Estimated Hearing Date: To be determined by the Court

Objection Deadline: To be determined by the Court

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)

BELFOR USA GROUP, INC., dba BELFOR PROPERTY RESTORATION’S FURTHER

CONSENTED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO ECF 24589 

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 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); and (v) 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).

Case:17-03283-LTS Doc#:24858 Filed:08/10/23 Entered:08/10/23 11:53:07 Desc: Main

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Estimated Hearing Date: To be determined by the Court

Objection Deadline: To be determined by the Court

TO THE HONORABLE LAURA TAYLOR SWAIN,

UNITED STATES DISTRICT JUDGE:

COMES NOW, BELFOR USA GROUP, INC., dba “BELFOR PROPERTY 

RESTORATION”), represented by the undersigned attorneys, and very respectfully avers and 

prays as follows:

1. BELFOR USA GROUP, INC. (“BELFOR”) respectfully prays for an extension of time of 

thirteen (13) days, lapsing on Wednesday, August 23, 2023, to file its reply to the Financial 

Oversight and Management Board for Puerto Rico’s (“Board”) objection at ECF 24589 to the 

motion for payment of administrative claim filed by BELFOR.

2. BELFOR is in the process of locating additional evidence which could allow the parties to 

reach a solution to this contested matter, however, there is a substantial amount of documents 

involved and we are presently continuing their analysis.

3. The Board, through its counsel of record Proskauer, has graciously consented to the instant

further request.

4. The instant request will not unduly cause prejudice or cause unjustified delay in this matter.

NOTICE

5. Notice has hereby been served by CM/EF and on the Master Service List posted on the 

website of the Debtors’ claims and noticing agent, by e-mail.

6. No prior request for the relief sought herein has been made to this Court or to any other 

Court.

WHEREFORE, BELFOR PROPERTY RESTORATION respectfully prays that this Honorable 

Court grant it an extension of time of thirteen (13) days, until August 23, 2023, to file its reply to 

the Financial Oversight and Management Board for Puerto Rico’s (“Board”) objection at ECF 

Case:17-03283-LTS Doc#:24858 Filed:08/10/23 Entered:08/10/23 11:53:07 Desc: Main

Document Page 2 of 3
Estimated Hearing Date: To be determined by the Court

Objection Deadline: To be determined by the Court

24589 to the motion for payment of administrative claim filed by BELFOR, with any other relief 

in its favor the Court deems proper.

RESPECTFULLY SUBMITTED.

Dated: August 10, 2023

Respectfully submitted,

REICHARD & ESCALERA, LLC

/s/ Fernando Van Derdys

Fernando Van Derdys, Esq.

USDC-PR 201913

fvander@reichardescalera.com

255 Ponce de León Avenue

MCS Plaza, 10th Floor

San Juan, PR 00917-1913

Telephone: (787) 777-8888

Case:17-03283-LTS Doc#:24858 Filed:08/10/23 Entered:08/10/23 11:53:07 Desc: Main

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