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. 

PROMESA 

Title III 

No. 17 BK 3283 – LTS 

Re: ECF No. 210, 1016, 2828, 2829, 2940 

(Jointly Administered) 

FINAL MOTION REQUESTING ADDITIONAL EXTENSION OF TIME 

To the Honorable Court: 

COMES BEFORE THE COURT DAT@ACCESS COMMUNICATION INC, 

NETWAVE EQUIPMENT CORP., and NUSTREAM COMMUNICATIONS CORP. 

(collectively referred to as the “Utility Providers”), utility providers pursuant to the Order (A) 

Prohibiting Utilities from Altering, Refusing, or Discontinuing Service, (B) Deeming Utilities 

Adequately Assured of Future Performance, and (C) Establishing Procedures for Determining 

Adequate Assurance of Payment [ECF No. 1016] (the “Utilities Order”) through the undersigned 

counsel, and respectfully submits this final motion for entry of an order granting an extension of 

time to file to comply with the Utilities Order [ECF. No. 1016] and the Amended Schedule of 

Covered Governmental Agencies and Instrumentalities [ECF. No. 2828] (“Amended Schedule 

II”). 

EXTENSION OF TIME 

1. On May 22, 2017, the Puerto Rico Fiscal Agency and Financial Advisory Authority 

(“AAFAF”) filed motion petitioning the Court to enter an order prohibiting the Utility providers 

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from altering refusing or discontinuing services to Debtor, providing assurance for future 

performance, and stablishing the procedures for determining adequate assurance of payment. 

2. To that effect, the Honorable Court entered the Utilities Order [ECF No. 1016], granting 

said motion on August 11, 2017 by which the Honorable Court granted Utility Services Providers 

an allowed administrative expense claim against Debtor pursuant to Bankruptcy Code sections 

503(b) and 507(a)(2), made applicable to Title III cases by PROMESA section 301(a). 

3. Said Order also extended to all the Government Agencies and Instrumentalities listed on 

Schedule 2 of the Utilities Motion, which was attached thereto. 

4. On March 29, 2018, AAFAF filed motion which, for all intents and purpose, amended 

Schedule 2 of the Utilities Motion and Order. 

5. On April 20th, 2018, the Utility Providers requested an extension of time of seven days to 

file an Assurance Request, related to The Utilities Order [ECF. No. 1016] also to comply with 

[ECF. No. 2940] 

6. The Utility providers have identified over 35 contracts and accounts, which we need to file 

to comply with the Utility Order [ECF. No 1016] and the Schedule II [ECF. No. 2828]. 

7. We will be filing all these claims and documents necessary to comply with both Utilities 

Order [ECF. No 1016, 2828.] on Monday. 

8. We will start filling on Monday if this Honorable Court grants us this motion. As a final 

request for an extension of time as we request herein, (supra) until Friday May 4, 2018 to comply 

fully and file all claims and documents of the Utility Providers, DAT@ACCESS 

COMMUNICATION INC, NETWAVE EQUIPMENT CORP., and NUSTREAM 

COMMUNICATIONS CORP. 

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WHEREFORE, we respectfully request from this Honorable Court that it grants us the extension 

a final extension of time to comply with the Utilities Order and Amendment [ECF No. 1016, 2828]. 

RESPECTFULLY SUBMITTED 

In San Juan, Puerto Rico, this 27th of April of 2018. 

I HEREBY CERTIFY that on this same date a true and exact copy of this notice was filed with 

the Clerk of Court using the CM/ECF system, which will notify all parties in interest. 

________________________________________ 

/S/ HECTOR FIGUEROA VINCENTY 

USDC NO.: 120006 

CALLE SAN FRANCISCO #310 

SUITE 32 

SAN JUAN, P.R. 00901 

MOBILE: 787-378-1154 

QUIEBRAS@ELBUFETEDELPUEBLO.COM 

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