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 

Case No. 17 BK 3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY,

 Debtor.

PROMESA

Title III 

Case No. 17 BK 4780-LTS

Re: ECF Nos. 814 (Case No. 17-4780), 

2980 (Case No. 17-3283) 

WIDERANGE CORPORATION,

Movant,

-againstTHE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

 as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY,

Respondent.

This Joint Motion Relates Only to 

PREPA and Shall Only be Filed in 

Case Nos. 17 BK 3283-LTS and 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).

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JOINT MOTION IN COMPLIANCE WITH ORDER RELATED TO 

WIDERANGE CORPORATION’S MOTION FOR RELIEF OF STAY

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

On behalf of the Puerto Rico Electric Power Authority (“PREPA”), the Puerto Rico Fiscal 

Agency and Financial Advisory Authority (“AAFAF”) pursuant to the authority granted to it under 

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

Widerange Corporation (“WR”), respectfully submit this Joint Motion in Compliance with Order 

Related to Widerage Corporation’s Motion for Relief of Stay (the “Motion”). In support of the 

Motion, the parties respectfully state as follows: 2

1. On July 16, 2018, this Court entered an order granting WR’s unopposed request 

for an extension of time to file a joint report and extended the deadline to July 25, 2018 [Dkt.

No. 3525]. The joint report pertains to this Court’s order entered on May 1, 2018 (the “Initial 

Order”) concerning the parties’ “efforts to seek to develop a mutually acceptable resolution of the 

outstanding performance bond issue or, at minimum, an agreed statement regarding the nature 

and pendency of the stayed litigation that can be used in connection with inquiries as WR’s bids 

for business.” [Dkt. No. 2980 at 6].

2. In compliance with the Initial Order, on July 25, 2018, the parties informed the 

Court of the efforts made by both parties to reach an agreement as related to the nature and 

pendency of the stayed litigation and WR’s concerns regarding the potential impact of the 

pending litigation in relation to its commercial prospects with PREPA [Dkt. No. 3697].

3. On August 27, 2018, the parties informed the Court that the parties were in 

communication and still in the process of discussing possible alternatives and drafting a mutually 

 

2 The Financial Oversight and Management Board for Puerto Rico, as the Debtors’ representative pursuant to 

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

authorized AAFAF to join in this Motion on behalf of PREPA. 

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acceptable statement, and requested until September 7, 2018 to inform the Court of the status of 

a mutually agreeable statement regarding both parties’ concerns going forward [Dkt. No. 3812].

4. On September 7, 2018, the parties informed the Court that they met on August 

30, 2018 to discuss alternatives to resolve the pending issues and scheduled a meeting for the 

week of September 10-14, 2018, and requested until October 7, 2018 to inform the Court of the 

status of their efforts [Dkt. No. 3896].

5. On October 5, 2018, the parties informed the Court that they are in 

communication and still in the process of discussing possible alternative and drafting a mutually 

acceptable statement, and requested until October 22, 2018 to inform the Court of the status of 

their efforts [Dkt. No. 4023].

6. On October 22, 2018, the parties informed the Court they are still in the process 

of drafting a mutually acceptable statement, and requested until November 16, 2018 to inform 

the Court of the status of their efforts [Dkt. No. 4083]. 

7. The parties hereby inform the Court that the parties are in the process of 

exchanging draft versions of an agreement to resolve the issues outlined in the Initial Order and 

respectfully request that the Court allow the parties until December 7, 2018 to file a joint status 

report on these additional efforts.

RESPECTFULLY SUBMITTED.

I HEREBY CERTIFY that on this date, I have electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system, which will send notification of such filing to 

counsel of record.

In San Juan, Puerto Rico, this 16th day of November, 2018.

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THE PUERTO RICO ELECTRIC POWER

AUTHORITY

By its attorneys,

/s/ Arturo Díaz Angueria

Arturo Diaz Angueira

USDC No. 117907

adiaz@cnrd.com

/s/ Katiuska Bolaños Lugo

Katiuska Bolaños Lugo

USDC No. 231812

kbolanos@cnrd.com

CANCIO, NADAL, RIVERA & DÍAZ, P.S.C.

PO Box 364966

San Juan, PR 00936-4966 Phone: 

(787) 767-9625

Fax: (787) 764-4430

THE PUERTO RICO FISCAL AGENCY

AND FINANCIAL ADVISORY

AUTHORITY, as Fiscal Agent for PREPA

By its attorneys,

/s/ Diana M. Perez 

Nancy N. Mitchell (admitted pro hac vice)

Diana M. Perez (admitted pro hac vice)

O’Melveny & Myers LLP

7 Times Square

New York, NY 10036

Phone: (212) 326-2000

Fax: (212) 326-2061

Email: nmitchell@omm.com

 dperez@omm.com

MOVANTS WIDERANGE

S/Henry Vázquez Irizarry

USDC No. 205011

Bufete Vázquez 

Irizarry, CSP Urb. 

Villa Fontana 

Park

Calle Parque Luis M. 

Rivera 5 HH6 Carolina, 

PR 00983

Tel. (787) 724-7514 / 787-645-2241

Fax (888) 518-1318

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