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 

Re: ECF Nos. 3914, 3916

(Jointly Administered) 

URGENT JOINT MOTION FOR EXTENSION OF DEADLINES

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

The Commonwealth of Puerto Rico (the “Commonwealth”)2and the Asociación de 

Maestros de Puerto Rico and Asociación de Maestros de Puerto Rico-Local Sindical (collectively, 

“Movants”), respectfully submit this urgent joint motion for entry of an order, substantially in the 

form attached hereto as Exhibit A (the “Proposed Order”), extending the deadlines set forth in the 

Order Scheduling Briefing of Motion for Relief from Automatic Stay [ECF No. 3916] (the 

“Scheduling Order”).

 

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

 The Financial Oversight and Management Board for Puerto Rico, as the Commonwealth’s representative pursuant 

to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), has 

authorized the Department of Justice to file this Urgent Joint Motion on behalf of the Commonwealth. 

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Request for Relief

1. On September 10, 2018, the Movants filed the Motion for Relief from Automatic

Stay [ECF No. 3914] (the “Motion), seeking relief from the automatic stay to allow the Puerto 

Rico Court of First Instance in the case captioned Asociación de Maestros de Puerto Rico et al v. 

Departamento de Educación et al., Case No. SJ2017CV00542 (the “Prepetition Action”) “to enter 

the appropriate declarations as to Movants’ right under Commonwealth law, but also to allow the 

Commonwealth Court to issue and enforce a remedy, in equity or in law, redressing any 

deprivation by Defendants to Movants’ right to due process and property rights.” Motion ¶¶ 20.

2. The Commonwealth is in the process of reviewing the pertinent information 

regarding the facts relating to the Prepetition Action in order to respond to the Motion. 

Nevertheless, the Commonwealth needs additional time to finalize such analysis and submit its 

response to the Motion. In consideration of the foregoing, the Commonwealth and Movants have 

agreed to the following extensions of the deadlines set forth in the Scheduling Order: 

 The deadline to file oppositions to the Motion, or to otherwise respond, shall be extended 

to October 10, 2018. 

 The deadline for Movants to file a reply to any oppositions shall be extended to October 

19, 2018. 

3. Pursuant to Paragraph 1.H of the Fifth Amended Notice, Case Management and 

Administrative Procedures [Case No. 17 BK 3283, ECF No. 3730-1] (the “Case Management 

Procedures”), the Commonwealth hereby certifies that they have carefully examined the matter 

and concluded that there is a true need for an urgent motion; they have not created the urgency 

through any lack of due diligence; have made a bona fide effort to resolve the matter without a 

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hearing; have made reasonable, good-faith communications in an effort to resolve or narrow the 

issues that are being brought to the Court, and no party opposes the relief requested herein. 

Notice

4. The Commonwealth has provided notice of this motion in accordance with the Case 

Management Procedures to the following parties: (a) the Office of the United States Trustee for 

the District of Puerto Rico; (b) the indenture trustees and/or agents, as applicable, for the Debtors’ 

bonds; (c) the entities on the list of creditors holding the 20 largest unsecured claims against 

COFINA; (d) counsel to the statutory committees appointed in these Title III cases; (e) the Office 

of the United States Attorney for the District of Puerto Rico; (f) counsel to the Oversight Board; 

(g) the Puerto Rico Department of Justice; (h) the Other Interested Parties;3(i) all parties filing a 

notice of appearance in these Title III cases; and (j) Movants. A copy of the motion is also available 

on the Commonwealth’s case website at https://cases.primeclerk.com/puertorico/.

5. The Commonwealth submits that, in light of the nature of the relief requested, no 

other or further notice need be given. 

WHEREFORE, the Commonwealth and Movants respectfully request the Court enter the 

Proposed Order and grant such other relief as is just and proper. 

Dated: September 21, 2018 

San Juan, Puerto Rico 

 

3 The “Other Interested Parties” include the following: (i) counsel to certain of the insurers and trustees of the bonds 

issued or guaranteed by the Debtors; and (ii) counsel to certain ad hoc groups of holders of bonds issued or guaranteed 

by the Debtors. 

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Respectfully submitted, 

WANDA VÁZQUEZ GARCED 

Secretary of Justice

/s/ Wandymar Burgos Vargas

WANDYMAR BURGOS VARGAS

USDC 223502

Deputy Secretary in Litigation

Department of Justice

P.O. Box 9020192

San Juan, Puerto Rico 00902-0192

Phone: 787-721-2940 Ext. 2500, 2501

wburgos@justicia.pr.gov

Attorneys for the Commonwealth of Puerto 

Rico

Respectfully submitted,

JOSE LUIS BARRIOS-RAMOS

/s/ José Luis Barrios-Ramos

JOSE LUIS BARRIOS RAMOS

USDC 223611

1801 McLeary Ave. Suite 303

San Juan, Puerto Rico, 00911

Phone: 787-593-6641

Fax: 787-764-4430

Email: barrios.jl@outlook.com

Attorney for Movants

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Exhibit A

Proposed Order

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