motion of the Oversight Board requesting an extension 

of the schedule proposed in the Administrative Expense Motion [ECF No. 20556], the 

Court entered an Order (the “Order”), pursuant to which it set the Objection Deadline for 

May 25, 2022, at 4:00 p.m. (A.S.T.) and the deadline for Movant’s reply papers (the “Reply 

Deadline”), if any, for June 8, 2022, at 4:00 p.m. (A.S.T.). The Hearing was scheduled for 

the June 29, 2022, omnibus hearing. See Order Granting Urgent Consensual Motion 

Seeking Adjournment of Hearing [ECF No. 20568] ¶ 2. 

5. On May 25, 2022, the Oversight Board filed the Objection of the Financial 

Oversight and Management Board for Puerto Rico to the Motion of Community Health 

Foundation of P.R. Inc. for Allowance and Payment of Administrative Expense [ECF No. 

21005] (the “Objection”) and a separate supporting Declaration of Felmarie Cruz Morales 

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in Respect of Objection of the Financial Oversight and Management Board for Puerto Rico 

[ECF No. 21006] (the “Cruz Declaration”). 

6. On June 6, 2022, upon the motion of Movant requesting an extension of the 

schedule proposed in the Order [ECF No. 21110], the Court entered the Scheduling Order 

(the “Extension Order”), which set the Reply Deadline for July 8, 2022, at 4:00 p.m. 

(A.S.T.) and scheduled the Hearing on the Administrative Expense Motion for the August 

10, 2022, omnibus hearing. See Order Granting Urgent Consensual Motion for Extension 

of Deadlines [ECF No. 21116], ¶¶ 2 and 3. 

7. On July 7, 2022, upon the motion of Movant requesting an extension of the 

schedule proposed in the Extension Order [ECF No. 21456], the Court entered the 

Scheduling Order (the “Second Extension Order”), which set the Reply Deadline for 

August 8, 2022, at 4:00 p.m. (A.S.T.) and scheduled the Hearing on the Administrative 

Expense Motion for the September 21, 2022, omnibus hearing. See Order Granting Urgent 

Consensual Motion for Extension of Deadlines [ECF No. 21461], ¶¶ 2 and 3. 

8. On August 8, 2022, upon the motion of Movant requesting an extension of the 

schedule proposed in the Second Extension Order [ECF No. 21750], the Court entered the 

Scheduling Order (the “Third Extension Order”), which set the Reply Deadline for 

September 7, 2022, at 4:00 p.m. (A.S.T.) and scheduled the Hearing on the Administrative 

Expense Motion for the November 2, 2022, omnibus hearing. See Order Granting Urgent 

Consensual Motion for Extension of Deadlines [ECF No. 21782], ¶¶ 2 and 3. 

9. On September 7, 2022, upon the motion of Movant requesting an extension of the 

schedule proposed in the Third Extension Order [ECF No. 22084], the Court entered the 

Scheduling Order (the “Fourth Extension Order”), which set the Reply Deadline for 

September 21, 2022, at 4:00 p.m. (A.S.T.) and maintained the Hearing on the 

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Administrative Expense Motion as scheduled for the November 2, 2022, omnibus hearing. 

See Order Granting Urgent Consensual Motion for Extension of Deadlines [ECF No. 

22093], ¶¶ 2 and 3. 

10. Movant is in the process of finalizing the Reply with its supporting documentation 

and statements but requires additional time to finalize and file the Reply. Due to the 

aftermath of Hurricane Fiona, the undersigned has had difficulties communicating with the 

client to finalize the supporting statements and the undersigned’s office operations have 

been affected by the lack of electrical power. 

11. Accordingly, Movant respectfully requests an extension of 7 days, or until 

September 28, 2022, to file the Reply. The Hearing on the Administrative Expense Motion 

will remain as scheduled for the November 2, 2022, omnibus hearing, at 9:30 a.m. A.S.T. 

The undersigned was not able to procure the Oversight Board’s consent to this 

extension until today at about 3:15 P.M. and has yet to receive a response. 

12. Pursuant to Paragraph 1.H of the Sixteenth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 20190-1] (the “Case Management Procedures”), 

Movant 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, goodfaith communications in an effort to resolve or narrow the issues that are being brought to 

the Court, and the Oversight Board consents to the relief. 

WHEREFORE, Community Health Foundation of P.R. Inc. respectfully requests the Court 

to enter the Proposed Order and to grant any further relief as is just and proper. 

RESPECTFULLY SUBMITTED. 

In San Juan, Puerto Rico, on this 21st day of September 2022. 

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CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that on this date, I electronically filed the foregoing with the Clerk 

of the Court using the CM/ECF system, which will notify all parties registered through their 

attorneys of record, including the Standard Parties and the Affected Parties; and have served a 

copy of the foregoing to the U.S. Trustee by U.S. mail. 

CORDOVA-AYUSO LAW OFFICE LLC 

P.O. BOX 194021 

SAN JUAN, PR 00919-4021 

TEL.: (787) 230-0463 

EMAIL: lac@calawpr.com 

/s/ Lucas A. Córdova-Ayuso 

Lucas A. Córdova-Ayuso, Esq. 

USDC-PR No. 226805 

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Exhibit A 

Proposed Order 

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