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 Nos. 1512-1, 2839-1, 

2938, 2945

DEBTORS’ SUPPLEMENT TO THIRD OMNIBUS MOTION FOR 

APPROVAL OF MODIFICATIONS TO THE AUTOMATIC STAY

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

The Commonwealth of Puerto Rico (the “Commonwealth”), the Puerto Rico Sales Tax 

Financing Corporation (“COFINA”), the Puerto Rico Highways and Transportation Authority 

(“HTA”), the Employees Retirement System of the Government of the Commonwealth of Puerto 

Rico (“ERS”), and the Puerto Rico Electric Power Authority (“PREPA” and together with the 

Commonwealth, COFINA, HTA, and ERS, the “Debtors”), as Title III debtors, by and through 

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, 

 

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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and Economic Stability Act (“PROMESA”),

2 respectfully submits this supplement (the 

“Supplement”) to Debtors’ Third Omnibus Motion for Approval of Modifications to the 

Automatic Stay [ECF No. 2938] (the “Third Omnibus Motion”), pursuant to sections 362(d)(1) 

and 105(a) of title 11 of the United States Code (the “Bankruptcy Code”), made applicable to 

these cases by PROMESA section 301(a), and in accordance with Paragraph III.Q of the Case 

Management Procedures (as defined below), for entry of an order, substantially in the form 

attached hereto as Exhibit A (the “Proposed Order”), retroactively approving the modifications 

to the automatic stay set forth in Bankruptcy Code sections 362(a) and 922(a) (the “Title III 

Stay”), (a) for the party and action set forth in Exhibit 1 to the Proposed Order, nunc pro tunc to 

the date specified therein, and (b) for parties to certain administrative employment and pension 

actions against debtor ERS as set forth on Exhibit 2 to the Proposed Order, nunc pro tunc to the 

dates specified therein. In support of this Supplement, the Debtors respectfully represent as 

follows:

Supplement

1. This Supplement incorporates in full, as if set forth herein, the contents and

factual and legal assertions of the Third Omnibus Motion and supplements it as follows.

Background

2. On April 23, 2018, the Court granted the Third Omnibus Motion, which modified 

the Title III Stay as set forth in the attached exhibits, nunc pro tunc, to the dates specified therein

[ECF No. 2945].

 2 PROMESA is codified at 48 U.S.C. §§ 2101-2241.

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3. ERS and the Commonwealth desire to supplement the Third Omnibus Motion to 

include modifications that were agreed to during the timeframe covered in such motion and that 

were inadvertently excluded.

Relief Requested

3. By this Supplement, the Debtors seek to supplement the Third Omnibus Motion 

to include modifications to the stay that were agreed to by the Debtors during the period from 

February 21, 2018 through April 20, 2018 and that were inadvertently excluded from the Third 

Omnibus Motion. As required by Paragraph III.Q of the Case Management Procedures, Exhibit 

1 to the Proposed Order includes a brief description of the modification of the Title III Stay and 

case information (including case number and court), as applicable, for each party to a stay 

modification stipulation previously executed by the indicated Debtor during the period from 

February 21, 2018 through April 20, 2018 (the date of the Third Omnibus Motion). Further, the 

Supplement seeks to approve modifications to the Title III Stay agreed to by ERS, through this 

Supplement and without the need for a stipulation in accordance with Paragraph III.Q of the 

Case Management Procedures, solely to allow the labor and pension claims detailed on Exhibit 2 

to the Proposed Order to continue through judgment but not the execution or enforcement of any 

judgment 

4. Accordingly, the Debtors request that the Court enter an order retroactively 

approving the modifications of the Title III Stay set forth on Exhibit 1 and 2 to the Proposed 

Order. 

Notice

5. The Debtors have provided notice of this Supplement in accordance with the Case 

Management Procedures to the following parties: (a) the Office of the United States Trustee for 

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the District of Puerto Rico; (b) the indenture trustees and/or agents, as applicable, for the 

Debtors’ bonds; (c) the entities on the list of creditors holding the 20 largest unsecured claims 

against COFINA; (d) counsel to the statutory committees appointed in these Title III cases; 

(e) the Office of the United States Attorney for the District of Puerto Rico; (f) counsel to the 

Oversight Board; (g) the Puerto Rico Department of Justice; (h) the Other Interested Parties;3

(i) all parties filing a notice of appearance in these Title III cases; and (j) the parties set forth in

Exhibit 1 and 2 to the Proposed Order. A copy of the Supplement is also available on the 

Debtors’ case website at https://cases.primeclerk.com/puertorico/.

6. The Debtors submit that, in light of the nature of the relief requested, no other or 

further notice need be given.

No Prior Motion

7. The Debtors have not made any prior motion for the relief sought in this 

Supplement to this or any other court.

Remainder of Page Intentionally Left Blank

 3 The “Other Interested Parties” include the following: (i) counsel to certain of the insurers and trustees of the 

bonds issued or guaranteed by the Debtors; and (ii) counsel to certain ad hoc groups of holders of bonds issued 

or guaranteed by the Debtors.

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WHEREFORE, the Debtors respectfully request entry of the Proposed Order in 

the form attached hereto as Exhibit A, retroactively approving the modifications of the Title III 

Stay set forth on Exhibit 1 and 2 to the Proposed Order, and granting such other and further relief 

as the Court may deem proper. 

Dated: May 1, 2018

San Juan, Puerto Rico

Respectfully submitted, 

/s/ Martin J. Bienenstock 

Martin J. Bienenstock (admitted pro hac vice)

Brian S. Rosen (admitted pro hac vice)

Paul V. Possinger (admitted pro hac vice)

Ehud Barak (admitted pro hac vice)

Maja Zerjal (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 the Debtors

/s/ Hermann D. Bauer 

Hermann D. Bauer

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 the Debtors

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Exhibit A

Proposed Order

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1

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. _____

ORDER SUPPLEMENTING THIRD OMNIBUS ORDER GRANTING 

RELIEF FROM THE AUTOMATIC STAY

Upon the Debtors’ Supplement to Third Omnibus Motion Seeking Approval of 

Stipulations Modifying the Automatic Stay (the “Supplement”);2 and the Court having found it 

has subject matter jurisdiction over this matter pursuant to PROMESA section 306; and it 

appearing that venue in this district is proper pursuant to PROMESA section 307; and the Court 

having found that the relief requested in the Supplement is in the best interests of the Debtors, 

their creditors, and other parties in interest; and the Court having found that the Debtors provided 

adequate and appropriate notice of the Supplement under the circumstances and that no other or 

further notice is required; and the Court having reviewed the Supplement; and the Court having 

determined that the legal and factual bases set forth in the Supplement establish just cause for the 

 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).

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

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relief granted herein; and any objections to the relief requested herein having been withdrawn or 

overruled on the merits; and after due deliberation and sufficient cause appearing therefor, it is 

HEREBY ORDERED THAT:

1. The relief requested in the Supplement is granted as set forth herein. 

2. Pursuant to Bankruptcy Code sections 362(d)(1) and 105(a), made 

applicable to the Title III cases by PROMESA section 301(a), the Title III Stay is modified as set 

forth in the attached Exhibit 1 for the matter subject to prior stipulations between the 

Commonwealth and the counterparties, nunc pro tunc to the dates specified therein.

3. Pursuant to Bankruptcy Code sections 362(d)(1) and 105(a), the Title III 

Stay is modified as set forth in the attached Exhibit 2 for administrative employment and pension 

matters against ERS, nunc pro tunc to April 20, 2018 (the date of the Third Omnibus Motion).

4. All rights, defenses, and protections of each of the Debtors with respect to 

any matters pending or that may arise in their respective Title III Cases, including the treatment 

of any claim arising from the matters set forth on Exhibits 1 and 2 hereof under a plan of 

adjustment or otherwise in the Title III Case are hereby reserved. Nothing in this Order or the 

Debtors’ consent to stay modification as set forth in the Motion shall be deemed to be, or 

construed as, (a) an admission by any party of any liability, wrongdoing, act, or matter or that 

any claim or defense has or lacks merit; (b) a waiver of the Debtors’ rights to dispute, contest, 

setoff, or recoup any claim, including any claims asserted in the subject actions, or assert any 

related rights, claims, or defenses and all such rights are reserved; or (c) an approval or 

assumption of any agreement or contract between the parties under Bankruptcy Code section 

365. 

5. Notwithstanding any applicability of any Federal Rule of Bankruptcy 

Procedure, the terms and conditions of this Order shall be immediately effective and enforceable 

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upon its entry.

6. The Court shall retain jurisdiction to hear and determine all matters 

(a) arising from or related to the implementation, enforcement, or interpretation of this Order and 

(b) concerning the execution or enforcement in the Title III cases of any judgment entered in a 

prepetition ordinary course civil action where the Debtors agreed to modify or lift the Title III 

Stay to allow the action to proceed to judgment by the underlying court. 

Dated: _________________

HONORABLE LAURA TAYLOR SWAIN

 UNITED STATES DISTRICT JUDGE

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Exhibit 1

Parties and Actions Granted Modification of the Title III Stay

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TITLE III STAY MODIFICATIONS AGREED TO BY THE DEBTORS 

FROM FEBRUARY 21, 2018 THROUGH APRIL 20, 2018

Case Information Movant(s) Debtor Brief Description of the Modification Stipulation Date

1. Caraballo-Rivera, et 

al. v. García Padilla, 

et al., Case No. 14-

1431

United States District 

Court for the District 

of Puerto Rico 

Discrimination action

Héctor M. VázquezGarcía, Doroteo 

Sánchez-Cruz, Daniel 

Valentín García, 

Carlos J. PachecoEstrada, Luis A. 

Pérez-Bernard, and 

Roberto VélezGarcia

Commonwealth The Title III Stay is hereby modified solely to 

the limited extent necessary to allow the 

Prepetition Action to proceed to judgment 

before the District Court; provided, however, 

the Title III Stay shall continue to apply in all 

other respects to the Prepetition Action 

including, but not limited to, the execution and 

enforcement of any judgment and for any claims 

for money damages and provisional remedies 

against the Commonwealth or any other Title III 

Debtor.

April 19, 2018

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Exhibit 2

ERS Administrative Actions Granted Modification of the Title III Stay

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TITLE III STAY MODIFICATIONS AGREED TO BY DEBTOR ERS

FROM FEBRUARY 21, 2018 THROUGH APRIL 20, 2018

Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

1 2016-0148 Reimbursement of 

contributions

Aida Rosario 

Ramos

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

2 2016-0087 Reinstatement Angel A. Quiñones ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

3 2016-0198 Readjustment of 

pension

Confesor Calderón 

Molina

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

4 2016-0349 Disability Edilia Rivera Flores ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

5 2015-0272 Disability Eliud Rivera 

Zambrana

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

6 2015-0052 Reimbursement of 

contributions

Emma I. Colón 

Centeno

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

7 2016-0149 Reimbursement of 

contributions

Giselle Rodríguez 

Figueroa

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

8 2016-0061 Disability Héctor González 

Martinez

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

9 2015-0066 Deferred pension Hipólito Ortiz 

Figueroa

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

10 2016-0025 Disability Iris M. Rodríguez 

Rodríguez

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

11 2014-0413 Disability José Rodríguez 

Román

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

12 2014-0365 Disability Julio Pérez Ortíz ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

13 2016-0097 Disability Lesvia Boria 

Escobar

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

14 20160067 Disability LESVIA BORIA 

ESCOBAR

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

15 2015-0167 Disability Lydia Velázquez 

Feliciano

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

16 2015-0290 Disability Maritza Cortés 

Pagán

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

17 2016-0218 Disability Marybel Ramos 

Hndez

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

18 2015-0323 Disability Melvin D. Faria 

Méndez

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

19 2016-0152 Reinstatement Norma I. Calo Calo ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

20 2016-0030 Disability Norma V. 

Rodríguez Lugo

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

21 2015-0258 Disability Orlando Pabón Del 

Río

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

22 2016-0038 Disability Otilia Quirindongo 

Vega

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

23 2015-0003 Disability Pablo Laboy Laboy ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

24 2016-0209 Reimbursement of 

contributions

Rafael Valle Ortiz ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

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Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

25 2016-0227 Disability Rene Solis Roldán ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

26 2016-0144 Disability Rosa M. Santoni 

López

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

27 2016-0187 Disability Sonia Y. Cortés 

González

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

Case:17-03283-LTS Doc#:2986 Filed:05/01/18 Entered:05/01/18 13:30:23 Desc: Main

Document Page 21 of 23
10

Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

28 2016-0110 Disability Teresa Reyes López ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

29 2016-0242 Disability Yadira E. Torres 

Nieves

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

30 KLRA 2016 

00908

Appeal from 

administrative 

determination on 

employee benefits

Luz Melba Lopez 

Ortiz

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

Case:17-03283-LTS Doc#:2986 Filed:05/01/18 Entered:05/01/18 13:30:23 Desc: Main

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11

Case 

Number Matter Movant(s) Debtor Brief Description of the Modification Stipulation Date

31 KLRA 2017 

00481

Appeal from 

administrative 

determination on 

employee benefits

Marta Carrasquillo 

Rivera

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

32 2016-0197 Disability Zahira Rodríguez 

Soler

ERS The Title III Stay is hereby modified solely to the limited extent 

necessary to allow the Prepetition Action to proceed to judgment 

before the Prepetition Forum; provided, however, the Title III 

Stay shall continue to apply in all other respects to the 

Prepetition Action including, but not limited to, the execution 

and enforcement of any judgment and for any claims for money 

damages and provisional remedies against ERS or any other 

Title III Debtor

4/20/2018

Case:17-03283-LTS Doc#:2986 Filed:05/01/18 Entered:05/01/18 13:30:23 Desc: Main

Document Page 23 of 23