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)

NOTICE OF CORRESPONDENCE REGARDING THE THREE HUNDRED 

SEVENTIETH OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF THE 

COMMONWEALTH OF PUERTO RICO, THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY, THE EMPLOYEES RETIREMENT SYSTEM OF 

THE GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO, 

AND THE PUERTO RICO PUBLIC BUILDINGS AUTHORITY 

TO PROOF OF CLAIM NO. 179391

To the Honorable United States District Judge Laura Taylor Swain:

1. On August 20, 2021, the Commonwealth of Puerto Rico (the “Commonwealth”), 

the Puerto Rico Highways and Transportation Authority (“HTA”), the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico (“ERS”), and the Puerto Rico 

Public Buildings Authority (“PBA,” and together with the Commonwealth, HTA, and ERS, the 

 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 (the “Commonwealth”) (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); (v) Puerto Rico Electric Power Authority 

(“PREPA” and together with the Commonwealth, COFINA, HTA, and ERS, the “Debtors”) 

(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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“Debtors”), by and through the Financial Oversight and Management Board for Puerto Rico (the 

“Oversight Board”), as the sole Title III representative of the Debtors pursuant to section 315(b) 

of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”),2 filed 

the Three Hundred Seventieth Omnibus Objection (Non-Substantive) of the Commonwealth of 

Puerto Rico, the Puerto Rico Highways and Transportation Authority, the Employees Retirement 

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

Buildings Authority to Duplicate Claims [ECF No. 17935] (the “Three Hundred Seventieth

Omnibus Objection”) to various proofs of claim.

2. The Three Hundred Seventieth Omnibus Objection seeks to disallow claims that 

are substantively duplicative of other proofs of claim filed in the Title III Cases.3 As set forth in 

Exhibit A thereto, the claims identified in the column titled “Claims to be Disallowed” 

(collectively, the “Claims to Be Disallowed”) assert the same liabilities against the 

Commonwealth, HTA, ERS and/or PBA as the claims identified in the column titled “Remaining 

Claims” (each a “Remaining Claim” and collectively, the “Remaining Claims”).

3. The Debtors received the attached correspondence from William Roman Morales 

(“Roman Morales”), a copy of which is attached hereto as Exhibit “A” (the “Roman Morales

Response”), regarding Proof of Claim No. 179391 (the “Roman Morales Claim”). A certified 

translation of the Roman Morales Response is attached hereto as Exhibit “A-1”.

 2 PROMESA is codified at 48 U.S.C. §§ 2101-2241.

3 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the 

Three Hundred Seventieth Omnibus Objection.

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4. The Roman Morales Claim asserts liabilities in an unspecified amount purportedly 

arising from civil rights violations and medical malpractice experienced during Roman Morales’s 

imprisonment at the Puerto Rico Department of Corrections and Rehabilitation (“DCR”). 

5. The Roman Morales Response, a copy of a notice sent to claimants subject to the 

Three Hundred Seventieth Omnibus Objection, on which notes were handwritten in Spanish, was 

received by Prime Clerk on October 27, 2021. Therein, Roman Morales does not dispute that the 

Roman Morales Claim asserts the same liabilities as set forth in a second proof of claim also filed 

by Roman Morales, Proof of Claim No. 179392 (the “Roman Morales Remaining Claim”), which 

also seeks liabilities against the DCR purportedly arising from civil rights violations and medical 

malpractice. Rather, the Roman Morales Response merely reiterates the basis of the Roman 

Morales Claim, stating that Roman Morales asserts liabilities associated with “[p]oor medical 

services and violation of my civil rights” and “[m]edical malpractice from the management at all 

times.” Roman Morales Resp. at 1.

6. Accordingly, because Roman Morales does not dispute that the Roman Morales 

Claim is duplicative of the Roman Morales Remaining Claim, the Debtors respectfully request that 

the Court grant the Three Hundred Seventieth Omnibus Objection and disallow the Roman 

Morales Claim, notwithstanding the Roman Morales Response.

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Dated: February 2, 2022 Respectfully submitted,

San Juan, Puerto Rico

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla García Benítez

USDC No. 203708

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice)

Brian S. Rosen (pro hac vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Commonwealth of Puerto Rico, the Puerto 

Rico Highways and Transportation 

Authority, the Employees Retirement System 

of the Government of the Commonwealth of 

,Puerto Rico and the Puerto Rico Buildings 

Authority

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