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

No. 17 BK 3283-LTS

(Jointly Administered)

AMENDED NOTICE OF FILING OF REVISED PROPOSED ORDER 

(A) APPROVING LIMITED OMNIBUS OBJECTION

PROCEDURES, (B) WAIVING THE REQUIREMENT OF 

BANKRUPTCY RULE 3007(e)(6), AND (C) GRANTING RELATED RELIEF

PLEASE TAKE NOTICE that on October 16, 2018, the Commonwealth of Puerto Rico 

(the “Commonwealth”), the Puerto Rico Sales Tax Financing Corporation (“COFINA”), the 

Puerto Rico Highways and Transportation Authority (“HTA”), the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico (“ERS”), and the Puerto Rico 

Electric Power Authority (“PREPA,” and together with the Commonwealth, COFINA, HTA, and 

ERS the “Debtors”), as Title III 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”), filed the Motion for Entry of an Order (A) Approving Limited Omnibus 

 

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).

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Objection Procedures, (B) Waiving the Requirement of Bankruptcy Rule 3007(e)(6), and (C) 

Granting Related Relief (the “Motion”) [ECF No. 4052]. Attached as Exhibit A to the Motion 

was a proposed order (the “Proposed Order”).

PLEASE TAKE FURTHER NOTICE that no objections have been filed with the 

Court in response to the Motion.

PLEASE TAKE FURTHER NOTICE that the Debtors received informal comments 

with respect to the Motion and the Proposed Order (the “Comments”).

PLEASE TAKE FURTHER NOTICE that the Debtors hereby file a revised proposed 

order, in the form attached hereto as Exhibit A, reflecting revisions made that address and 

resolve all of the Comments (the “Revised Proposed Order”).

PLEASE TAKE FURTHER NOTICE that a redline comparing the Revised Proposed 

Order against the Proposed Order is attached hereto as Exhibit B, demonstrating cumulative 

changes incorporated into the Revised Proposed Order.

PLEASE TAKE FURTHER NOTICE that, in light of the absence of any objections, 

and for the purposes of judicial economy, the Debtors request that the Revised Proposed Order 

be entered without a hearing.

PLEASE TAKE FURTHER NOTICE that copies of all documents filed in these title

III cases are available (a) free of charge by visiting https://cases.primeclerk.com/puertorico or by 

calling +1 (844) 822-9231, and (b) on the Court’s website at http://www.prd.uscourts.gov, 

subject to the procedures and fees set forth therein.

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Dated: October 31, 2018

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

USDC No. 215205

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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