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 Nos. 3928, 3930

(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 

No. 17 BK 4780-LTS 

This motion relates to PREPA and 

shall be filed in Case Nos. 17 BK 

3283-LTS and 17 BK 4780-LTS.

CONSENTED MOTION FOR EXTENSION OF DEADLINES

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

The Puerto Rico Fiscal Agency and Financial Authority (“AAFAF”), on behalf of the 

Puerto Rico Power Authority (“PREPA”), pursuant to the authority granted to it under the 

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

 

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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submits this urgent consented motion for extension of deadlines, substantially in the form attached 

hereto as Exhibit A (the “Proposed Order”), extending the deadlines set forth in the Order 

Scheduling Briefing of Motion for Relief from Stay and for a Ruling that a Judgement on a Claim 

Arrising from the Taking of Properties Without Just Compensation is Not Subject to Reduction or 

Compensation in Bankruptcy [Case No. 17 BK 3283, ECF No. 3930] (the “Scheduling Order”).2

Request for Relief

1. On September 12, 2018, Ismael L. Purcell-Soler, Alys Collazo-Bougeois and the

community of property they compose (collectively, “Movants”) filed the Motion for Relief From 

Stay and for a Ruling that a Judgment on a Claim Arising from the Taking of Properties Without

Just Compensation is Not Subject to Reduction or Compensation in Bankruptcy [Case No. 17 BK 

3283, ECF No. 3928] (the “Motion”), seeking an order (i) lifting the automatic stay with respect 

to the case captioned Ismael Purcell-Soler, et al. v. Puerto Rico Electric Power Authority, et al., 

Case No. JDP 2012-0406 (the “Prepetition Action”), before the Puerto Rico Court of First Instance, 

and (ii) holding that any judgment entered in the Prepetition Action is not subject to reduction or 

compromise. Motion at 21.

2. On August 9, 2018 the Court entered the Scheduling Order, which provides that

opposition papers to the Motion must be filed by September 26, 2018 and Movant’s reply papers 

must be filed by October 3, 2018.

3. PREPA is in the process of reviewing the pertinent information regarding the facts 

and issues raised in the Motion in an effort to seek a consensual resolution to the Motion. In 

 

2 The Financial Oversight and Management Board for Puerto Rico, as PREPA’s representative pursuant to section 

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

AAFAF to file this motion on behalf of PREPA.

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consideration of the foregoing, PREPA, with Movants’ consent, have agreed to the following 

extensions of the deadlines set forth in the Scheduling Order:

• The deadline to file oppositions to the Motion, or to otherwise respond, shall be 

extended to October 5, 2018.

• The deadline for Movants to file reply papers to any oppositions shall be 

extended to October 12, 2018.

4. PREPA discussed this request with counsel for Movants who consented to the relief 

requested herein.

Notice

5. PREPA 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

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) Movants. A copy of the motion is also available

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

6. PREPA submits that, in light of the nature of the relief requested, no other or further 

notice need be given.

WHEREFORE, PREPA respectfully requests the Court enter the Proposed Order and

grant such other relief as is just and proper.

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Dated: September 24, 2018

San Juan, Puerto Rico

Respectfully submitted, 

/s/ Arturo Diaz-Angueira 

Arturo Diaz-Angueira 

USDC No. 117907

adiaz@cnrd.com

/s/ Katiuska Bolaños-Lugo

Katiuska Bolaños-Lugo

USDC No. 231812

kbolanos@cnrd.com

CANCIO, NADAL, RIVERA & DIAZ, PSC 

403 Muñoz Rivera Ave.

San Juan, PR 00918-3345

Tel: (787) 767-9625

Fax: (787) 622-2230

Attorneys for the Puerto Rico Electric 

Power Authority

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Exhibit A

Proposed Order

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