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 

Case 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 

Case No. 17 BK 4780-LTS 

Re: ECF Nos. 815 (Case No. 17-4780), 

2985 (Case No. 17-3283) 

MASTER LINK CORPORATION, 

Movant, 

-againstTHE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

 as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

Respondent. 

Motion in Compliance with Order 

Relates Only to PREPA and Shall 

Only be Filed in Case Nos. 

17 BK 3283-LTS and 17 BK 4780-

LTS

 

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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JOINT MOTION IN COMPLIANCE WITH ORDER RELATED TO 

MASTER LINK CORPORATION’S MOTION FOR RELIEF OF STAY

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

On behalf of the Puerto Rico Electric Power Authority (“PREPA”), the Puerto Rico 

Fiscal Agency and Financial Advisory Authority (“AAFAF”) pursuant to the authority granted to 

it under the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, 

and Movant, Masterlink Corporation (“ML”), respectfully submit this Joint Motion in 

Compliance with Order (the “Motion”). In support of the Motion, the parties respectfully state as 

follows:2

1. On July 16, 2018, this Court issued an order granting ML’s unopposed request 

for an extension of time to file a joint report and extended the deadline to July 25, 2018. [Dkt. 

No. 3524.] The joint report pertains to this Court’s order entered on May 1, 2018 (the “Initial 

Order”) concerning the parties’ “efforts to seek to develop a mutually acceptable resolution of 

the outstanding performance bond issue or, at minimum, an agreed statement regarding the 

nature and pendency of the stayed litigation that can be used in connection with inquiries as 

ML’s bids for business.” [Dkt. No. 2985 at 6.] 

2. In compliance with the Initial Order, on July 25, 2018, the parties informed the 

Court of the efforts made by both parties to reach an agreement as related to the nature and 

pendency of the stayed litigation and ML’s concerns regarding the potential impact of the 

pending litigation in relation to its commercial prospects with PREPA. [Dkt. No. 3696] 

3. At the time, the parties requested until October 7, 2018 to inform the Court of 

the status of a mutually agreeable statement regarding both parties’ concerns going forward. 

 

2

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

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

authorized AAFAF to join in this Motion on behalf of PREPA. 

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4. The parties hereby inform the Court that the parties are in communication and 

still in the process of discussing possible alternatives and drafting a mutually acceptable 

statement. 

5. Notwithstanding, the parties are exchanging the draft versions and the 

documents. 

6. Accordingly, the parties respectfully request that the parties provide the Court 

a joint status report on these additional efforts on or before October 22, 2018. 

WHEREFORE, the herein appearing party respectfully requests the Honorable Court to 

grant the requested extension of time, until October 22, 2018. 

WE HEREBY CERTIFY that on this date, I have electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF system, which will send notification of such 

filing to counsel of record. 

RESPECTFULLY SUBMITTED. 

In San Juan, Puerto Rico, this 5th of October, 2018. 

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 

MOVANTS MASTERLINK 

S/ Alexis A. Betancourt Vincenty 

Alexis A. Betancourt Vincenty 

USDC-PR No. 301304 

Lugo Mender Group, LLC 

100 Carr. 165 Suite 501 

Guaynbao, P.R. 00968-8052 

Tel. (787) 707-0404 

Fax (787) 707-0412 

a_betancourt@lugomender.com 

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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: mitchelln@gtlaw.com 

 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 

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. 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 

Dated: October 5, 2018 

 San Juan, Puerto Rico 

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