UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO,

As representative of

THE COMMONWEALTH OF PUERTO 

RICO, et al.,

Debtors1

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 24050

 

DANOSA CARIBBEAN INC.’S UNCONTESTED URGENT MOTION TO EXTEND 

DEADLINE TO FILE A RESPONSE TO THE FIVE HUNDRED SEVENTIETH

OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO 

RICO, THE EMPLOYEES RETIREMENT SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO, THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY, AND PUERTO RICO PUBLIC BUILDINGS 

AUTHORITY TO CLAIMS FOR WHICH THE DEBTORS ARE NOT LIABLE

COMES NOW, Danosa Caribbean Inc. (“DCI”), by and through the undersigned legal 

counsel, and after meeting and conferring with Debtors’ counsel respectfully submits this urgent 

uncontested motion (the “Urgent Motion”) to extend the deadline for DCI to file a response to the 

Five Hundred Seventieth Omnibus Objection (Substantive) Of The Commonwealth Of Puerto 

Rico, The Employees Retirement System Of The Government Of The Commonwealth Of Puerto 

Rico, The Puerto Rico Highways And Transportation Authority, And Puerto Rico Public 

Buildings Authority To Claims For Which The Debtors Are Not Liable (the “Five Hundred 

Seventieth Omnibus Objection”). Dkt. No. 24050.

1 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number listed as a bankruptcy 

case number due to software limitations and the last four (4) digits of each Debtor’s federal tax identification number, 

as applicable, are the (i) Commonwealth of Puerto Rico (the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283 

(LTS)) (Last Four Digits of Federal Tax ID: 3481), (ii) 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), (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567 

(LTS)) (Last Four Digits of Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) 

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

Power Authority (“PREPA”) (Bankruptcy Case No. 17-4780 (LTS)) (Last Four Digits of Federal Tax ID: 3747); and 

(vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of 

Federal Tax ID: 3801).

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BACKGROUND

1. DCI filed its Proof of Claim asserting the amount of $108,926.02 on June 27, 2018

(the “Proof of Claim”). See Claim Number 56478. 

2. On April 20, 2023, Debtors filed the Five Hundred Seventieth Omnibus Objection

requesting the disallowance of DCI’s Proof of Claim. See Dkt. No. 24050.

3. DCI’s deadline to respond to the Five Hundred Sixty-Ninth Omnibus Objection is 

due on Monday, May 22, 2023 (the “Response Deadline”). See Id. at 1. 

RELIEF REQUESTED

1. The undersigned was recently engaged by DCI to represent them in connection 

with the Five Hundred Seventieth Omnibus Objection. Because of this, sufficient time is 

required by counsel to familiarize themselves with the Proof of Claim and to prepare an adequate 

response to the Five Hundred Seventieth Omnibus Objection. 

2. Counsel for DCI met and conferred with counsel for Debtors today, May 19, 2023,

to inform that it would be filing the instant Urgent Motion requesting a 30-day extension to file 

a response to the Five Hundred Seventieth Omnibus Objection and to ascertain whether they had 

an objection to said request. Debtors counsel informed that they did not.

3. DCI respectfully requests, on an urgent basis, that the Court grant it a 30-day 

extension to file its response to the Five Hundred Seventieth Omnibus Objection, which 

extension shall commence from the Response Deadline of May 22, 2023, and would be due on 

June 22, 2023.

COMPLIANCE WITH CASE MANAGEMENT PROCEDURES

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

and Administrative Procedures Order (Docket No. 20190-2 of Case No. 17-03283 (LTS)) (the 

“CMP Order”), DCI hereby certifies that it has (a) carefully examined the matter and concluded 

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that there is a true need for an urgent decision; (b) not created the urgency through any lack of 

due diligence; and (c) reasonable, good-faith communications took place with the parties to this 

adversary proceeding to resolve or narrow the issues before the Court. Specifically, counsel for 

DCI reached out to counsel for Debtors on May 19, 2023, who informed that they did not have 

an objection to DCI’s 30-day extension request. In addition, DCI certifies that no prior request 

for the relief sought herein has been made.

WHEREFORE, DCI hereby requests, on an urgent basis, that the Court (i) enter an order 

substantially in the form attached hereto as Exhibit A granting it a 30-day extension, until June

22, 2023, to file its response to Five Hundred Seventieth Omnibus Objection; and (ii) enter any 

other relief that is just or appropriate given the circumstances. 

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 19

th day of May 2023.

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

Bankr. P. 7004(b), and the Court’s CMP Order, we 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 

by U.S. mail upon all the Standard Parties listed in the CMP Order.

MCCONNELL VALDÉS LLC

270 Muñoz Rivera Avenue, Suite 7

Hato Rey, Puerto Rico 00918

P.O. Box 364225

San Juan, PR 00936-4225

Tel: 787-250-5619

Fax: 787-759-9225

By: /s/ Nayuan Zouairabani Trinidad

 Nayuan Zouairabani Trinidad

 USDC No. 226411

 E-mail: nzt@mcvpr.com

By: /s/ Victoria Rivera Lloréns

 Victoria Rivera Llorens

 USDC No. 307808

 E-mail: vrll@mcvpr.com

Attorneys for Danosa Caribbean Inc.

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