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)

Re: Dkt. Nos. 3928, 3930, 3969, 3970

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY,

 Debtor.

PROMESA

Title III 

No. 17 BK 4780-LTS

ISMAEL L. PURCELL-SOLER, ALYS COLLAZOBOUGEOIS

Movants,

-againstTHE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

PUERTO RICOELECTRIC POWER AUTHORITY,

Respondent.

This Informative Motion Relates 

Only to PREPA and Shall be Filed in 

Both the Lead Case No. 17 BK-3283-

LTS and in PREPA’s Title III Case 

No. 17 BK 4780-LTS

 

1 The Debtors in the jointly-administered 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) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) 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); (iv) Puerto Rico Highways and Transportation Authority 

(“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) (Last Four Digits of Federal Tax ID: 3808); 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).

Case:17-03283-LTS Doc#:4007 Filed:10/04/18 Entered:10/04/18 11:45:47 Desc: Main

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JOINT INFORMATIVE MOTION REGARDING

ISMAEL L. PURCELL-SOLER, ALYS COLLAZO-BOUGEOIS’

MOTION FOR RELIEF FROM AUTOMATIC STAY

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

The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”), on behalf of 

the Puerto Rico Electric Power Authority (“PREPA”) pursuant to the authority granted to it under 

the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, and Ismael L. 

Purcell-Soler, Alys Collazo-Bougeois, and the community property comprised by them 

(collectively, “Movants” ),1by and through their undersigned counsel and respectfully submit this

informative motion to inform the Court that PREPA and Movants (together, the “Parties”) have 

consensually resolved the Motion for Relief from Stay and for a Ruling that a Judgment on a Claim 

Arising from the Taking of Properties Without Just Compensation is not Subject to Reduction or 

Compensation in Bankruptcy [Case No. 17-3283; ECF No. 3928] (the “Motion“) filed by Movant.

Background

1. On September 12, 2018, Movants filed the Motion seeking that the Title III Stay be 

lifted to allow Movants to proceed with the case captioned Ismael L. Purcell-Soler, Alys CollazoBougeois v. Puerto Rico Electric Power Authority, civil case no. J DP 2012-0406 (605), Puerto 

Rico Court of First Instance, Ponce Part.

2. The Parties have met and conferred and have entered into a stipulation to resolve the 

Motion in its entirety. PREPA will include such stipulation in the next omnibus stay modification 

motion in accordance with Paragraph III.Q of Section III (Scheduling) of the Sixth Amended Notice, 

 

1 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”), has authorized the Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”) to 

file this Informative Motion on behalf of PREPA. AAFAF is an entity of the Commonwealth of Puerto Rico 

authorized to act on behalf of PREPA pursuant to the authority granted to it under the Enabling Act of the Fiscal 

Agency and Financial Advisory Authority, Act 2 2017.

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2

Case Management, and Administrative Procedures [Case No. 17-03283; ECF No. 3804-1]. 

Therefore, Movants withdraw the Motion.

Dated: October 4, 2018.

San Juan, Puerto Rico

Respectfully submitted,

/s/ Arturo Díaz-Angueira

Arturo Díaz-Angueira

USDC No. 117907

adiaz@cnrd.com

/s/ Katiuska Bolaños-Lugo

Katiuska Bolaños-Lugo

USDC No. 231812

kbolanos@cnrd.com

CANCIO, NADAL, RIVERA & DIAZ, 

P.S.C.

P.O. Box 364966

San Juan, PR 00936-4966

Tel: (787) 767-9625

Fax: (787) 764-4430

Attorneys for Puerto Rico Electric Power 

Authority

/s/ Ismael L. Purcell-Soler

ISMAEL L. PURCELL SOLER

USDC-PR 217402

URB. JACARANDA

35271 CALLE CLAVELINA

PONCE, PUERTO RICO 00730

TEL. (787) 481-4540

E-mail: pfpurcell2000@yahoo.com

Movant

/s/ María E. Vicéns-Rivera

MARĺA E. VICÉNS RIVERA

USDC- PR 226711

9140 MARINA ST., SUITE 801

PONCE, PUERTO RICO 00717

TEL. / FAX: (787) 259-1999

E-mail: mevicens@yahoo.com

Attorney for Movants

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