UNITED STATES DISTRICT 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

(Jointly Administered)

Re: Docket No. 210, 389, 412

THIRD NOTICE OF CONSENSUAL EXTENSION OF OBJECTION DEADLINE 

REGARDING MOTION OF DEBTOR ENTITIES FOR 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

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

The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF’) as the 

entity authorized to act on behalf of the Debtor entities pursuant to the authority granted to it 

under the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017,2

respectfully files this third notice of the Debtors’ consent to the extension of the deadline for 

certain parties in interest (the “Extension Parties”)3to file an objection to the Motion of Debtor 

Entities for an Order (A) Prohibiting Utilities from Altering, Refusing, or Discontinuing Service, 

 

1 The Debtors in these Title III Cases, along with each Debtor’s respective bankruptcy 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) (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); and (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).

2 The Financial Oversight and Management Board for Puerto Rico has consented to the filing of this notice by 

AAFAF.

3 The Extension Parties are as follows: (a) Puerto Rico Electric Power Authority; (b) Puerto Rico Aqueduct and 

Sewer Authority; (c) WorldNet Telecommunications; and (d) Puerto Rico Telephone Company d/b/a Claro.

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(B) Deeming Utilities Adequately Assured of Future Performance, and (C) Establishing 

Procedures for Determining Adequate Assurance of Payment (the “Motion”) [D.I. 210].4The 

original deadline to object to the Motion was Monday, June 19, 2017 at 4:00 p.m. (Prevailing

Eastern Time).

On June 19, 2017, AAFAF, on behalf of the Debtor entities, filed the Notice of 

Consensual Extension of Objection Deadline Regarding Motion of Debtor Entities for 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 [D.I. 389], which extended the original objection deadline to 

12:00 p.m. (Prevailing Eastern Time) on Wednesday, June 21, 2017. 

On June 21, 2017, AAFAF, on behalf of the Debtor entities, filed the Second Notice of 

Consensual Extension of Objection Deadline Regarding Motion of Debtor Entities for 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 [D.I. 412], which extended the original objection deadline to 

12:00 p.m. (Prevailing Eastern Time) on Thursday, June 22, 2017.

To provide the parties with additional time to consensually resolve any open issues with 

respect to the Motion, the Debtors have further agreed to extend the deadline for the Extension 

Parties to file an objection to the Motion to 4:00 p.m. (Prevailing Eastern Time) on Friday, June 

23, 2017. See First Amended Notice, Case Management and Administrative Procedures [D.I. 

262-1] at ¶ III.I (providing that the deadline to file an objection to any pleading “may be 

extended with the consent of the movant or applicant,” provided that the “movant shall provide 

notice of the extension to Chambers”).

 

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

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RESPECTFULLY SUBMITTED. 

In San Juan, Puerto Rico, this 22nd day of June, 2017.

I HEREBY CERTIFY: That on this same date, the foregoing has been electronically 

filed with the Clerk of the Court using the CM/ECF system, which will notify all counsel of 

record of such filing.

/s/ Suzzanne Uhland 

John J. Rapisardi 

Suzzanne Uhland

Diana M. Perez

(Admitted pro hac vice)

O’MELVENY & MYERS LLP

7 Times Square

New York, NY 10036

Tel: (212) 326-2000

Fax: (212) 326-2061

-andPeter Friedman

(Admitted pro hac vice)

O’MELVENY & MYERS LLP

1625 Eye Street, NW

Washington, DC 20006

Tel: (202) 383-5300

Fax: (202) 383-5414

Attorneys for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority

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/s/ Andrés W. López 

Andrés W. López

USDC No. 215311

THE LAW OFFICES OF

ANDRÉS W. LÓPEZ, P.S.C.

902 Fernández Juncos Ave.

San Juan, PR 00907

Tel: (787) 294-9508

Fax: (787) 294-9519

Co-Attorney for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority

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