UNITED STATES DISTRICT COURT 

FOR THE 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) 

Re: Dkt. No. 3159 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

 Debtor. 

PROMESA 

Title III 

No. 17 BK 4780-LTS 

ANTONIO FUENTES-GONZALES, MARIA IVONNE 

VIGUIE-FERNANDEZ 

Movants, 

-againstTHE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

Respondent. 

Motion Relates Only to PREPA and 

Shall be Filed in Both the Lead Case 

No. 17 BK-3283-LTS and in 

PREPA’s Title III Case No. 17 BK 

4780-LTS

 

1

 The Debtors in the jointly-administered 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 (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 (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#:3280 Filed:06/08/18 Entered:06/08/18 17:22:03 Desc: Main

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1 

CONSENTED-TO MOTION FOR EXTENSION 

OF DEADLINES IN CONNECTION WITH 

ANTONIO FUENTES-GONZALES, MARIA IVONNE VIGUIEFERNANDEZ’S MOTION FOR RELIEF FROM AUTOMATIC STAY

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

The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”), on behalf 

of the Puerto Rico Electric Power Authority (“PREPA”) pursuant to the authority granted to it 

under the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, by and 

through its undersigned counsel, respectfully submits this consented-to motion for entry of an 

order, substantially in the form attached hereto as Exhibit A, extending the deadlines in connection 

with the Motion for Relief from Automatic Stay [Case No. 17-03283, Dkt. No 3159] (the “Motion 

for Relief from Automatic Stay”) filed by Antonio Fuentes-Gonzales, Maria Ivonne ViguieFernandes, and the conjugal partnership constituted by them (together, the “Movants”).2

 In 

support of this motion, AAFAF respectfully states as follows: 

BACKGROUND 

On May 25, 2018, the Movants filed the Motion for Relief from Automatic Stay seeking 

relief from the automatic stay “for cause” under section 362(d) of title 11 of the United States 

Code. Specifically, the Movants seek a modification of the stay in order to execute their 

judgment for monetary relief against PREPA in Autoridad de Energía Eléctrica v. Antonio 

Fuentes Gonzales et al., Case No. KEF 2012-0039 (the “Fuentes-Viguie Action”). 

Pursuant to this Court’s order entered on May 25, 2018, opposition papers to the Motion 

for Relief from Automatic Stay must be filed by June 8, 2018, and Movants’ reply papers must be 

filed by June 15, 2018 [Case No. 17-03283, Dkt. No 3162]. 

 

2

 The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), as the Debtors’ 

representative pursuant to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act

(“PROMESA”), 48 U.S.C. §§ 2101-2241, has authorized AAFAF to file this motion on behalf of PREPA. 

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2 

The parties are engaged in settlement discussions that may resolve the Fuentes-Viguie 

Action in its entirety, but the parties need additional time to reach an agreement. 

The Movants consented to a fifteen-day (15) extension of the applicable deadlines. 

AAFAF submits that no party or creditor will be prejudiced by this extension. 

RELIEF REQUESTED 

By this motion, AAFAF requests a fifteen-day (15) extension of the applicable deadlines. 

AAFAF requests entry of an order extending the deadlines as follows: 

 Any objection to the Motion for Relief from Automatic Stay shall be filed by June 

23, 2018. 

 Any reply shall be filed by June 30, 2018. 

WHEREFORE, AAFAF respectfully requests the Court to enter an order, substantially in 

the form attached hereto as Exhibit A, (a) granting the motion and (b) granting such other relief as 

is just and proper. 

Dated: June 8, 2018 Respectfully submitted, 

 San Juan, Puerto Rico 

THE PUERTO RICO FISCAL AGENCY 

AND FINANCIAL ADVISORY 

AUTHORITY, as Fiscal Agent for PREPA 

By its attorneys, 

 /s/ Kevin D. Finger

Kevin D. Finger (admitted pro hac vice) 

David D. Cleary (admitted pro hac vice) 

Greenberg Traurig, LLP 

77 West Wacker Drive Suite 3100 

Chicago, IL 60601 

Phone: 312.456.8400 

Fax: 312.456.8435 

Email: fingerk@gtlaw.com 

 clearyd@gtlaw.com 

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Nancy A. Mitchell (admitted pro hac vice) 

Nathan A. Haynes (admitted pro hac vice) 

Greenberg Traurig, LLP 

200 Park Avenue 

New York, NY 10166 

Phone: 212.801.9200 

Fax: 212.801.6400 

 Email: mitchelln@gtlaw.com 

 haynesn@gtlaw.com 

 Joseph P. Davis (admitted pro hac vice) 

 Greenberg Traurig, LLP 

 One International Place, Suite 2000 

 Boston, MA 02110 

 Phone: 617.310.6000 

 Fax: 617.310.6001 

 Email: davisjo@gtlaw.com 

THE PUERTO RICO ELECTRIC 

POWER AUTHORITY 

 

By its attorneys, 

/s/ Arturo Díaz Angueria

USDC No. 117907 

/s/ Katiuska Bolaños Lugo

USDC No. 231812 

CANCIO, NADAL, RIVERA & DÍAZ, P.S.C. 

PO Box 364966 

San Juan, PR 00936-4966 

Phone: (787) 767-9625 

Fax: (787) 764-4430 

Email: adiaz@cnrd.com 

 kbolanos@cnrd.com 

 

 

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Exhibit A 

Proposed Order

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UNITED STATES DISTRICT COURT 

FOR THE 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) 

Re: Dkt. No. 2852 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

 Debtor. 

PROMESA 

Title III 

No. 17 BK 4780-LTS 

ANTONIO FUENTES-GONZALES, MARIA IVONNE 

VIGUIE-FERNANDEZ 

Movants, 

-againstTHE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

Respondent. 

[Caption Continued on the Next Page]

 

1

 The Debtors in the jointly-administered 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 (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 (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). 

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ORDER GRANTING CONSENTED-TO MOTION FOR 

EXTENSION OF DEADLINES IN CONNECTION WITH 

ANTONIO FUENTES-GONZALES, MARIA IVONNE VIGUIEFERNANDEZ’S MOTION FOR RELIEF FROM AUTOMATIC STAY

Upon the Consented-To Motion for Extension of Deadlines in Connection with Antonio 

Fuentes-Gonzales, Maria Ivonne Viguie-Fernandez’s Motion for Relief from Automatic Stay 

(the “Motion”)4

 and the Court having found it has subject matter jurisdiction over this matter 

pursuant to PROMESA section 306(a); and it appearing that venue is proper pursuant to 

PROMESA section 307(a); and the Court having found that the relief requested in the Motion is 

in the best interests of the Debtors, their creditors, and other parties in interest, it is HEREBY 

ORDERED THAT: 

1. The Motion is granted. 

2. Any objection to the Motion for Relief from Automatic Stay shall be due on June 23, 

2018. 

3. Any reply shall be due on June 30, 2018. 

4. This Court retains exclusive jurisdiction with respect to all matters arising from or 

related to the implementation, interpretation, and enforcement of this Order. 

5. This Order resolves docket entry no._______. 

SO ORDERED. 

Dated: _________________, 2018 ________________________ 

San Juan, Puerto Rico LAURA TAYLOR SWAIN 

 UNITED STATES DISTRICT JUDGE 

 

4

 Capitalized terms used but not otherwise defined herein have the meanings given to them in the Motion. 

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