Estimated Hearing Date: To be determined by the Court

Objection Deadline: To be determined by the Court

UNITED STATES DISTRICT COURT

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)

 LIGHTHOUSE GROUP LLC’S MOTION FOR EXTENSION OF TIME 

 TO FILE REPLY TO ECF 24749

1 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number 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) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-

LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) 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); 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).

Case:17-03283-LTS Doc#:24874 Filed:08/12/23 Entered:08/12/23 07:32:22 Desc: Main

Document Page 1 of 3
Estimated Hearing Date: To be determined by the Court

Objection Deadline: To be determined by the Court

TO THE HONORABLE LAURA TAYLOR SWAIN,

UNITED STATES DISTRICT JUDGE:

COMES NOW, Lighthouse Group, LLC (“Lighthouse”), represented by the undersigned 

attorneys, and very respectfully avers and prays as follows:

1. Lighthouse respectfully prays for an extension of time of Twenty (20) days, lapsing on 

Friday, September 1, 2023, to file its reply to the Financial Oversight and Management Board for 

Puerto Rico’s (“Board”) objection at ECF 24749 to the proof of claim filed by Lighthouse at claims 

docket ECF 15035.

2. Lighthouse is in the process of locating evidence which will allow it to file a comprehensive 

response to the objection filed by the Board. There are several transactions involved between the 

parties, including deed instruments recorded at the Commonwealth of Puerto Rico Registry of 

Property, which are relevant to Lighthouse’s reply brief.

3. The instant request will not unduly cause prejudice or cause unjustified delay in this matter,

however, Lighthouse prays that the hearing on the objection scheduled for August 30, 2023 be set 

aside pending the submission of all pertinent briefs.

NOTICE

4. Notice has hereby been served by CM/EF and on the Master Service List posted on the

website of the Debtors’ claims and noticing agent, by e-mail.

5. No prior request for the relief sought herein has been made to this Court or to any other 

Court.

WHEREFORE, LIGHTHOUSE GROUP, LLC respectfully prays that this Honorable Court grant 

it until Friday, September 1, 2023, to file its reply to the Financial Oversight and Management 

Board for Puerto Rico’s (“Board”) objection at ECF 24749 to the proof of claim filed by

Case:17-03283-LTS Doc#:24874 Filed:08/12/23 Entered:08/12/23 07:32:22 Desc: Main

Document Page 2 of 3
Estimated Hearing Date: To be determined by the Court

Objection Deadline: To be determined by the Court

Lighthouse at claims docket ECF 15035, that the hearing on the objection scheduled for August 

30, 2023 be set aside pending the submission of all pertinent briefs, with any other relief in its 

favor the Court deems proper.

RESPECTFULLY SUBMITTED.

Dated: August 12, 2023

Respectfully submitted,

REICHARD & ESCALERA, LLC

/s/ Fernando Van Derdys

Fernando Van Derdys, Esq.

USDC-PR 201913

fvander@reichardescalera.com

255 Ponce de León Avenue

MCS Plaza, 10th Floor

San Juan, PR 00917-1913

Telephone: (787) 777-8888

Case:17-03283-LTS Doc#:24874 Filed:08/12/23 Entered:08/12/23 07:32:22 Desc: Main

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