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 

Case No. 17 BK 3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO (“ERS”),

 Debtor.

PROMESA

Title III 

Case No. 17 BK 3566-LTS

RE: ECF Nos. 278, 281

Because of the nature of the relief 

requested herein, this Response shall 

be filed in the Title III cases for each 

of the Debtors.

ASOCIACIÓN DE EMPLEADOS DEL ESTADO 

LIBRE ASOCIADO,

Movant.

v.

 

1 The debtors in the jointly-administered Title III cases (collectively, the “Debtors”), 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) (the “Commonwealth”); 

(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).

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THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO,

 Respondent.

JOINDER OF THE PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY 

AUTHORITY TO DEBTORS’ RESPONSE TO 

(I) MOTION FOR EXTENSION OF BAR DATE TO FILE PROOFS OF CLAIM

AND (II) RESPONSE OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS

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

The Puerto Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”), as the entity 

authorized to act on behalf of the Commonwealth of Puerto Rico, the Puerto Rico Sales Tax 

Financing Corporation, the Puerto Rico Highways and Transportation Authority, the Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico, and the Puerto Rico 

Electric Power Authority (collectively, the “Debtors”) pursuant to the authority granted to it under 

the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, respectfully 

submits this joinder to the Debtors’ Response to (i) Motion for Extension of Bar Date to File Proofs 

of Claim and (ii) Response of Official Committee of Unsecured Creditors [17-0356-ECF No. 281] 

(the “Response”) and states as follows:2 

1. AAFAF hereby joins the Debtors in their position as detailed in their Response and 

adopts all the factual and legal arguments set forth in the same.

3

CONCLUSION

For the reasons set forth in the Response, AAFAF respectfully requests the Court that it 

enter the proposed order attached to the Response.

Dated: May 25, 2018

San Juan, Puerto Rico

/s/ Peter Friedman

John J. Rapisardi 

(Admitted Pro Hac Vice) 

O’MELVENY & MYERS LLP 

7 Times Square 

Respectfully submitted,

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Email: lmarini@mpmlawpr.com

 

2 Capitalized terms used but not defined herein shall have the meaning used in the Response.

3

In consenting to this extension, AAFAF does not waive any arguments, rights, or defenses with respect to any further 

requests to extend the Extended Bar Date or to seek allowance of claims filed after the Extended Bar Date; and 

AAFAF’s position in this Response shall not be deemed or construed as creating or conferring any right upon any 

persons or entities, or evidence of any willingness or obligation to consent to any other or future modifications of or 

relief from the Bar Date or the Extended Bar Date, as the case may be.

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New York, NY 10036 

Tel: (212) 326-2000 

Fax: (212) 326-2061 

Peter Friedman

(Admitted Pro Hac Vice) 

O’MELVENY & MYERS LLP 

1625 Eye Street, NW

Washington DC 20006

Tel: (202) 383-5300

Fax: (202) 383-5414

Elizabeth L. McKeen

(Admitted Pro Hac Vice)

O’MELVENY & MYERS LLP 

610 Newport Center Drive

17th Floor

Newport Beach, California 92660

Tel: (949) 823-6900

Fax: (949) 823-6994

Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

/s/ Carolina Velaz-Rivero

Carolina Velaz-Rivero

USDC No. 300913

E:mail: cvelaz@mpmlawpr.com

MARINI PIETRANTONI MUÑIZ LLC

MCS Plaza, Suite 500

255 Ponce de León Ave.

San Juan, Puerto Rico 00917

Tel: (787) 705-2171

Fax: (787) 936-7494

Co-Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

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