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)

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

Re: ECF Nos. 815 (Case No. 17-4780), 

2985 (Case No. 17-3283) 

MASTER LINK CORPORATION,

Movant,

-againstTHE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY,

Respondent.

Motion in Compliance with Order 

Relates Only to PREPA and Shall 

Only be Filed in Case Nos. 

17 BK 3283-LTS and 17 BK 4780-

LTS

 

1

 The Debtors in the jointly-administered Title III cases, along with each Debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations 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) 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); (iv) Puerto Rico Highways 

and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) (Last Four Digits of Federal 

Tax ID: 3808); 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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JOINT MOTION IN COMPLIANCE WITH ORDER RELATED TO 

MASTER LINK CORPORATION’S MOTION FOR RELIEF OF STAY

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

On behalf of the Puerto Rico Electric Power Authority (“PREPA”), the Puerto Rico 

Fiscal Agency and Financial Advisory Authority (“AAFAF”) pursuant to the authority granted to 

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

and Movant, Masterlink Corporation (“ML”), respectfully submit this Joint Motion in 

Compliance with Order (the “Motion”). In support of the Motion, the parties respectfully state as 

follows:2

1. On July 16, 2018, this Court issued an order granting ML’s unopposed request 

for an extension of time to file a joint report and extended the deadline to July 25, 2018. [Dkt.

No. 3524.] The joint report pertains to this Court’s order entered on May 1, 2018 (the “Initial 

Order”) concerning the parties’ “efforts to seek to develop a mutually acceptable resolution of 

the outstanding performance bond issue or, at minimum, an agreed statement regarding the 

nature and pendency of the stayed litigation that can be used in connection with inquiries as 

ML’s bids for business.” [Dkt. No. 2985 at 6.]

2. In compliance with the Initial Order, the parties hereby inform the Court of the 

efforts made by both parties to reach an agreement as related to the nature and pendency of 

the stayed litigation and ML’s concerns regarding the potential impact of the pending 

litigation in relation to its commercial prospects with PREPA.

3. Counsel for each of the parties met on July 12, 2018. After the meeting, 

PREPA’s counsel provided ML with some documents regarding ML’s contracts with PREPA 

 

2 The Financial Oversight and Management Board for Puerto Rico, as the Debtors’ representative pursuant to 

section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), has 

authorized AAFAF to join in this Motion on behalf of PREPA. 

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and both parties are currently in the process of drafting a mutually acceptable statement that 

will address the Court’s Initial Order and both parties’ concerns going forward.

4. Accordingly, the parties respectfully request that the parties provide the Court

a joint status report on these efforts on or before August 27, 2018.

RESPECTFULLY SUBMITTED.

I HEREBY CERTIFY that on this date, I have electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system, which will send notification of such filing 

to counsel of record.

In San Juan, Puerto Rico, this 25th of July, 2018.

THE PUERTO RICO FISCAL

AGENCY AND FINANCIAL

ADVISORY AUTHORITY, as Fiscal 

Agent for PREPA

By its attorneys,

/s/ Kevin D. Finger 

Kevin D. Finger (admitted pro hac vice)

David D. Cleary (admitted pro hac vice)

Greenberg Traurig, LLP

77 West Wacker Drive Suite 3100

Chicago, IL 60601

Phone: 312.456.8400

Fax: 312.456.8435

Email: fingerk@gtlaw.com 

 clearyd@gtlaw.com 

Nathan A. Haynes (admitted pro hac vice)

Greenberg Traurig, LLP

200 Park Avenue

New York, NY 10166

Phone: 212.801.9200

Fax: 212.801.6400

 Email: mitchelln@gtlaw.com

MOVANTS MASTERLINK

S/Henry Vázquez Irizarry

USDC No. 205011

Bufete Vázquez Irizarry, 

CSP Urb. Villa Fontana 

Park

Calle Parque Luis M. Rivera 5 

HH6 Carolina, PR 00983

Tel. (787) 724-7514 / 787-645-2241

Fax (888) 518-1318

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 haynesn@gtlaw.com 

Joseph P. Davis (admitted pro hac vice)

Greenberg Traurig, LLP

One International Place, Suite 2000

Boston, MA 02110

Phone: 617.310.6000

Fax: 617.310.6001

Email: davisjo@gtlaw.com

THE PUERTO RICO ELECTRIC

POWER AUTHORITY

By its attorneys,

/s/ Arturo Díaz Angueria

USDC No. 117907

/s/ Katiuska Bolaños Lugo

USDC No. 231812

CANCIO, NADAL, RIVERA & DÍAZ,

P.S.C.

PO Box 364966

San Juan, PR 00936-4966

Phone: (787) 767-9625

Fax: (787) 764-4430

Email: adiaz@cnrd.com

kbolanos@cnrd.com

Dated: July 25, 2018

San Juan, Puerto Rico

TCO 363170336v2

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