GOVERNMENT OF PUERTO RICO PUBLIC SERVICE REGULATORY BOARD PUERTO RICO ENERGY BUREAU
N0E16P0R Received: Aug 30, 2023 12:03 PM
PBJL ENERGY CORPORATION
Petitioners
v.
PUERTO RICO ELECTRIC POWER AUTHORITY, et al. Respondents
CASE NO.: NEPR-QR-2021-0026
SUBJECT: Joint Request for Extension
of Time to Inform Status of Settlement Agreement Negotiations in Compliance
with the August 23 Order
JOINT REQUEST FOR EXTENSION OF TIME TO INFORM STATUS OF SETTLEMENT AGREEMENT NEGOTIATIONS IN COMPLIANCE WITH THE AUGUST 23 ORDER
COMES NOW, the Puerto Rico Electric Power Authority (“PREPA”) and PBJL Energy Corporation (“PBJL”)1, through the undersigned counsel and respectfully submit and request as follows:
1. On April 10, 2023, the Parties filed a motion titled Joint Request for Additional Extension of Time to Complete Settlement Agreement Negotiations and Inform Results, whereby the Parties requested an extension of time to inform the progress of the negotiations undertaken pursuant to an agreement in principle reached between the Parties to settle the captioned case.
2. On August 23, 2023, the Energy Bureau ordered the Parties to inform the status of the Negotiations by September 1, 2023. The Energy Bureau warned that failure to inform the case status would result in the complaint being dismissed for lack of interest (“August 23 Order”).
3. The Parties respectfully inform the Energy Bureau that after an impasse in the negotiations, followed by a period of time where PREPA was focused on the reorganization ahead of Genera’s July 1, 2023, Commencement date, and the resulting changes in PREPA’s employee
composition, PBJL and PREPA have recently resumed the settlement negotiations. Consequently, this Friday, September 1, 2023, PREPA’s management has a meeting to evaluate PBJL’s most recent communication and settlement proposal, received on August 25, 2023.
4. Considering the foregoing, the Parties respectfully request an additional fifteen (15) days, until September 13, 2023, to review, evaluate, and discuss their settlement process, as applicable to this case, and inform the Energy Bureau of the results.
5. As before, all efforts and proceedings related to the Settlement Proposal are made under Puerto Rico Rule of Evidence no. 408.
WHEREFORE, the Parties respectfully request the Honorable Energy Bureau to take notice of the aforementioned, find the Parties in compliance with the August 23 Order and grant until September 13, 2023, to inform the Energy Bureau of the results of their settlement efforts.
In San Juan, Puerto Rico, this 30th day of August 2023.
s/ Joannely Marrero Cruz
Joannely Marrero Cruz
TSPR No. 20,014
DIAZ & VAZQUEZ LAW FIRM, P.S.C.
290 Jesus T. Pinero Ave. Oriental Tower, Suite 803 San Juan, PR 00918
Tel. (787) 395-7133
Fax. (787) 497-9664
Counsel for PREPA
CARLOS R. SOSA PADRO LAW OFFICE
PO Box 191682 San Juan, Puerto Rico 00919-1682
s/Carlos R. Sosa Padro Carlos R. Sosa-Padro, Esq.
De Guzman Law Offices
P.O. Box 362738 San Juan, PR 00936-2738 Mobile (787) 646-3597 Ph.(787) 756-2765 Fax (787) 756-4024
gdeguzman@dgglawpr.com TSPR (RUA) No. 6370 USDC-PR No. 205112
s/Guillermo F. De Guzman-Vendrell Guillermo F. De Guzman-Vendrell, Esq.
Counsels for PBJL