UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.

 Debtors.1

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PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO (“ERS”),

2

Debtor

PROMESA

Title III

No. 17 BK 3566-LTS

(Joint Administration Requested)

 

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) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case 

No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474).

2

The last four (4) digits of ERS’s federal tax identification number are 9686.

Case:17-03283-LTS Doc#:362 Filed:06/16/17 Entered:06/16/17 14:59:39 Desc: Main

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In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”),

3

Debtor.

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PROMESA

Title III

No. BK 3567-LTS

(Joint Administration Requested)

NOTICE OF CONSENSUAL EXTENSION OF OBJECTION DEADLINE 

REGARDING MOTION OF DEBTORS PURSUANT TO PROMESA SECTION 301(A) 

AND BANKRUPTCY CODE SECTIONS 105(A), 362(A), 365, AND 922 FOR ENTRY OF 

ORDER CONFIRMING (I) APPLICATION OF THE AUTOMATIC STAY TO 

GOVERNMENT OFFICERS, AGENTS, AND REPRESENTATIVES (II) STAY OF 

PREPETITION LAWSUITS AND ACTIONS AGAINST INHABITANTS OF PUERTO

RICO (III) APPLICATION OF CONTRACT PROTECTIONS

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

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

Financing Corporation (“COFINA”), the Puerto Rico Highways and Transportation Authority 

(“HTA”), and the Employees Retirement System of the Government of the Commonwealth of 

Puerto Rico, as Title III debtors (the “ERS,” and together with the Commonwealth, COFINA, 

and HTA, the “Debtors”), by and through 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”),4

respectfully file this notice of their consent to the extension of the deadline for certain parties in 

interest (the “Saturday Extension Parties”

5

and the “Monday Extension Parties”

6

) to file an 

 

3

The last four (4) digits of HTA’s federal tax identification number are 3808.

4

PROMESA has been codified in 48 U.S.C. §§ 2101-2241.

5

The Saturday Extension Parties are as follows: Oppenheimer Funds, Franklin Funds and First 

Puerto Rico Family of Funds.

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objection to the Motion of Debtors Pursuant to PROMESA Section 301(A) and Bankruptcy Code 

Sections 105(A), 362(A), 365, and 922 For Entry of Order Confirming (I) Application of the 

Automatic Stay to Government Officers, Agents, and Representatives (II) Stay of Prepetition 

Lawsuits and Actions Against Inhabitants of Puerto Rico (III) Application of Contract

Protections (the “Motion”) [D.I. 301]. The original deadline to object to the Motion pursuant to

¶¶ III.I and III.T of this Court’s First Amended Notice, Case Management and Administrative 

Procedures [D.I. 262-1] (the “Case Management Procedures”) is Friday, June 16, 2017 at 4:00 

p.m. (Prevailing Eastern Time). The Debtors have agreed to extend the deadline for the Saturday 

Extension Parties to file an objection to the Motion to 11:59 p.m. (Prevailing Eastern Time) on 

Saturday, June 17, 2017 and the Monday Extension Parties to file an objection to the Motion to 

4:00 p.m. (Prevailing Eastern Time) on Monday, June 19, 2017. See Case Management 

Procedures, at ¶ III.I (providing that the deadline to file an objection to any pleading “may be 

extended with the consent of the movant or applicant,” provided that the “movant shall provide 

notice of the extension to Chambers”). 

 

6

The Monday Extension Parties are as follows: certain funds or entities managed or advised by

Aurelius Capital Management, LP, Autonomy Capital (Jersey) LP, FCO Advisors LP, Franklin 

Mutual Advisers LLC, Monarch Alternative Capital LP, Senator Investment Group LP, and 

Stone Lion L.P.

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Dated: June 16, 2017

San Juan, Puerto Rico

Respectfully submitted,

/s/ Martin J. Bienenstock

Martin J. Bienenstock

Paul V. Possinger

Ehud Barak

Maja Zerjal

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial 

Oversight and Management Board 

as representative for the Debtors

/s/ Hermann D. Bauer

Hermann D. Bauer

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-Attorneys for the Financial 

Oversight and Management Board 

as Representative for the Debtors

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