EXHIBIT E-1 

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Exhibit E-1 Page 1 of 26
Certified to be a correct and true translation from the source text in Spanish to the target language English.

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By Targem Translations Inc.

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By Targem Translations Inc.

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2. Venue is proper in this district pursuant to PROMESA section 307(a)

BACKGROUND

A. Deadline Orders

3. On May 3, 2017, the Oversight Board issued a restructuring certification pursuant to sections 

104(j) and 206 of PROMESA and filed a voluntary petition for relief for the Commonwealth pursuant to 

section 304(a) of PROMESA, initiating a case under Title III of said body of law (the "Commonwealth 

Title III Case"). On May 21, 2017, the Oversight Board issued a restructuring certification pursuant to 

sections 104(j) and 206 of PROMESA and filed a voluntary petition for relief for the ERS and the HTA

pursuant to section 304(a) of PROMESA, initiating a case under Title III of said body of law (the "ERS 

Title III Case" and the HTA Title III Case," respectively). On September 27, 2019, the Oversight Board 

issued a restructuring certification pursuant to sections 104(j) and 206 of PROMESA and filed a voluntary 

petition for relief for the PBA pursuant to section 304(a) of PROMESA, initiating a case under Title III of 

said body of law (the "PBA Title III Case," and together with the Commonwealth Title III Case and the 

ERS Title III Case, the "Title III Cases"). On June 29, 2017, and October 9, 2019, the Court entered orders 

granting joint administration of the Title III Cases for procedural purposes only. ECF no. 537, ECF no. 

8829.3

[Signature]

3 Except as otherwise provided herein, ECF citations shall refer to documents filed in Bankruptcy Case No. 

17 BK 3283-LTS.

3

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4. On January 16, 2018, the Debtors filed their Motion for an order A) setting deadlines and 

procedures for filing proofs of claim; and, B) approving the form and manner of service thereof [ECF no. 

2255] (the "Deadline Motion"). Pursuant to the Order A) setting deadlines and procedures for filing proofs

of claim; and, B) approving the form and manner of service thereof [ECF. no. 2521] (the "Initial Deadline 

Order"), the Court granted the relief requested in the Deadline Motion and set deadlines and procedures for 

filing proofs of claim under the Title III Cases. Following the motion providing information of certain 

creditors and the Debtors' support, the Court thereafter entered an Order A) extending deadlines for filing 

proofs of claim; and, B) approving the form and manner of service thereof [ECF no. 3160] (together with 

the Initial Deadline Order, the "Commonwealth, ERS and ACT Deadline Orders"), extending said deadlines 

to June 29, 2018, 04:00 p.m. (AST). 

5. On February 11, 2020, the PBA filed its Motion for an order A) setting deadlines and 

procedures for filing proofs of claim; and, B) approving the form and manner of service thereof. [ECF no. 

36 in 19-BK-5523-LTS] (the "PBA Motion for Deadline"). Pursuant to the Order A) setting deadlines and 

procedures for filing proofs of claim; and, B) approving the form and manner of service thereof. [ECF. 

no. 55 in 19-BK- 5523-LTS] (the "PBA Initial Deadline Order"), the Court granted the relief requested in 

the PBA’s Deadline Motion, setting deadlines and procedures for filing proofs of claim under the PBA's 

Title III Case. In view of the public health emergency caused by the spread of COVID-19, the Court 

subsequently extended this deadline through July 29, 2020 (inclusive) at 4:00 p.m. (AST) by way of the

Order A) extending deadlines for filing proofs of claim; and, B)

4

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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.

PROMESA

Title III

No. 17 BK 3283-LTS 

(Jointly Administered) 

This filing relates to the Commonwealth, 

ERS, HTA and PBA.

NOTICE OF THE THREE HUNDRED EIGHTIETH OMNIBUS OBJECTION (SUBSTANTIVE) 

OF THE COMMONWEALTH OF PUERTO RICO, THE COMMONWEALTH OF PUERTO 

RICO GOVERNMENT EMPLOYEES’ RETIREMENT SYSTEM, THE PUERTO RICO 

HIGHWAYS AND TRANSPORTATION AUTHORITY, AND THE PUERTO RICO PUBLIC 

BUILDINGS AUTHORITY TO EMPLOYEE CLAIMS ASSERTING LIABILITIES OWED BY 

ENTITIES THAT ARE NOT TITLE III DEBTORS

IF YOUR CLAIM IS LISTED ON EXHIBIT A TO THE OMNIBUS OBJECTION, THE 

DEBTORS ARE SEEKING TO DISALLOW YOUR CLAIM BECAUSE THEY ARE NOT 

LIABLE FOR YOUR CLAIM.

THIS OMNIBUS OBJECTION SEEKS TO ALTER YOUR RIGHTS. ANY CLAIM THAT IS 

DISALLOWED WILL BE TREATED AS THOUGH IT WERE NEVER FILED.

IF YOUR CLAIM IS LISTED ON EXHIBIT A, YOU MUST READ THIS NOTICE AND THE 

OMNIBUS OBJECTION CAREFULLY AND DISCUSS IT WITH YOUR ATTORNEY. IF YOU 

DO NOT HAVE AN ATTORNEY, YOU MAY W1SH TO CONSULT ONE.

PLEASE TAKE NOTICE THAT on August 20, 2021, the Commonwealth of Puerto Rico (the 

“Commonwealth”), the Commonwealth of Puerto Rico Government Employees’ Retirement System 

(“ERS"), the Puerto Rico Highways and Transportation Authority (the "HTA") and the Puerto Rico Public 

Buildings Authority (the "PBA," and together with the Commonwealth, the ERS, and the HTA, the 

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

Board"), as the representative of the Commonwealth pursuant to section 315(b) of the 

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Puerto Rico Oversight, Management, and Economic Stability Act ("PROMESA"),1 filed the Three Hundred 

Eightieth Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico, the Commonwealth of 

Puerto Rico Government Employees’ Retirement System, and the Puerto Rico Public Buildings Authority 

to Employee Claims Asserting Liabilities Owed by Entities That Are Not Title III Debtors (the "Omnibus 

Objection") with the United States District Court for the District of Puerto Rico (the "Court"). 2

OVERVIEW

• PLEASE CHECK IF YOUR CLAIM(S) IS/ARE LISTED ON EXHIBIT A TO THE 

OMNIBUS OBJECTION.

• If your claim(s) are NOT listed on Exhibit A, the Omnibus Objection will not affect your 

claim, and you DO NOT have to do anything. 

• If your claim(s) is/are listed on Exhibit A to the Omnibus Objection, the Debtors are seeking 

to disallow your claim(s) listed on Exhibit A because, as explained in the accompanying 

Omnibus Objection, the Debtors believe they are not liable for your claim(s). The Omnibus 

Objection and Exhibit A to the Omnibus Objection provide additional details regarding why 

the Debtors believe they are not liable.

• Copies of the Omnibus Objection and all other filings in the Title III Cases are available free 

online at https://cases.primeclerk.com/puertorico

• If you have questions, please contact Prime Clerk, LLC at (844) 822-9231 (toll free for 

U.S. and Puerto Rico) or (646) 486-7944 (for international callers), available 10:00 a.m. 

to 7:00 p.m. (Atlantic Standard Time) (Spanish available).

IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE 

COURT MAY GRANT THE RELIEF REQUESTED IN THE OMNIBUS OBJECTION 

WITHOUT FURTHER NOTICE OR HEARING.

[Additional pages follow]

________[signature]____________________

1 PROMESA is codified under Title 48 U.S.C., §§ 2101-2241. 

2 Capitalized terms used but not defined herein shall have the meanings set forth in the Omnibus Objection.

2

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I, Jay Herriman, pursuant to Title 28 U.S.C. § 1746, do hereby declare under penalty of perjury that 

the following is true and correct to the best of my knowledge and belief:

1. I am a Managing Director of Alvarez & Marsal North America, LLC ("A&M"). The Financial 

Oversight and Management Board for Puerto Rico (the "Oversight Board") retained A&M to assist it with, 

among other things, the claims reconciliation process in connection with the Debtors' cases (as defined 

below) filed under the Puerto Rico Oversight, Management and Economic Stability Act ("PROMESA").2

Except as otherwise provided in this declaration, I have personal knowledge of the facts set forth herein.

2. In my capacity as Managing Director of A&M, I am one of the individuals responsible for 

overseeing the reconciliation and objections process relating to claims in the Debtors' PROMESA cases. 

The Debtors' ongoing claims reconciliation process involves a collective effort by a team of A&M 

employees, as well as Proskauer Rose LLP and O'Neill & Borges LLC, counsel for the Oversight Board, 

the legal representative of the Commonwealth of Puerto Rico (the "Commonwealth"), the Commonwealth 

of Puerto Rico Government Employees' Retirement System (the "ERS"), the Puerto Rico Highways and 

Transportation Authority (the “HTA”), and the Puerto Rico Public Buildings Authority (the "PBA, " and 

together with the Commonwealth, ERS and HTA, the "Debtors").

3. I am making this statement in support of the Three hundred and eightieth omnibus objection 

(substantive) of the Commonwealth of Puerto Rico, the Commonwealth of Puerto Rico Government 

Employees' Retirement System

[Signature]

2 PROMESA is codified under Title 48 U.S.C., §§ 2101-2241.

2

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the Puerto Rico Highways and Transportation Authority and the Puerto Rico Public Buildings Authority to 

Employee Claims Asserting Liabilities Owed by Entities That Are Not Title III Debtors (the "Three hundred 

eightieth omnibus objection").3 I have personally reviewed the Three Hundred Eightieth Omnibus 

Objection and exhibits thereto and am, accordingly, familiar with the information contained therein.

4. In preparation for filing the Three hundred and Eightieth Omnibus Objection, and under my 

direction and/or supervision, each of the claims at issue in the Three Hundred and Eightieth Omnibus 

Objection was carefully reviewed and analyzed in good faith applying due diligence by the relevant staff 

or was reviewed and analyzed by the staff of other agents hired by the Oversight Board. Such efforts 

resulted in the identification of claims to be disallowed, as identified in Exhibit A to the Three hundred 

Eightieth Omnibus Objection.

5. To the best of my knowledge, each of the claims identified in Exhibit A to the Three hundred 

and eightieth omnibus objection (collectively, the "Claims to be Disallowed") alleges liability for alleged 

unpaid wages or other employment benefits allegedly owed by the entities that are not Title III Debtors. 

The Claims to be disallowed allege liability for unpaid wages or other labor benefits allegedly owed by the 

by the Puerto Rico Land Administration, the Puerto Rico Sugar Corporation or Puerto Rico Telephone 

Company. However, none of these entities are Title III Debtors. For example, the Administration [...]

[Signature]

3 Capitalized terms not otherwise defined herein shall have the meanings given to such terms in the Three 

Hundred and Eightieth Omnibus Objection

3

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IMPORTANT NOTICE ABOUT SENSITIVE INFORMATION CONTAINED IN THE REPLIES

All materials submitted to the Court in response to the Omnibus Objection may be publicly filed 

and made accessible to the general public. Accordingly, the response should not include sensitive 

documents or information; for example, copies of driver's licenses, passports, birth certificates, 

Social Security cards, sensitive medical information, or confidential business information. 

Sensitive information submitted to the Court in response to the Omnibus Objection must comply 

with the following guidelines:

• Social Security numbers and tax identification numbers should be hidden (i.e., crossed 

out), except for the last four digits.

• Dates of birth should be hidden, except for the person's year of birth.

• The name of any person known to be a minor should be withheld, except for the person’s 

initials.

• Financial account numbers should be redacted, except for the last four digits.

Such sensitive or confidential information that claimants invoke in support of their claim must be 

provided directly to the Debtors' counsel and will be kept confidential. You may provide this 

information by mailing it to the following address:

Counsel for the Oversight Board

Proskauer Rose LLP 

Eleven Times Square 

New York, New York 10036-8299 

Attn: Martin J. Bienenstock 

Brian S. Rosen

Where and how to file and serve a reply. All replies must be filed electronically with the Court under the 

caption and docket: In re: Commonwealth of Puerto Rico, Case No. 17 BK 3283-LTS. There are two 

methods you can use to file your reply:

1. Online. Users registered in the Court's case filing system must file their reply electronically in a 

searchable pdf format.

2. By mail. If you are not an attorney who is a registered user of the Court's case filing system, you 

may file and serve a reply by mail addressed to the Clerk of the Court, the Oversight Board and the 

Creditors' Committee at the following addresses:

5

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Clerk’s Office

United States District Court

Room 150 Federal Building

San Juan (Puerto Rico) 00918-1767 

Counsel for the Oversight Board

Proskauer Rose LLP 

Eleven Times Square

New York, New York 10036-8299 

Attn: Martin J. Bienenstock 

Brian S. Rosen

Counsel for the Creditors’ Committee

Paul Hastings LLP 

200 Park Avenue 

New York, New York 10166 

Attn: Luc A. Despins 

James Bliss 

James Worthington 

G. Alexander Bongartz

YOUR REPLY must be mailed so as to be received by the Clerk, the Oversight Board and the 

Creditors' Committee no later than 04:00 p.m. (AST) on September 20, 2021, unless extended in 

writing by the Debtors or upon written request to the Court and an order of the Court extending 

the deadline. Your reply must be signed. Failure to do so will result in the clerk not accepting your 

reply for filing.

If you are unable to file and serve a reply online or by mail, as specified above, you may file a 

reply in person at the following address no later than 04:00 p.m. (AST) on September 20, 2021,

unless extended in writing by the Debtors or upon written request to the Court and an order of the 

Court extending the deadline:

Clerk’s Office 

United States District Court

#150 Avenida Chardón 

Federal Building

San Juan (Puerto Rico) 00918

Your response must include a certificate of service indicating the manner in which service was 

effected.

If you have any questions about how to file and serve a response, including questions about the 

Court's case filing system, please contact Prime Clerk directly at (844) 822-9231.

6

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD EOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors. 1

PROMESA

Title III

No. 17 BK 3283-LTS 

(Jointly Administered) 

This filing relates to the Commonwealth, 

ERS, HTA and PBA.

STATEMENT OF JAY HERRIMAN IN SUPPORT OF THE THREE HUNDRED AND 

EIGHTIETH OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF 

PUERTO RICO, THE COMMONWEALTH OF PUERTO RICO GOVERNMENT 

EMPLOYEES’ RETIREMENT SYSTEM, THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY, AND THE PUERTO RICO PUBLIC BUILDINGS 

AUTHORITY TO EMPLOYEE CLAIMS ASSERTING LIABIL1TIES OWED BY ENTITIES 

THAT ARE NOT TITLE III DEBTORS

[Signature]

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 (i) the 

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") (Bankruptcy Case No. 17 BK 

4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority 

("PBA", and together with the Commonwealth, COFINA, HTA, ERS, and PREPA, the "Debtors") 

(Bankruptcy Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case 

numbers are listed as Bankruptcy Case numbers due to software limitations.)

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EXHIBIT B

Statement of Jay Herriman

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EXHIBIT D

Proposed Order

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD EOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors. 1

PROMESA

Title III

No. 17 BK 3283-LTS 

(Jointly Administered) 

This filing relates to the Commonwealth, 

the ERS, the HTA and the PBA.

ORDER GRANTING THE THREE HUNDRED AND EIGHTIETH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO, THE COMMONWEALTH OF 

PUERTO RICO GOVERNMENT EMPLOYEES’ RETIREMENT SYSTEM, THE PUERTO RICO 

HIGHWAYS AND TRANSPORTATION AUTHORITY, AND THE PUERTO RICO PUBLIC 

BUILDINGS AUTHORITY TO EMPLOYEE CLAIMS ASSERTING LIABIL1TIES OWED BY 

ENTITIES THAT ARE NOT TITLE III DEBTORS

With regard to the Three hundred and eightieth omnibus objection (substantive) of the 

Commonwealth of Puerto Rico, the Commonwealth of Puerto Rico Government Employees’ Retirement 

System, the Puerto Rico Highways and Transportation Authority, and the Puerto Rico Public Buildings 

Authority to employee claims alleging liabilities of entities that are not Title III Debtors (the “Three hundred 

eightieth [...]

[Signature]

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 (i) the 

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") (Bankruptcy Case No. 17 BK 

4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority 

("PBA", and together with the Commonwealth, COFINA, HTA, ERS, and PREPA, the "Debtors") 

(Bankruptcy Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case 

numbers are listed as Bankruptcy Case numbers due to software limitations.)

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omnibus objection"),2 filed by the Commonwealth of Puerto Rico (the "Commonwealth"), the 

Commonwealth of Puerto Rico Government Employees’ Retirement System (the "ERS"), the Puerto Rico 

Highways and Transportation Authority (the "HTA") and the Puerto Rico Public Buildings Authority (the 

"PBA," and together with the Commonwealth, the ERS, and the HTA, the "Debtors"), dated August 20, 

2021, seeking an order disallowing certain claims asserted against the Debtors in their entirety, as more 

fully set forth in the Three hundred and eightieth Omnibus Objection itself and the supporting exhibits 

thereto; and the Court having jurisdiction to hear the Three hundred and eightieth Omnibus Objection and 

to grant the relief requested therein pursuant to PROMESA section 306(a), and the Court having jurisdiction 

pursuant to PROMESA section 307(a); and the Court having jurisdiction under PROMESA section 307(a); 

and notice of the Three hundred and eightieth omnibus objection having been given in a timely manner to 

those parties identified therein, no further notice being necessary; and having concluded that each of the 

claims identified in Exhibit A to the Three hundred and Eightieth Omnibus Objection (collectively, the 

"Claims to be Disallowed") is a claim seeking recovery of amounts for which the Debtors are not liable; 

and the Court having determined that the relief requested in the Three hundred and eightieth Omnibus 

Objection is in the best interests of the Debtors and their creditors, as well as all parties in interest; and the 

Court having determined that the legal and factual bases set forth in the Three hundred and eightieth 

Omnibus Objection establish good cause for the relief granted herein; and after due deliberation and 

sufficient cause being shown, hereby finds, [...]

[Signature]

2 Capitalized terms not otherwise defined herein shall have the meanings given to such terms in the Three 

Hundred Eightieth Omnibus Objection

2

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Hearing date: October 6, 2021, at 9:30 a.m. (AST) 

Deadline to respond: September 20, 2021, at 4:00 p.m. (AST)

REVIEW THIS OBJECTION AND THE ENCLOSED DOCUMENTS CLOSELY TO DETERMINE IF 

THE OBJECTION AFFECTS YOUR CLAIM(S)

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) 

This filing relates to the Commonwealth, 

ERS, HTA and PBA.

THREE HUNDRED AND EIGHTIETH OMNIBUS OBJECTION (SUBSTANTIVE) OF THE 

COMMONWEALTH OF PUERTO RICO, THE COMMONWEALTH OF PUERTO RICO 

GOVERNMENT EMPLOYEES’ RETIREMENT SYSTEM, THE PUERTO RICO HIGHWAYS 

AND TRANSPORTATION AUTHORITY, AND THE PUERTO RICO PUBLIC BUILDINGS 

AUTHORITY TO EMPLOYEE CLAIMS ASSERTING LIABILITIES OWED BY ENTITIES 

THAT ARE NOT TITLE III DEBTORS

[Signature]

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 (i) the 

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") (Bankruptcy Case No. 17 BK 

4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority 

("PBA", and together with the Commonwealth, COFINA, HTA, ERS, and PREPA, the "Debtors") 

(Bankruptcy Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case 

numbers are listed as Bankruptcy Case numbers due to software limitations.)

Case:17-03283-LTS Doc#:20006-10 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit E-1 Page 22 of 26
Certified to be a correct and true translation from the source text in Spanish to the target language English.

29/DECEMBER/2021 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

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

The Commonwealth of Puerto Rico (the “Commonwealth”), the Commonwealth of Puerto Rico 

Government Employees’ Retirement System (“ERS”), the Puerto Rico Highways and Transportation 

Authority (the "HTA"), and the Puerto Rico Public Buildings Authority (the "PBA," and together with the 

Commonwealth, the ERS, and the HTA, the "Debtors"), by and through the Financial Oversight and 

Management Board for Puerto Rico (the “Oversight Board”), as the Debtors’ sole Title III representative 

pursuant to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act

(“PROMESA”)2 file this three hundred and eightieth omnibus objection (the “Three Hundred and Eightieth 

Omnibus Objection”) seeking to disallow the proofs of claim listed on Exhibit A hereto, each of which 

asserts liabilities associated with allegedly unpaid wages or other employment benefits purportedly owed 

by entities that are not Title III debtors, but which fails to comply with the applicable rules by not providing 

a basis for purporting to assert a claim against the Commonwealth, ERS, PBA, or any other Title III Debtor. 

In support of the Three Hundred and Eightieth Omnibus Objection, the Debtors respectfully represent as 

follows:

JURISDICTION

1. The United States District Court for the District of Puerto Rico has subject matter jurisdiction to 

hear this matter and grant the relief requested herein pursuant to PROMESA section 306(a).

[Signature]

2 PROMESA is codified under Title 48 U.S.C., §§ 2101-2241.

2

Case:17-03283-LTS Doc#:20006-10 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit E-1 Page 23 of 26
Certified to be a correct and true translation from the source text in Spanish to the target language English.

29/DECEMBER/2021 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

ORDERED that the Three Hundred and Eightieth Omnibus Objection is GRANTED 

as set forth herein; and it is further

ORDERED that the Claims to Be Disallowed are hereby disallowed in their entirety; 

and it is further

ORDERED that Prime Clerk, LLC, is authorized and directed to delete the Claims to Be Disallowed 

from the official claims registry in the Title III Cases; and it is further 

ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the implementation, interpretation, or enforcement of this Order.

SO ORDERED. 

Date: _________________________ 

___________________________________________________

Honorable Judge Laura Taylor Swain 

United States District Judge

3

Case:17-03283-LTS Doc#:20006-10 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit E-1 Page 24 of 26
Certified to be a correct and true translation from the source text in Spanish to the target language English.

29/DECEMBER/2021 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:20006-10 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit E-1 Page 25 of 26
TRANSLATOR’S CERTIFICATE OF TRANSLATION

Translation from: Spanish (Puerto Rico) into English (US)

TARGEM Translations Inc.

I, Andreea I. Boscor, ATA-certified Spanish-English #525556, acting as translator at TARGEM Translations Inc., a NEW 

YORK City corporation, with its principal office at 185 Clymer Street, Brooklyn, NY, 11211, USA, certify that:

the English translated document is a true and accurate translation of the original Spanish and has been translated to 

the best of my knowledge.

Original Document Name: Claim No. 172107

 

Signed this 29th day of December, 2021 

__________________________ 

 Andreea I. Boscor

Case:17-03283-LTS Doc#:20006-10 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit E-1 Page 26 of 26