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. 3958, 4112

(Jointly Administered) 

FOURTH URGENT MOTION FOR EXTENSION OF DEADLINES

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

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

the Commonwealth of Puerto Rico (the “Debtor”), 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 urgent 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 Granting Third 

Urgent Motion for Extension of Deadlines [ECF No. 4112] (the “Third Amended Scheduling 

Order”).2

 

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 Debtor’s representative pursuant to section 

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

AAFAF to file this Urgent Motion on behalf of the Commonwealth.

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Request for Relief

1. On September 21, 2018, Ponce Real Estate Corporation (“Movant”) filed a Motion

for Application Requesting Administrative Rent Payment [Case No. 17 BK 3283, ECF No. 3958] 

(the “Motion), requesting that the Court order the Debtor to pay Movant the amount of $62,190.00 

in administrative rent. Motion at 3. 

2. On October 29, 2018, the Court entered the Third Amended Scheduling Order,

which provides that opposition papers to the Motion must be filed by November 5, 2018, and 

Movant’s reply by November 12, 2018.

3. The Debtor has reached out to Movant to explore the possibility of a consensual 

resolution of the Motion and needs additional time to attempt to consensually resolve the same. 

Accordingly, the Debtor requests the following extensions of the deadlines set forth in the Third 

Amended Scheduling Order: 

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

to November 12, 2018. 

• The deadline for Movant to file a reply to any oppositions shall be extended to 

November 19, 2018. 

4. Pursuant to Paragraph 1.H of the Sixth Amended Notice, Case Management and 

Administrative Procedures [Case No. 17-03283 (LTS), ECF No. 3804-1] (the “Case Management 

Procedures”), the Debtor hereby certifies that it has carefully examined the matter and concluded 

that there is a true need for an urgent motion; it has not created the urgency through any lack of 

due diligence; has made a bona fide effort to resolve the matter without a hearing; and has made 

reasonable, good-faith communications in an effort to resolve or narrow the issues that are being 

brought to the Court. 

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Notice

5. The Debtor 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) Movant. A copy of the motion is also available 

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

6. The Debtor submits that, in light of the nature of the relief requested, no other or 

further notice need be given. 

WHEREFORE, the Debtor respectfully requests the Court enter the Proposed Order and 

grant such other relief as is just and proper. 

Dated: November 2, 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, 

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Email: lmarini@mpmlawpr.com

/s/ Carolina Velaz-Rivero

Carolina Velaz-Rivero

USDC No. 300913

Email: 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

Attorneys for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority

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Exhibit A

Proposed Order

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