UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

MOTION OF THE GOVERNMENT DEVELOPMENT BANK FOR PUERTO RICO 

AND THE PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY 

AUTHORITY FOR LEAVE TO SUBMIT SPANISH LANGUAGE CASE LAW AND 

FOR EXTENSION OF TIME TO FILE CERTIFIED TRANSLATIONS

TO THE HONORABLE COURT: 

The Government Development Bank for Puerto Rico (the “GDB”) and the Puerto Rico 

Fiscal Agency and Financial Advisory Authority (“AAFAF”), through the undersigned attorneys, 

respectfully state as follows: 

1. Today, AAFAF and the GDB filed their Objection of the Government Development 

Bank for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority to the 

Urgent Motion of Official Committee of Unsecured Creditors, Pursuant to Bankruptcy Code 

Sections 105(a) and 362, for Entry of Order Enforcing Automatic Stay and Court’s June 29, 2017 

Order Confirming Application of Automatic Stay with Respect to GDB Restructuring (the 

“Objection”) [ECF No. 3826]. 

 

1 The Debtors in these 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); and (ii) The Employees Retirement System of the Government of the Commonwealth of 

Puerto Rico (“ERS”) (Bankruptcy Case No. 17 BK 3566) (Last Four Digits of Federal Tax ID: 9686).

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2. In support of the arguments included in the Objection, AAFAF and GDB cited

various cases from the Puerto Rico Supreme Court including: Rodríguez Román v. Banco 

Gubernamental de Fomento para Puerto Rico, 151 D.P.R. 383 (2000), Commoloco of Caguas, 

Inc. v. Benítez Díaz, 126 D.P.R. 478 (1990) and Amieiro Gozález v. Pinnacle Real Estata Home 

Team, 173 D.P.R. 363 (2008) (jointly, the “Spanish Case Law”). Nevertheless, due to time 

constrains, AAFAF and GDB were unable to translate the Spanish Case Law from their original 

Spanish language. Accordingly, AAFAF and GDB seek leave from this Court to submit the 

Spanish Case Law and request an extension of seven (7) days to file certified English translations 

of the Spanish Case Law pursuant to Local District Court Rule 5(g). 

3. AAFAF and GDB have diligently tried to obtain certified translations of these

documents. Nevertheless, they have not had sufficient time to obtain certified translations. 

AAFAF and GDB are in the process of doing so on an expedited basis.

4. Accordingly, AAFAF and GDB respectfully request that the Court enter an order 

substantially in the form attached hereto as Exhibit A (the “Proposed Order”) granting AAFAF 

and GDB until September 5, 2018 to submit the certified translations of the Spanish Case Law. 

WHEREFORE, AAFAF and GDB respectfully request this Honorable Court enter the 

Proposed Order attached as Exhibit A hereto and grant such other relief as is just and proper. 

Dated: August 29, 2018

San Juan, Puerto Rico

Respectfully submitted,

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Carolina Velaz-Rivero

USDC No. 300913

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MARINI PIETRANTONI MUÑIZ LLC

MCS Plaza, Suite 500

255 Ponce de León Ave.

San Juan, Puerto Rico 00917

Tel: (787) 705-2171

Fax: (787) 936-7494

- and -

O’MELVENY & MYERS LLP

John J. Rapisardi 

Suzzanne S. Uhland

Peter Friedman

(Admitted Pro Hac Vice)

7 Times Square

New York, NY 10036

Tel: (212) 326-2000

Fax: (212) 326-2061

Attorneys for the Puerto Rico Fiscal Agency and 

Financial Advisory Authority and the Government 

Development Bank for Puerto Rico 

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Exhibit A

Proposed Order

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