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 EXHIBITS 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 

Official Committee of Unsecured Creditors’ Derivative Standing Motion [ECF No. 3881] (the 

“Objection”) with a supporting Declaration of Matthew P. Kremer, Esq. in Support of the 

Objection of the Government Development Bank for Puerto Rico and the Puerto Rico Fiscal 

Agency and Financial Advisory Authority to the Official Committee of Unsecured Creditors’

Derivative Standing Motion [ECF No. 3881] (the “Declaration”) [ECF No. 3961]. 

 

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 included 

as exhibits A, B C and D to the Declaration various joint resolutions from the Puerto Rico 

Legislative Assembly (the “Joint Resolutions”). Nevertheless, due to time constrains, AAFAF and 

GDB were unable to translate the Joint Resolutions from their original Spanish language. 

Accordingly, AAFAF and GDB seek leave from this Court to submit the Joint Resolutions and 

request an extension until Tuesday, September 25, 2018, at 11:59 p.m. (AST) to file certified 

English translations of the Joint Resolutions 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 the same. 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 25, 2018, at 11:59 p.m. (AST) to submit the certified translations of the 

Joint Resolutions.

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: September 21, 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

MARINI PIETRANTONI MUÑIZ LLC

MCS Plaza, Suite 500

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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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