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 SECOND UNCONTESTED URGENT MOTION TO 

EXTEND DEADLINE TO FILE A RESPONSE TO THE 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 second 

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

response to 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”). See 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

was originally set for May 22, 2023. See Id. at 1. 

4. However, on May 19, 2023, DCI filed an uncontested motion to extend the 

deadline for DCI to file a response to the Five Hundred Sixty-Ninth Omnibus Objection. See 

Dkt. No. 24272. 

5. On May 22, 2023, the Court entered an Order granting DCI’s request for 

extension. See Dkt. No. 24282. As a result, DCI’s response is now due today, June 22, 2023 (the 

“Response Deadline”). See Id.

RELIEF REQUESTED

1. Although the undersigned counsel have diligently employed significant efforts to 

familiarize themselves with the Proof of Claim and to prepare an adequate response to the Five 

Hundred Seventieth Omnibus Objection; additional time is necessary to finalize these tasks. 

2. Counsel for DCI met and conferred with counsel for Debtors today, June 22, 2023,

to inform that it would be filing the instant Second Urgent Motion requesting an additional 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 an additional

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

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

July 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 

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 June 22, 2023, who informed that they did not have 

an objection to DCI’s additional 30-day extension request.

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 an additional 30-day extension, 

until July 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 22nd day of June 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

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Tel: 787-250-5619

Fax: 787-759-9225

By: /s/ Antonio A. Arias

 Antonio A. Arias

 USDC No. 204906

 E-mail: aaa@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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