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)

Re: ECF No. 24125

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

Re: ECF No. 3440

CERTIFICATE OF NO OBECTION REGARDING THIRTEENTH MOTION OF THE 

PUERTO RICO ELECTRIC POWER AUTHORITY FOR ENTRY OF ORDER 

PURSUANT TO RULE 9006(b) OF THE FEDERAL RULES OF BANKRUPTCY 

PROCEDURE FURTHER ENLARGING THE TIME WITHIN WHICH TO FILE

NOTICES OF REMOVAL PURSUANT TO BANKRUPTCY RULE 9027

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-BK3567-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); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17- BK-4780-LTS) 

(Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy 

Case No. 19- BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations).

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 1 of 7
2

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

1. On May 3, 2023, the Puerto Rico Electric Power Authority (“PREPA” or the 

“Debtor”), through the Financial Oversight and Management Board for Puerto Rico (the “FOMB” 

or “Oversight Board”) as PREPA’s sole Title III representative pursuant to section 315(b) of the 

Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), filed the 

Thirteenth Motion of the Puerto Rico Electric Power Authority for Entry of Order Pursuant to 

Rule 9006(b) of the Federal Rules of Bankruptcy Procedure Further Enlarging the Time Within 

Which to File Notices of Removal Pursuant to Bankruptcy Rule 9027 [Case No. 17-3283-LTS, 

ECF No. 24125; Case No. 17-4780-LTS, ECF No. 3440] (the “Motion”).

2

2. Responses or objections, if any, were to be filed and served no later than May 23, 

2023, at 4:00 p.m. (AST) (the “Objection Deadline”). According to this Court’s Sixteenth

Amended Notice, Case Management and Administrative Procedures [Case No. 17-3283-LTS, ECF 

No. 20190-1] (the “Case Management Procedures”), the Court may enter an order granting a 

request for relief without a hearing upon receipt of a certificate of no objection (“CNO”, as defined 

by the Case Management Procedures). See Case Management Procedures, III.P.

3. In accordance with the Case Management Procedures, the undersigned hereby 

certifies that this CNO is filed not less than forty-eight (48) hours after the expiration of the 

Objection Deadline. The undersigned further certifies that counsel for the Oversight Board has 

reviewed the Court’s docket in the above-captioned cases not less than forty-eight (48) hours after 

expiration of the Objection Deadline, and, to the best of counsel’s knowledge, no applicable 

2

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

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 2 of 7
3

objection, responsive pleading, or request for a hearing with respect to the Motion appears on the 

docket.

WHEREFORE PREPA respectfully requests the Court enter the proposed order attached 

hereto as Exhibit A.

Dated: May 26, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Paul V. Possinger

Martin J. Bienenstock (admitted pro hac vice)

Paul V. Possinger (admitted pro hac vice)

Ehud Barak (admitted pro hac vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial Oversight and 

Management Board as representative for 

PREPA

/s/ Hermann D. Bauer 

Hermann D. Bauer

USDC No. 215205

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-Attorneys for the Financial Oversight and 

Management Board as representative for 

PREPA

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 3 of 7
Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 4 of 7
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 

Case No. 17-BK-3283-LTS

(Jointly Administered)

Re: ECF No. 24125

In re:

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO,

as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY,

Debtor.

PROMESA

Title III

Case No. 17-BK-4780-LTS

(Jointly Administered)

Re: ECF No. 3440

[PROPOSED] ORDER GRANTING MOTION OF THE 

PUERTO RICO ELECTRIC POWER AUTHORITY FOR ENTRY 

OF ORDER PURSUANT TO RULE 9006(B) OF THE FEDERAL RULES OF 

BANKRUPTCY PROCEDURE FURTHER ENLARGING THE TIME WITHIN WHICH 

TO FILE NOTICES OF REMOVAL PURSUANT TO BANKRUPTCY RULE 9027 

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-BK3567-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); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17- BK-4780-LTS) 

(Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy 

Case No. 19- BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations).

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 5 of 7
2

Upon the Thirteenth Motion of the Puerto Rico Electric Power Authority for Entry of Order 

Pursuant to Rule 9006(b) of the Federal Rules of Bankruptcy Procedure Further Enlarging the 

Time Within Which to File Notices of Removal Pursuant to Bankruptcy Rule 9027 [Case No. 17-

3283-LTS, ECF No. 24125; Case No. 17-4780-LTS, ECF No. 3440] (the “Motion”);2and the 

Court having found it has subject matter jurisdiction over this matter pursuant to PROMESA 

section 306(a); and it appearing that venue in this district 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 PREPA, its creditors, and other parties in interest; and the Court having found that PREPA 

provided adequate and appropriate notice of the Motion under the circumstances and that no other 

or further notice is required; and the Court having determined that the legal and factual bases set 

forth in the Motion establish just cause for the relief granted herein,

IT IS HEREBY ORDERED THAT:

1. The Motion is GRANTED as set forth herein.

2. The deadline for PREPA to file notices of removal under Bankruptcy Rule 9027(a) 

is further extended through and including through the later of: (i) November 6, 2023; and (ii) such 

later date prescribed by Bankruptcy Rule 9027(a)(2) and (a)(3).

3. The foregoing is without prejudice to PREPA’s right to seek further extensions of 

the time within which to remove related proceedings.

4. Nothing herein is intended to, shall constitute, or shall be deemed to constitute 

PREPA’s or the Oversight Board’s consent, pursuant to PROMESA section 305, to this Court’s 

interference with (a) any of the political or governmental powers of PREPA, (b) any of the property 

or revenues of PREPA, or (c) the use or enjoyment of PREPA of any income-producing property.

2 Capitalized terms not otherwise defined herein shall have the meanings given to them in the Motion. 

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 6 of 7
3

5. Notwithstanding any applicability of any Bankruptcy Rule, the terms and 

conditions of this Order shall be immediately effective and enforceable upon its entry.

6. PREPA and the Oversight Board, as PREPA’s representative, have consented to 

the relief in this Order, and are authorized to take all actions, and to execute all documents, 

necessary or appropriate, to effectuate the relief granted in this Order in accordance with the 

Motion.

7. The Court retains exclusive jurisdiction to hear and determine any and all disputes 

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

Dated:________________________

Honorable Laura Taylor Swain

United States District Judge

Case:17-03283-LTS Doc#:24342 Filed:05/26/23 Entered:05/26/23 17:29:45 Desc: Main

Document Page 7 of 7