Hearing Date: June 28, 2017 at 9:30 a.m. 

UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO 

----------------------------------------------------------x 

In re: PROMESA 

Title III 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

No. 17 BK 3283-LTS 

THE COMMONWEALTH OF PUERTO RICO, 

et al., 

(Jointly Administered) 

Re: Docket No. 301 

Debtors.1

---------------------------------------------------------- 

RESERVATION OF RIGHTS OF THE MUTUAL FUND GROUP TO 

THE DEBTORS’ MOTION FOR ENTRY OF AN ORDER 

CONFIRMING THE APPLICATION OF THE AUTOMATIC STAY 

The Mutual Fund Group2

 hereby files this reservation of rights (the “Reservation of 

Rights”) 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, and (III) Application of Contract 

Protections [Dkt. No. 301, the “Motion”]. In support of the Reservation of Rights, the Mutual 

Fund Group respectfully states as follows: 

 

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) (Last Four Digits of Federal Tax ID: 8474). 

2

 The Mutual Fund Group consists of mutual funds managed by Oppenheimer Funds, Inc., Franklin 

Advisers, Inc., and the First Puerto Rico Family of Funds. 

Case:17-03283-LTS Doc#:380 Filed:06/17/17 Entered:06/17/17 18:21:56 Desc: Main

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RESERVATION OF RIGHTS 

1. On June 9, 2017, the Debtors filed the Motion. The objection deadline 

was originally set for June 16, 2017 at 4:00 p.m. ET. Pursuant to an agreement between the 

Mutual Fund Group and the Debtors, the objection deadline was extended to June 17, 2017 at 

11:59 p.m. ET. [Dkt. No. 362]. 

2. Although the Mutual Fund Group had significant concerns regarding the 

Proposed Order (as defined in the Motion), the Mutual Fund Group engaged in negotiations with 

the Debtors that culminated in a revised Proposed Order (the “Revised Proposed Order”) 

agreed to by the Debtors and the Mutual Fund Group that addresses those concerns. The Mutual 

Fund Group submits this Reservation of Rights to preserve the Mutual Fund Group’s right to 

object to the Motion, solely to the extent that the final Proposed Order presented to the Court 

differs from the Revised Proposed Order agreed to by the Debtors and the Mutual Fund Group. 

RESPECTFULLY SUBMITTED, 

In San Juan, Puerto Rico, today June 17, 2017. 

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TORO, COLÓN, MULLET, RIVERA 

& SIFRE, P.S.C. 

 s/ Manuel Fernandez-Bared 

MANUEL FERNÁNDEZ-BARED 

USDC-PR No. 204,204 

E-mail: mfb@tcmrslaw.com 

 s/ Linette Figueroa-Torres______ 

LINETTE FIGUEROA-TORRES 

USDC-PR No. 227,104 

E-mail: lft@tcmrslaw.com 

P.O. Box 195383 

San Juan, PR 00919-5383 

Tel.: (787) 751-8999 

Fax: (787) 763-7760 

Counsel to the Mutual Fund Group 

KRAMER LEVIN NAFTALIS & 

FRANKEL LLP 

 s/ Thomas Moers Mayer 

THOMAS MOERS MAYER* 

AMY CATON* 

PHILIP BENTLEY* 

DAVID E. BLABEY, JR.* 

DOUGLAS BUCKLEY* 

1177 Avenue of the Americas 

New York, New York 10036 

Tel.: (212) 715-9100 

Fax: (212) 715-8000 

Email: tmayer@kramerlevin.com 

acaton@kramerlevin.com 

pbentley@kramerlevin.com 

dblabey@kramerlevin.com 

dbuckley@kramerlevin.com 

*(pro hac vice application pending) 

Counsel to the Mutual Fund Group 

CERTIFICATE OF SERVICE 

I hereby certify that, on this same date, I electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system, which will send notifications of such filing to 

all CM/ECF participants in this case. 

s/ Manuel Fernandez-Bared 

MANUEL FERNÁNDEZ-BARED 

USDC-PR No. 204,204 

P.O. Box 195383 

San Juan, PR 00919-5383 

Tel.: (787) 751-8999 

Fax: (787) 763-776 

E-mail: mfb@tcmrslaw.com 

Case:17-03283-LTS Doc#:380 Filed:06/17/17 Entered:06/17/17 18:21:56 Desc: Main

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