UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

 RE:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO

RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO

RICO, ET AL.

DEBTOR

 PROMESA Title III 

 No. 17 BK 3283-LTS 

 (Jointly Administered)

PROMESA Title III 

 No. 17 BK 4780-LTS

 

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO

RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER

AUTHORITY, 

 

 DEBTOR

 Relief of the Automatic Stay Of acts 

 against property under 11 U.S.C. 362 

 D(1) “Cause”

WITHDRAWAL OF MOTION FOR RELIEF FROM STAY

AND 

CERTIFICATE OF SERVICE

COMES NOW, Martami, Inc. (“Movant”), through the undersigned counsel and

very respectfully moves the Court for an Order granting the withdrawal of the 11 U.S.C.

§ 362 motion for relief from the Automatic Stay. 

FACTS AND AVERMENTS

1. That on July 18th, 2018, Movant filed a Motion for Relief from Stay Under 11

U.S.C. § 362 [e] (See docket entry number 3614).

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2. That on July 19th, 2018, the Honorable Court issued an or ORDER SCHEDULING

BRIEFING OF MOTION FOR RELIEF FROM STAY, informing that the Opposition

papers were due by August 1st, 2018; and Movant's reply due by August 8th, 2018 (See

docket entry number 3624).

3. That after granting a first joint motion for extension of time for deadlines in

relation to the motion for Relief from Stay (See Dockets 3731 & 3733), the Honorable

Court entered and ORDER GRANTING a Second Urgent Joint Motion for Extension of

Deadlines filed at docket 3752; informing that the opposition papers must be filed by

August 15th, 2018 at 5:00 p.m. (Atlantic Standard Time) and the reply papers must be

filed by August 22nd, 2018 at 5:00 p.m. (Atlantic Standard Time). (See docket entry

number 3754).

4. That the parties have amicably reached an agreement and the Fiscal Board will file

an omnibus Motion on August 17th, 2018, which will include the joint stipulation; and

said stipulation will take care of the matters in the Motion for Relief From Stay.

5. Wherefore, based on the aforementioned, Movant hereby withdraws the Motion for

Relief From Stay filed at docket number 3614.

PRAYER FOR RELIEF

WHEREFORE, Movant respectfully requests that the Court enter an order granting the

withdrawal of the motion for relief from the automatic stay filed at docket 3614 and any

other further relief as the Court deems proper under Law and Equity. 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY: That on this day, I

electronically filed the foregoing motion with the

Clerk of the Court using CM/ECF Filing system

which will send notification to the parties and

subscribed users. 

 RESPECTFULLY SUBMITTED: 

In Bayamon, Puerto Rico, this 15th day of August of 2018. 

/s/ Ruben Gonzalez Marrero, Esq.

Ruben Gonzalez Marrero

Gonzalez & Velasco Law Offices, P.S.C. 

Carr. 174; Blq. 21-24

Santa Rosa, Bayamon, PR 00959

Tel. 787-798-8600 

E-mail(s): rgmattorney1pr@gmail.com

[Gonzalez & Velasco Law Office, P.S.C.] 

rgm@microjuris.com

[Ruben Gonzalez Marrero] 

Velascolaw@hotmail.com

 [Jaime L. Velasco Bonilla]

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