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. 23222 and 23347

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

COMMONWEALTH OF PUERTO RICO,

Movant,

v.

BELFOR USA GROUP, INC., dba BELFOR 

PROPERTY RESTORATION,

Respondent.

URGENT CONSENSUAL MOTION FOR EXTENSION OF 

DEADLINES REGARDING BELFOR USA GROUP, INC., DBA

BELFOR PROPERTY RESTORATION’S MOTION FOR ALLOWANCE AND

PAYMENT OF ADMINISTRATIVE EXPENSE CLAIM IN THE SUM OF $71,760.95

 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 

(“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”) (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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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 representative of the Commonwealth of Puerto Rico (“Commonwealth” or the “Debtor”) 

in this Title III case pursuant to section 315(b) of the Puerto Rico Oversight, Management and 

Economic Stability Act (“PROMESA”),2 respectfully submits this urgent motion for an order 

extending the briefing schedule related to the Belfor USA Group, Inc., dba Belfor Property 

Restoration’s Motion for Allowance and Payment of Administrative Expense Claim in the Sum of 

$71,760.95 [ECF No. 23222] (the “Motion”) and represents as follows:

REQUEST FOR RELIEF

1. On January 10, 2023, Belfor USA Group, Inc., dba “Belfor Property Restoration”

(the “Movant”), filed the Motion, seeking payment of certain asserted administrative expenses, as 

described further in the Motion. 

2. On January 10, 2023, the Court entered the Order Scheduling Briefing of Belfor 

USA Group, Inc., dba Belfor Property Restoration’s Motion for Allowance and Payment of 

Administrative Expense Claim in the Sum of $71,760.95 [ECF No. 23233] (the “Scheduling 

Order”), which established a deadline of January 24, 2023 at 5:00 p.m. (AST) for the filing of any 

responsive papers (the “Objection Deadline”) and a deadline of January 31, 2023 at 5:00 p.m. 

(AST) for the filing of the Movant’s reply papers (the “Reply Deadline”), with the Motion to be 

taken under submission without a hearing.

3. On January 25, 2023 the Court entered an order [ECF No. 23347] granting the 

Debtor’s request for the extension of deadlines, establishing February 23, 2023 at 5:00 p.m. 

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

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(Atlantic Standard Time) as the Objection Deadline and March 2, 2023 at 5:00 p.m. (Atlantic 

Standard Time) as the Reply Deadline.

4. The Commonwealth continues to analyze its books and records in an attempt to 

reconcile the assertions in the Motion but has not completed its analysis. The Debtor therefore 

submits this Urgent Motion to request an extension of the Objection Deadline and Reply Deadline 

to permit the Commonwealth to complete its assessment. Movant has been informed of and has 

no objection to the extension requested herein. Accordingly, with the Movant’s consent, the 

Debtor respectfully requests that the Court enter an order, substantially in the form attached hereto 

as Exhibit A (the “Proposed Order”), extending the Objection Deadline and Reply Deadline to

March 23, 2023 at 5:00 p.m. (prevailing Atlantic Time), and March 30, 2023 at 5:00 p.m. 

(prevailing Atlantic Time), respectively. 

5. Pursuant to Paragraph I.H of the Sixteenth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 20190-1 in Case No. 17-3283] (the “Case Management 

Procedures”), the Debtor 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 no party opposes the relief requested herein.

NOTICE

6. The Commonwealth has provided notice of this Urgent 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 Puerto Rico Fiscal Agency and Financial Advisory 

Authority (AAFAF); (c) counsel for AAFAF; (d) counsel to the statutory committees appointed in 

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these Title III cases; (e) the entities on the list of creditors holding the 20 largest unsecured claims 

against COFINA; (f) all parties filing a notice of appearance in these Title III cases; and 

(g) Movant. A copy of the Urgent Motion is also available on the Commonwealth’s case website 

at https://cases.primeclerk.com/puertorico/.

7. The Debtor submits that, in light of the nature of the relief requested herein, no 

other or further notice need be given.

[Remainder of Page Left Intentionally Blank]

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WHEREFORE the Debtor requests the Court enter the Proposed Order and grant the 

Debtor such other relief as is deemed just and proper.

Dated: February 23, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Brian S. Rosen

Martin J. Bienenstock

Brian S. Rosen

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: mbienenstock@proskauer.com

 brosen@proskauer.com

Attorneys for the Financial Oversight and 

Management Board as representative for 

the Commonwealth

/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

Email: hermann.bauer@oneillborges.com

Co-Attorney for the Financial Oversight 

and Management Board as representative 

for the Commonwealth

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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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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)

Re: ECF Nos. 23222 and _____

[PROPOSED] ORDER GRANTING URGENT CONSENSUAL MOTION FOR 

EXTENSION OF DEADLINES REGARDING BELFOR USA GROUP, INC., DBA

BELFOR PROPERTY RESTORATION’S MOTION FOR ALLOWANCE AND

PAYMENT OF ADMINISTRATIVE EXPENSE CLAIM IN THE SUM OF $71,760.95

 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 (“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”) (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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Upon the Urgent Consensual Motion for Extension of Deadlines Regarding Belfor USA 

Group, Inc., dba Belfor Property Restoration’s Motion for Allowance and Payment of 

Administrative Expense Claim in the Sum of $71,760.95 (Docket Entry No. ____ in Case No. 17-

3283, the “Urgent Motion”);2 and the Court having found it has subject-matter jurisdiction over 

this matter pursuant to PROMESA section 306(a); and it appearing that venue in this district is 

proper pursuant to PROMESA section 307(a); and the Court having found the Debtor provided 

adequate and appropriate notice of the Urgent Motion under the circumstances and no other or 

further notice is required; and upon the record herein, after due deliberation thereon, the Court 

having found good and sufficient cause exists for the granting of the relief as set forth herein:

1. The Urgent Motion is GRANTED as set forth herein. 

2. The Scheduling Order shall be modified as provided herein.

3. The following briefing schedule is shall apply for filing responsive pleadings to 

the Motion:

• The deadline for parties to file an opposition to the Motion shall be March 23, 2023

at 5:00 p.m. (Atlantic Standard Time).

• The deadline for the Movant to file a reply to all oppositions and responses shall be

March 30, 2023 at 5:00 p.m. (Atlantic Standard Time).

4. The Court will thereafter take the Motion on submission.

5. The Court shall retain jurisdiction to hear and determine all matters arising from 

the implementation of this Order. 

 2 Capitalized terms not otherwise defined herein shall have the meanings given to them in the 

Urgent Motion.

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6. This Order resolves Docket Entry No. _____ in Case No. 17-3283.

Dated: ___________, 2023.

SO ORDERED:

_________________________________

 HONORABLE LAURA TAYLOR SWAIN

United States District Judge

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