UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

-------------------------------------------------------------x

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 3163, 3167

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO

Debtor.

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3283-LTS

This Assented-To Motion relates 

only to the Commonwealth and 

shall only be filed in the lead 

Case No. 17 BK 3283-LTS 

ASSENTED-TO URGENT MOTION FOR EXTENSION OF DEADLINES

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

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

2 with Virgilio F. Acevedo’s

(“Movant”) assent, respectfully submit this assented-to urgent motion for entry of an order, 

 

1The 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

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

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

authorized the Department of Justice to file this Assented-To Motion on behalf of the Commonwealth. 

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substantially in the form attached hereto as Exhibit A (the “Proposed Order”), extending the 

deadlines set forth in the Order Scheduling Briefing of Motion by Virgilio F. Acevedo for Relief 

from Automatic Stay [ECF No. 3167] (the “Scheduling Order”).

Request for Relief

1. On May 27, 2018, Movant filed its Motion by Virgilio F. Acevedo for Relief from 

Automatic Stay [ECF No. 3163] (the “Motion”), seeking relief from the automatic stay to 

commence an adversary proceeding (the “Adversary Proceeding”) in Movant’s bankruptcy case 

in the United States Bankruptcy Court for the District of Massachusetts, Case Number 14-15154, 

against the Registrar of the Registry of Deeds of Aguadilla, Puerto Rico, in her official capacity, 

to “ascertain vested hereditary rights over a structure/gas station located in Rincon, Puerto Rico.” 

Motion at 3. In the alternative, Movant seeks a determination that the automatic stay does not 

apply to the Adversary Proceeding. 

2. On May 29, 2018, the Court entered the Scheduling Order, which provides that 

opposition papers to the Motion must be filed by June 11, 2018, and Movant’s reply papers must 

be filed by June 18, 2018.

3. The Commonwealth and Movant are in the process of negotiating a possible 

consensual resolution of the Motion and thus, the Commonwealth and Movant 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 June 29, 2018. 

 The deadline for Movant to file a reply to any oppositions shall be extended to July 6, 

2018. 

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4. Pursuant to Paragraph 1.H of the Fourth Amended Notice, Case Management and 

Administrative Procedures [ECF No. 2839-1] (the “Case Management Procedures”), the 

Commonwealth hereby certifies that it has carefully examined the matter and concluded that 

there is a true need for an urgent motion; has not created the urgency through any lack of due 

diligence; has made a bona fide effort to resolve the matter without a hearing; has made 

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

brought to the Court; and has conferred with counsel for the Oversight Board, and no party 

opposes the relief requested herein. 

Notice

5. The Commonwealth 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) Movant. A copy of the 

motion is also available on the Debtors’ case website at https://cases.primeclerk.com/puertorico/.

6. The Commonwealth submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

WHEREFORE, the Commonwealth, with Movant’s assent, respectfully requests the 

Court enter the Proposed Order and grant such other relief as is just and proper. 

 

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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Dated: June 11, 2018 

San Juan, Puerto Rico 

Respectfully submitted, 

WANDA VÁZQUEZ GARCED 

Secretary of Justice

/s/ Wandymar Burgos Vargas

WANDYMAR BURGOS VARGAS\

USDC 223502

Deputy Secretary in Litigation

Department of Justice

P.O. Box 9020192

San Juan, Puerto Rico 00902-0192

Phone: 787-721-2940 Ext. 2500, 2501

wburgos@justicia.pr.gov

Attorneys for the Commonwealth of Puerto 

Rico

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Exhibit A

Proposed Order

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UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

-------------------------------------------------------------x

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 3163, 3167

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO

Debtor.

-------------------------------------------------------------x

PROMESA

Title III

No. 17 BK 3283-LTS

This Order relates only to the 

Commonwealth and shall only 

be filed in the lead Case No. 17 

BK 3283-LTS 

ORDER EXTENDING DEADLINES UNDER

ORDER SCHEDULING BRIEFING IN CONNECTION WITH

MOTION BY VIRGILIO F. ACEVEDO FOR RELIEF FROM AUTOMATIC STAY 

 

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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Upon the Assented-To Urgent Motion for Extension of Deadlines (the “Extension 

Motion”);

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 Extension 

Motion is in the best interests of the Commonwealth and Movant; and the Court having found 

that the Commonwealth 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 deadline to file oppositions to the Motion by Virgilio F. Acevedo for Relief from 

Automatic Stay [ECF No. 3163], or to otherwise respond, shall be extended to June 

29, 2018.

3. The deadline for Movant to file a reply to any oppositions shall be extended to July 6, 

2018. 

4. This Order resolves docket entry no. _____ in Case No. 17-3283.

Dated: ___________, 2018

___________________________________

HONORABLE LAURA TAYLOR SWAIN

UNITED STATES DISTRICT JUDGE

 

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

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