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) 

Re: ECF No. 4051 

NOTICE OF FILING OF REVISED PROPOSED 

SIXTH OMNIBUS ORDER GRANTING RELIEF FROM THE AUTOMATIC STAY 

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”),2 filed the 

 

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). 

2

 PROMESA is codified at 48 U.S.C. §§ 2101-2241. 

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Debtors’ Sixth Omnibus Motion for Approval of Modifications to the Automatic Stay [ECF No. 

4051] (the “Motion”), requesting entry of an order retroactively approving the modifications to the 

automatic stay set forth in Bankruptcy Code sections 362(a) and 922(a) (the “Title III Stay”), (a) 

for the parties and actions set forth in Exhibit 1 to the proposed order attached to the Motion (the 

“Original Proposed Order”), nunc pro tunc to the dates specified therein, (b) for parties to certain 

forfeiture cases filed against the Commonwealth as set forth in Exhibit 2 to the Original Proposed 

Order, nunc pro tunc to the date of the Motion, and (c) for parties to certain administrative 

employment actions against debtor ERS as set forth in Exhibit 3 to the Original Proposed Order. 

PLEASE TAKE FURTHER NOTICE that on October 23, 2018, Cooperativa de Seguros 

Múltiples de Puerto Rico (“Cooperativa”) filed the Cooperativa de Seguros Multiples’ Objection 

to Debtors’ Sixth Omnibus Motion for Approval of Modifications to the Automatic Stay [ECF No. 

4051] [ECF No. 4092] (the “Objection”), objecting to the inclusion of certain actions set forth in 

Exhibit 2 to the Original Proposed Order. 

PLEASE TAKE FURTHER NOTICE that on October 23, 2018, the Court entered the 

Order Scheduling Briefing of Debtors’ Sixth Omnibus Motion for Approval of Modifications to the 

Automatic Stay [ECF No. 4093], setting October 30, 2018 as the deadline to file opposition papers 

to the Motion, and November 6, 2018 as the deadline for the Debtors to file reply papers. 

PLEASE TAKE FURTHER NOTICE that the Debtors and Cooperativa have reached a 

consensual resolution to the Objection by removing certain actions identified by Cooperativa from 

Exhibit 2 to the Original Proposed Order.3 Attached hereto as Exhibit A is the revised proposed 

 

3

 The Memorandum Order Denying Motion of Cooperativa de Seguros Multiples’ Motion for Clarification of the 

Automatic Stay and in the Alternative Relief from the Automatic Stay (Docket Entry No. 1276) [ECF No. 1765], 

entered on November 13, 2017, shall continue to govern the cases identified in Exhibit A to the Cooperativa de 

Seguros Multiples’ Motion for Clarification of Automatic Stay and in the Alternative Relief from the Automatic 

Stay [ECF No. 1276]. 

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order incorporating such changes to the schedule of actions in Exhibit 2 (the “Revised Proposed 

Order”). Attached hereto as Exhibit B is a redline of Exhibit 2 attached to the Original Proposed 

Order against Exhibit 2 attached to the Revised Proposed Order.

PLEASE TAKE FURTHER NOTICE that copies of the Motion, the Original Proposed 

Order, the Revised Proposed Order, and all other 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. 

Remainder of Page Intentionally Left Blank 

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PLEASE TAKE FURTHER NOTICE that the Debtors respectfully request that the 

Court consider and enter the attached Revised Proposed Order granting the relief requested therein. 

Dated: November 5, 2018 

 San Juan, Puerto Rico 

Respectfully submitted, 

/s/ Martin J. Bienenstock 

 

Martin J. Bienenstock (admitted pro hac vice) 

Brian S. Rosen (admitted pro hac vice) 

Paul V. Possinger (admitted pro hac vice) 

Ehud Barak (admitted pro hac vice) 

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 

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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