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 

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 

No. 17 BK 4780-LTS

Re: Dkt. Nos. 881, 882

Motion Relates Only to PREPA and 

Shall be Filed in Both the Lead Case 

No. 17 BK-3283-LTS and in 

PREPA’s Title III Case No. 17 BK 

4780-LTS

JOINT MOTION FOR AN EXTENSION OF TIME IN CONNECTION 

WITH LORD ELECTRIC COMPANY OF PUERTO RICO, INC.’S

MOTION FOR ALLOWANCE OF ADMINISTRATIVE EXPENSE CLAIMS

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

the Puerto Rico Electric 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, and Lord 

Electric Company of Puerto Rico, Inc. (“Movant”), by and through their undersigned counsel, 

 

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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respectfully submit this joint motion for entry of an order, substantially in the form attached hereto 

as Exhibit A, extending the deadlines in connection with the Motion for Allowance of Administrative 

Expense Claims [Case No. 17-04780, Dkt. No. 881] (the “Motion for Administrative Expense 

Claims” or “Motion”) filed by Movant.

2

 In support of this motion, the parties respectfully state as 

follows:

BACKGROUND

On June 22, 2018, the Movant filed the Motion for Administrative Expense Claims seeking 

the allowance of an alleged post-petition administrative expense claim in the amount of 

$1,091,860.96. Pursuant to this Court’s order entered on June 22, 2018, any opposition to the 

Motion for Administrative Expense Claims must be filed by July 6, 2018, and any reply must be 

filed by July 13, 2018 [Case No. 17-04780, Dkt. No. 882].

Counsel for AAFAF and Movant have had two conferences to discuss a mutually agreeable 

resolution of the Motion. Counsel for AAFAF, however, requires additional time to obtain and 

review information pertinent to the Motion. As a result, AAFAF requested, and Movant agreed, to 

extend the date by which AAFAF’s response to the Motion is due. AAFAF submits that no party 

or creditor will be prejudiced by this extension. 

RELIEF REQUESTED

In consideration of the foregoing, the parties have agreed to a seven (7) day extension of the 

applicable deadlines. The parties request entry of an order extending the deadlines as follows: 

• Any opposition to the Motion for Administrative Expense Claims shall be filed by 

July 13, 2018. 

 

2 The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), as the Debtors’ 

representative pursuant to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act

(“PROMESA”), 48 U.S.C. §§ 2101-2241, has authorized AAFAF to file this motion on behalf of PREPA.

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• Any reply in support of the Motion shall be filed by July 20, 2018.

WHEREFORE, the parties request the Court to enter an order, substantially in the form 

attached hereto as Exhibit A, (a) granting the motion and (b) granting such other relief as is just and 

proper.

Dated: July 6, 2018 Respectfully submitted,

San Juan, Puerto Rico

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: 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

LORD ELECTRIC COMPANY

OF PUERTO RICO, INC.

By its attorneys,

/s/ Nanette Rickenbach 

Nanette Rickenbach 

USDC-PR No. 230208

Myrna Ruiz-Olmo

USDC-PR No. 223209

RICKENBACH OJEDA ATTORNEYS AT 

LAW PSC

400 Juan Calaf PMB 232

San Juan, PR 00918

Phone: (787) 723-8083

Fax: (787) 723-8085

Email: nrickenbach@rickenbachpr.com

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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. 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

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Exhibit A

Proposed Order

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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 

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 

No. 17 BK 4780-LTS

Re: Dkt. Nos. 881, 882

This Order Relates Only to PREPA 

and Shall be Filed in Both the Lead 

Case No. 17 BK-3283-LTS and in 

PREPA’s Title III Case No. 17 BK 

4780-LTS

ORDER GRANTING JOINT MOTION FOR AN EXTENSION

OF TIME IN CONNECTION WITH LORD ELECTRIC 

COMPANY OF PUERTO RICO, INC.’S MOTION

FOR ALLOWANCE OF ADMINISTRATIVE EXPENSE CLAIMS

Upon the Joint Motion for an Extension of Time in Connection with Lord Electric Company 

of Puerto Rico, Inc.’s Motion for Allowance of Administrative Expense Claims (the “Motion”)2

 

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).

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

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and the Court having found it has subject matter jurisdiction over this matter pursuant to 

PROMESA section 306(a); and it appearing that venue is proper pursuant to PROMESA section 

307(a); and the Court having found that the relief requested in the Motion is in the best interests 

of the Debtors, their creditors, and other parties in interest, it is HEREBY ORDERED THAT: 

1. The Motion is granted. 

2. Any opposition to the Motion for Administrative Expense Claims shall be due on July 

13, 2018. 

3. Any reply shall be due on July 20, 2018. 

4. This Court retains exclusive jurisdiction with respect to all matters arising from or related 

to the implementation, interpretation, and enforcement of this Order. 

5. This Order resolves docket entry no._______. 

SO ORDERED. 

Dated: _________________, 2018 ________________________

San Juan, Puerto Rico LAURA TAYLOR SWAIN 

UNITED STATES DISTRICT JUDGE

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