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. 24683, 24685

(Jointly Administered)

URGENT CONSENSUAL MOTION FOR EXTENSION OF DEADLINES

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

The Commonwealth of Puerto Rico (the “Commonwealth”) respectfully submits this 

urgent consensual motion (the “Urgent Motion”) for entry of an order, substantially in the form 

attached hereto as Exhibit A (the “Proposed Order”), extending the deadlines set forth in the Order 

Scheduling Briefing of Motion Requesting Order to Compel [ECF No. 24685] (the “Scheduling 

Order”).2

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-BK3567-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).

2

 The Financial Oversight and Management Board for Puerto Rico, as the Commonwealth’s representative pursuant 

to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), has 

authorized the Department of Justice to file this Urgent Motion on behalf of the Commonwealth.

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Request for Relief

1. On June 28, 2023, Rose M. Flores-Perez (“Movant”) filed a Motion Requesting 

Order to Compel [ECF No. 21912] (the “Motion”), requesting this Court “issue an order directing 

the Commonwealth to comply with the order and return the vehicle, or its appraisal value to 

movant,” in connection with a case filed by Movant under the Uniform Forfeiture Act of 2011 in 

the Trial Court of Puerto Rico, Civil Case No. ISCI2012-00496. See Motion at 3. 

2. Also on June 28, 2023, the Court entered the Scheduling Order, which provides that 

responses to the Motion must be filed by July 12, 2023 at 5:00 PM (AST), and Movant’s reply by 

July 19, 2023 at 5:00 PM (AST).

3. The Commonwealth is gathering the relevant information necessary to evaluate the 

allegations and relief requested in the Motion and to determine whether a consensual resolution is 

possible. Accordingly, the Commonwealth, with Movant’s consent, proposes the following 

extensions of the deadlines set forth in the Scheduling Order: 

• The deadline to respond to the Motion shall be extended to August 2, 2023. 

• The deadline for Movant to file a reply to a response, if any, shall be extended to

August 9, 2023.

• The Court will thereafter take the Motion on submission, unless the Court determines 

that a hearing is necessary.

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

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

Commonwealth 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 without a hearing; has made reasonable, goodCase:17-03283-LTS Doc#:24723 Filed:07/12/23 Entered:07/12/23 14:14:30 Desc: Main

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faith communications in an effort to resolve or narrow the issues that are being brought to the 

Court, and Movant consents to the request in this urgent motion.

Notice

5. The Commonwealth has provided notice of this 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 indenture trustees and/or agents, as applicable, for the Debtors’ 

bonds; (c) the entities on the list of creditors holding the 20 largest unsecured claims against 

COFINA; (d) counsel to the statutory committees appointed in these Title III cases; (e) the Office 

of the United States Attorney for the District of Puerto Rico; (f) counsel to the Oversight Board; 

(g) the Puerto Rico Department of Justice; (h) all parties filing a notice of appearance in these Title 

III cases; and (i) Movant. A copy of the motion is also available on the Commonwealth’s case 

website at: https://cases.ra.kroll.com/puertorico/.

6. The Commonwealth submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

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

such other relief as is just and proper. 

Dated: July 12, 2023

San Juan, Puerto Rico 

Respectfully submitted,

DOMINGO EMANUELLI HERNÁNDEZ

Secretary of Justice 

/s/ Susana I. Peñagarícano Brown

SUSANA I. PEÑAGARICANO BROWN

USDC No. 219907 

Deputy Secretary in Charge of Litigation 

Department of Justice 

P.O. Box 9020192 

San Juan, Puerto Rico 00902-0192 

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Phone: 787-721-2900 Ext. 1404 

spenagaricano@justicia.pr.gov

Attorney for the Commonwealth of Puerto 

Rico

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Exhibit A

Proposed Order

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