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UNITED STATES BANKRUPTCY 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, 1032, 

1039, 1303, 1310

(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 Joint 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. 

INFORMATIVE MOTION OF AGREEMENT CONCERNING THE REQUEST 

FOR RELIEF OF STAY FILED BY HTA MANAGERIAL EMPLOYEES

AND REQUEST FOR A TEN DAY PERIOD TO SUBMIT FINAL STIPULATION

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

(‘HTA”) listed in ExhibitI ofthe Motion Requesting Relief From Stay (Dckt. 663) (the “Stay Motion”),

 

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).

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hereinafter designated as the “Movants,” and the Puerto Rico Highway Transportation Authority 

(“HTA”), through their respective counsel and respectfully state and pray:2

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 HTA by Movants before different

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

2. On August 2, 2017, AAFAF, on behalf of HTA, 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 HTA’s Title III case. It also 

pointed to Movants’ failure to provide information about the status and stage of each of the 115 

employment claims prosecuted by them, which have been stayed upon the commencement of HTA’s 

Title III case. 

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

Filed by The HTA Managerial Employees (ECF No. 1032, hereinafter the “Joint Motion”) filed on 

August 15, 2017, Movants and HTA reached an agreement to adopt a process that would allow HTA

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.

4. After several extensions of the schedule agreed between the party, motivated by the 

conditions generated by the impact of the 2017 storms, and pursuant to the agreements, the Movants 

 

2 The Financial Oversight and Management Board for Puerto Rico, as the Debtors’ representative pursuant to section 

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

AAFAF to consent to this joint motion on behalf of HTA.

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furnished HTA with particularized information concerning each claim included in the list attached 

as Exhibit 1 to the Motion, including a summary of the nature of the claim, the status and stage of 

the proceedings, as well as other information relevant to Sonnax factors nos. 1, 10, & 11. The 

information was furnished on November 30, 2017 and supplemented on January 10, 2018.

5. After the information was furnished, HTA made an analysis of the request for relief 

of stay for each claim. Shortly after the conclusion of this analysis, counsel for the parties met and 

held discussions. These discussions proved fruitful and have resulted in an agreement between the 

parties. 

6. In general terms, the agreement will produce a joint request to this Honorable Court 

an entry of an order approving the modifications to the automatic stay set forth in Bankruptcy Code 

sections 362(a) and 922(a) (the “Title III Stay”), made applicable to the Title III cases by 

PROMESA section 301(a) in order to lift the stay to all actions prosecuted by the Movants as set

forth in Exhibit 1 of the Motion Requesting Relief From Stay (Dckt. 663)

WHEREFORE, the appearing parties respectfully request this Honorable Court to take 

notice of the above and grant the parties a period of fifteen (15) days expiring on April 3, 2018 to

file the final stipulation setting forth the detailed terms of the agreement and proposing an Order 

to the Honorable Court. 

CERTIFICATE OF SERVICE

COUNSEL FOR BOTH PARTIES CERTIFY that on this date, this document has been 

electronically filed with the Clerk of the Court using the CM/ECF System, which will send notice

to all registered participants.

COUNSEL FOR MOVANTS certify they have also sent a true and exact copy of this 

Motion via regular mail and e-mail to counsel for HTA in various of the proceedings that have been

stayed pursuant to the commencement of HTA’s Title III case, including: Lcdo. Juan M. Maldonado

De Jesús, Oficina del Asesor Legal ACT, P.O. Box 42007 San Juan, Puerto Rico 00940-2007 and

jumaldonado@dtop.pr.gov; CarlosJ. Garcia Bonilla, Oficina de Asesoría Legal ACT, PO Box 42007

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San Juan, Puerto Rico 00940-2007 and cjgarcia@dtop.pr.gov; María Elena Vázquez Graziani and

Rocío Ramos Santiago, Vázquez Graziani & Rodríguez, 33 Calle Resolución, Suite 805 San Juan,

Puerto Rico 00920-2707 and rocioramos@vgrlaw.com and vazgra@vgrlaw.com, respectively;

Sarah G. Sáez López and Raúl Castellanos, Development & Construction Law Group LLC PMB

443, Suite 112, 100 Grand Paseos Boulevard San Juan, Puerto Rico 00926 and 

rcastellanos@devconlaw.com and ssaez@devconlaw.com, respectively.

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 19th day of March, 2018.

/s/JESÚS R. 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 

bufetemoralescordero@gmail.com/moracor@gmail.com

Development & Construction Law 

Group, LLC

Attorneys for the Puerto Rico

Highways & Transportation Authority

PMB 443, Suite 112

100 Grand Paseos Blvd.

San Juan, PR 00926-5902

T. 787. 403.2757

F. 888.500.1827

e-mail: rcastellanos@devconlaw.com

s/Raúl Castellanos

Raúl Castellanos-Malavé

PR USDC No. 214611

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