UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO 

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In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

 Debtors.1

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PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 663, 674, 858, 1039, 

1310, 1540, 2243, 2244

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of 

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”)

 Debtor.

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PROMESA

Title III

No. 17 BK 3567-LTS

This Motion relates only to HTA

and shall be filed in the lead Case 

No. 17 BK 3283-LTS and Case No. 

17 BK 3567-LTS. 

FOURTH JOINT NOTICE AND STIPULATION 

AMENDING DEADLINES CONCERNING THE REQUEST FOR

RELIEF OF STAY FILED BY HTA MANAGERIAL EMPLOYEES

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

COME NOW, the Managerial Employees of the Puerto Rico Highway and Transportation 

Authority (‘ME-PRHTA”) listed in Exhibit I of the Motion Requesting Relief From Stay [ECF 

 

1 The Debtors in these Title III Cases, along with each Debtor’s respective bankruptcy 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) 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); (iv) Puerto 

Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) (Last Four 

Digits of Federal Tax ID: 3808); and (iv) 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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No. 663] (the “Stay Motion”), hereinafter designated as the “Movants,” and the Puerto Rico 

Highway and Transportation Authority (“PRHTA”), through their respective counsel and 

respectfully state and pray: 

1. On July 19, 2017, the Movants filed the Stay Motion, pursuant to Bankruptcy Code 

section 362(d)(1), requesting this Honorable Court lift the automatic stay under Bankruptcy Code 

section 362(a), made applicable by PROMESA section 301(a) (the “Title III Stay”), of the legal 

proceedings concerning employment claims filed and prosecuted against PRHTA by Movants 

before different Commonwealth judicial and administrative forums. See ECF No. 663. 

2. On August 2, 2017, AAFAF, on behalf of PRHTA, filed an objection to the Stay 

Motion [ECF No. 858] (the “Objection”). In the Objection, AAFAF argued, among other things, 

that it needed additional time to evaluate Movants’ claims in the overall context of PRHTA’s Title 

III case. It also pointed to Movants’ failure to provide information about the status and stage of 

each of the one hundred and fifteen (115) employment claims prosecuted by them, which have 

been stayed upon the commencement of PRHTA’s Title III case. 

3. As set forth in the Joint Motion and Stipulations Concerning the Request for Relief 

of Stay Filed by the movants ME-HTA [ECF No. 1032] (the “Joint Motion”) filed on August 15, 

2017, Movants and PRHTA reached an agreement to adopt a process that would allow PRHTA to 

receive particularized information on each of the claims involved in the Stay Motion and for both 

parties to conduct discussions in an effort to reach agreements regarding Movants’ request for 

relief from the stay. On August 15, 2017, this Honorable Court entered the Order Granting Joint 

Motion and Stipulations Concerning the Request For Relief of Stay Filed by movants ME-HTA 

[ECF No. 1039] (the “Order”) granting the Joint Motion and adopting the stipulations of the parties 

set forth therein. 

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4. Due to the circumstances caused by the close passage to Puerto Rico of Hurricane 

Irma on September 6, 2017, the parties filed a Joint Notice Extending and Stipulations Amending 

Deadlines Agreed at Docket 1032 Concerning the Request for Relief of Stay Filed by HTA

Managerial Employees [ECF No. 1303] (the “First Extension Notice”), which requested an 

extension of the deadlines set forth in the Order. On September 15, 2017, the Court entered an 

order approving the agreed-upon extensions set forth in the First Extension Notice [ECF No. 1310] 

(the “First Extension Order”). 

5. Shortly after entry of the First Extension Order, on September 20, 2017, Hurricane 

Maria —the fifth strongest hurricane to ever hit the United States— made landfall in Puerto Rico. 

Due to the circumstances that arose in Puerto Rico after the passage of Hurricane Irma and 

Hurricane Maria, the parties agreed to extend the deadlines set forth in the First Extension Order, 

and extend the period during which the Stay Motion, as well as the Objection filed by PRHTA, 

are held in abeyance. See ECF No. 1517. 

6. On October 26, 2017, the Court entered the Order Approving Second Joint Notice 

and Stipulation Amending Deadlines Agreed [ECF No. 1303] Concerning the Request for Relief 

of Stay Filed by HTA Managerial Employees [ECF No. 1540] (the “Second Extension Order”). 

7. On November 30, 2017, Movants furnished information regarding the relevant 

claims to PRHTA. However, due to the lingering effects from Hurricane Maria, PRHTA required

additional time to complete its due diligence on Movants’ individual claims, which must be 

finished before PRHTA can assess each request for relief from the Title III Stay. To that effect on 

January 16, 2018, the parties jointly filed their “Third Joint Notice and Stipulation Amending 

Deadlines Concerning the Request for Relief of Stay Filed by HTA Managerial Employees”. See 

ECF No. 2243. This petition was granted by the Court on January 17, 2018. See ECF No. 2244. 

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8. Notwithstanding the above, the time previously requested and diligently provided 

by this Court, proved insufficient to complete the pending tasks. After the recent withdrawal of 

the HTA’s attorney that was handling the matter, the undersigned has been requested by HTA to 

assume its legal representation and conclude the required due diligence without further petitions 

of time, other than the one at hand. The undersigned attorneys have dialogued and agreed on a 

schedule to comply with the extended term herein requested. In consideration of this, the parties 

have agreed to request an amendment of the Third Extension Order to further extend the deadlines 

set forth therein, and request the Court to further extend the period during which the Stay Motion 

and Objection are held in abeyance. 

9. The new deadlines agreed to by the parties are as follows: 

• March 13, 2018 - PRHTA to furnish an answer to Movants informing them of its position 

concerning the request for relief of stay as to each individual claim. 

• March 14, 2018 - March 16, 2018 - the parties to meet and confer in an effort to reach an 

agreement on any remaining controversies concerning the request for relief of the stay of 

the proceedings corresponding to the claims being prosecuted by Movants against PRHTA. 

• March 19, 2018 - the parties to file a joint motion with the Court informing the Court of 

the results of the negotiations, any agreements obtained, and any remaining controversies. 

• All other agreements and provisions set forth by the parties in the Joint Motion maintain 

their full force and effect. 

10. The parties respectfully request the Court amend the Third Extension Order [ECF 

No. 2244] to adopt the new deadlines set forth above and hold the Stay Motion and Objection in 

abeyance until April 1, 2018. 

WHEREFORE, the appearing parties respectfully request this Court approve the 

agreements as set forth above. 

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 15th day of February, 2018. 

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I hereby certify that on this date I electronically filed the foregoing Motion with the Clerk 

of the Court, using the CM/ECF System, which will send notification of such filing to all appearing 

parties and counsels using the Court's electronic system.

/s/ Jesús Morales Cordero 

Jesús Morales Cordero

USDC-PR 210609 

BUFETE MORALES CORDERO, CSP 

Attorneys for Movants 

PO Box 363085

San Juan, Puerto Rico 00936-3085 

Tel. (787) 624-4299/Fax (787) 777-1410 

e-mails: bufetemoralescordero@gmail.com

 moracor@gmail.com 

/s/Raul Castellanos

Raúl Castellanos-Malavé

USDC-PR 214611

Development & Construction Law Group LLC

Attorneys for the Puerto Rico Highway and 

Transportation Authority

PMB 443, Suite 112, 100 Grand Paseos Blvd.

San Juan, PR 00926

T. 787.403.2757 / F. 888.500.1827

e-mail: rcastellanos@devconlaw.com

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