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

Re: ECF No. 23702

(Jointly Administered)

URGENT CONSENSUAL MOTION 

FOR EXTENSION OF RESPONSE DEADLINES

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

The Commonwealth of Puerto Rico (the “Commonwealth” or the “Debtor”), by and 

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

as the sole Title III representative of the Commonwealth pursuant to section 315(b) of the Puerto 

Rico Oversight, Management, and Economic Stability Act (“PROMESA”),2 respectfully submits

this urgent consensual motion (the “Urgent Motion”) for entry of an order, substantially in the 

form attached hereto as Exhibit A (the “Proposed Order”), extending the briefing deadlines 

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); (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”) (Last Four 

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case No. 19-BK-5523-

LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations).

2

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

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established in the Order Scheduling Briefing Concerning Discharge and Requesting Relief from 

Stay [ECF No. 23702] (the “Scheduling Order”) relating to the Motion to Set Aside Discharge and 

Requesting Relief from of Stay [ECF No. 23700] (the “Motion”), and states as follows:

Request for Relief

1. On March 7, 2023, Maria De Los Angeles Ortiz-Soto and Nilda Melendez-Santana 

(collectively, the “Movants”) filed the Motion, requesting relief from the Debtor’s discharge 

injunction, as described further in the Motion.

2. Pursuant to the Scheduling Order, responses to the Motion must be filed by April 

4, 2023, at 5:00 p.m. (Atlantic Standard Time), and replies must be filed by April 11, 2023, at 5:00 

p.m. (Atlantic Standard Time). Scheduling Order at 1. 

3. Since the filing of the Motion, the Debtor and the Movants reached an agreement 

in principle to consensually resolve the Motion. However, the parties require additional time to 

document and finalize such agreement in principle. 

4. Accordingly, and with the consent of the Movants, the Oversight Board proposes 

the following extensions to the dates set forth in the Scheduling Order: 

• The deadline to respond to the Motion be extended to April 18, 2023 at 5:00 p.m. 

(Atlantic Standard Time).

• The deadline for Movants to file a reply, if any, be extended to April 25, 2023 at 

5:00 p.m. (Atlantic Standard Time).

5. Pursuant to Paragraph 1.H of the Sixteenth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 20190-1] (the “Case Management Procedures”), the 

Oversight Board certifies that it has carefully examined the matter and concluded that there is a 

true need for an urgent motion; it has not created the urgency through any lack of due diligence; 

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has made a bona fide effort to resolve the issues presented in the Urgent Motion; and has made 

reasonable, good-faith communications in an effort to resolve or narrow the issues that are being 

brought to the Court.

Notice

6. The Oversight Board has provided notice of this motion in accordance with the 

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

for 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 the Debtors; (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) the 

Applicable Movants; and (j) all parties filing a notice of appearance in these Title III cases. A copy 

of the motion is also available at https://cases.ra.kroll.com/puertorico/. 

7. The Oversight Board submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

[Remainder of Page Left Intentionally 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 request the Court enter the Proposed Order and grant such 

other relief as is just and proper. 

Dated: April 4, 2023

 San Juan, Puerto Rico

PROSKAUER ROSE LLP

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice) 

Brian S. Rosen (pro hac vice) 

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

-andO’NEILL & BORGES LLC

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla García-Benítez

USDC No. 203708

Gabriel A. Miranda

USDC No. 306704

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Commonwealth

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Exhibit A

Proposed Order

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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

Re: ECF No. _____

(Jointly Administered)

ORDER GRANTING

URGENT CONSENSUAL MOTION FOR EXTENSION OF RESPONSE DEADLINES

Upon the Urgent Consensual Motion for Extension of Response Deadlines, dated April 4,

2023 (Docket Entry No. _____)

2 (the “Extension Motion”);3 and the Court having found it has 

subject-matter jurisdiction over this matter pursuant to section 306(a) of PROMESA; and it 

appearing that venue in this district is proper pursuant to section 307(a) of PROMESA; the Court 

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); (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”) (Last Four 

Digits of Federal Tax ID: 3801) (Last Four Digits of Federal Tax ID: 3801) (Bankruptcy Case 

No. 19-BK-5523-LTS). (Title III case numbers are listed as Bankruptcy Case numbers due to 

software limitations).

2 All docket entry references are to entries in Case No. 17-3283, unless otherwise specified.

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

the Extension Motion.

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having found that the Oversight Board provided adequate and appropriate notice of the Extension 

Motion under the circumstances and that no other or further notice is required; and the Court 

having reviewed the Extension Motion; and the Court having determined that the factual bases set 

forth in the Extension Motion establish just cause for the relief granted herein; and after due 

deliberation and sufficient cause appearing therefor, it is hereby ORDERED that:

1. The Extension Motion is GRANTED as set forth herein.

2. The Scheduling Order shall be modified as provided herein.

3. The deadline to respond to the Motion shall be extended to April 18, 2023 at 5:00 

p.m. (Atlantic Standard Time).

4. The deadline for the Movants to file a reply shall be extended to April 25, 2023 at 

5:00 p.m. (Atlantic Standard Time).

5. The Court will thereafter take the Motion on submission.

6. This Order resolves Docket Entry No. _____ in Case No. 17-3283.

SO ORDERED.

Dated: April ___, 2023

 

LAURA TAYLOR SWAIN

United States District Judge

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