UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

 as representative of : Case No. 17-BK-3283 (LTS) 

 : 

THE COMMONWEALTH OF PUERTO RICO, et al., : (Jointly Administered) 

 : 

Debtors.1

 : 

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INFORMATIVE MOTION REGARDING WITHDRAWAL, WITHOUT PREJUDICE, 

OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS’ URGENT MOTION, 

PURSUANT TO BANKRUPTCY CODE SECTION 105(a), TO COMPEL DEBTORS TO 

COMPLY WITH INTERIM COMPENSATION ORDERS

To the Honorable United States District Court Judge Laura Taylor Swain: 

The Official Committee of Unsecured Creditors of all Title III Debtors (other than 

COFINA) (the “Committee”) hereby states as follows: 

1. On July 18, 2018, the Committee filed its (A) Urgent Motion, Pursuant To 

Bankruptcy Code Section 105(a), to Compel Debtors to Comply With Interim Compensation 

Orders and (B) Joinder in Motions of Retiree Committee and COFINA Agent to Compel 

 

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), (ii) 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), (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK3567 (LTS)) (Last Four Digits of Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17-BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); and (v) 

Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780) (Last Four Digits of 

Federal Tax ID: 3747). 

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Compliance with Same [Docket No. 3604] (the “Motion to Compel”)2

 and the related motion to 

expedite the hearing on the Motion to Compel [Docket No. 3605] (the “Motion to Expedite”). 

2. By order dated July 18, 2018 [Docket No. 3608], the Court granted the Motion to 

Expedite, setting the hearing on the Motion to Compel for the omnibus hearing scheduled on 

July 25, 2018. 

3. On July 19, 2018, Paul Hastings received a partial payment on account of its 

outstanding fees and expenses. In order to allow the parties to seek a consensual resolution 

regarding payment of the remaining portion of Paul Hastings’ outstanding fees and expenses, 

without the need to involve the court, the Committee adjourned (with the consent of the Puerto 

Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”)) the Motion to Compel, 

solely as it relates to its request to compel payment of Paul Hastings’ outstanding fees and 

expenses, to the September 13, 2018 omnibus hearing.3 

4. On July 23, 2018, the Committee withdrew the Motion to Compel, solely as it 

relates to the Committee’s request to compel payment of Kroma’s fees and expenses, without 

prejudice to renewing such request in the future.4 

5. Subsequently, the Committee further adjourned (with the consent of AAFAF) the 

Motion to Compel, as it relates to its request to compel payment of Paul Hastings’ outstanding 

fees and expenses, to the November 7, 2018 omnibus hearing.5

 

2

 Capitalized terms used but not defined in this informative motion have the meanings set forth in the Motion to 

Compel. 

3

 See Informative Motion Regarding Consensual Adjournment of Official Committee of Unsecured Creditors’ 

Urgent Motion, Pursuant to Bankruptcy Code Section 105(a), to Compel Debtors to Comply with Interim 

Compensation Orders, Solely as it Relates to Request to Compel Payment of Paul Hastings’ Fees and Expenses

[Docket No. 3652] (the “Notice of Adjournment”). 

4

 See Informative Motion Regarding Withdrawal, Without Prejudice, of Official Committee of Unsecured Creditors’ 

Urgent Motion, Pursuant to Bankruptcy Code Section 105(a), to Compel Debtors to Comply with Interim 

Compensation Orders, Solely as It Relates to Request to Compel Payment of Kroma’s Fees and Expenses [Docket 

No. 3668]. 

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6. On October 31, 2018, Paul Hastings received payment on account of the 

remaining portion of its outstanding fees and expenses. Therefore, the Committee hereby 

withdraws the Motion to Compel, without prejudice to renewing such request in the future. 

[Remainder of page intentionally left blank.] 

 

 5

 See the Notice of Agenda of Matters Scheduled for the Hearing on September 13–14, 2018 at 9:30 a.m. (AST & 

EST) [Docket No. 3909]. 

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Dated: November 1, 2018 /s/ G. Alexander Bongartz .

PAUL HASTINGS LLP 

Luc. A. Despins, Esq. (Pro Hac Vice) 

James R. Bliss, Esq. (Pro Hac Vice)

James B. Worthington, Esq. (Pro Hac Vice) 

G. Alexander Bongartz, Esq. (Pro Hac Vice) 

200 Park Avenue 

New York, New York 10166 

Telephone: (212) 318-6000 

lucdespins@paulhastings.com 

jamesbliss@paulhastings.com 

jamesworthington@paulhastings.com 

alexbongartz@paulhastings.com 

Counsel to the Official Committee of Unsecured 

Creditors 

- and - 

/s/ Juan J. Casillas Ayala .

CASILLAS, SANTIAGO & TORRES LLC 

Juan J. Casillas Ayala, Esq., USDC - PR 218312 

Diana M. Batlle-Barasorda, Esq., USDC - PR 213103 

Alberto J. E. Añeses Negrón, Esq., USDC - PR 302710 

Ericka C. Montull-Novoa, Esq., USDC - PR 230601 

El Caribe Office Building 

53 Palmeras Street, Ste. 1601 

San Juan, Puerto Rico 00901-2419 

Telephone: (787) 523-3434 

jcasillas@cstlawpr.com

dbatlle@cstlawpr.com 

aaneses@cstlawpr.com 

emontull@cstlawpr.com 

Local Counsel to the Official Committee of Unsecured 

Creditors

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