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.

REPLY OF THE COMMONWEALTH OF PUERTO RICO TO RESPONSE FILED BY 

CLAIMANT CARMEN R. LÓPEZ CAMACHO [ECF NO. 19429] TO THE THREE 

HUNDRED EIGHTY-THIRD OMNIBUS OBJECTION (SUBSTANTIVE) TO 

EMPLOYEE CLAIMS ASSERTING LIABILITIES OWED BY ENTITIES THAT ARE 

NOT TITLE III DEBTORS

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

The Commonwealth of Puerto Rico (the “Commonwealth”), 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 Puerto Rico Oversight, Management, and 

 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”) (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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Economic Stability Act (“PROMESA”),2 files this reply (the “Reply”) to the Replica de Objeción 

Global [ECF No. 19429] (the “López Camacho Response”) filed by Carmen R. López Camacho 

(“López Camacho”) and in support of the Three Hundred Eighty-Third Omnibus Objection 

(Substantive) of the Commonwealth of Puerto Rico to Employee Claims Asserting Liabilities Owed 

By Entities That Are Not Title III Debtors [ECF No. 17922] (the “Three Hundred Eighty-Third

Omnibus Objection”), and in support of the Reply, respectfully states as follows:

1. On August 20, 2021, the Debtors filed the Three Hundred Eighty-Third Omnibus 

Objection seeking to disallow claims asserting liabilities associated with allegedly unpaid wages 

or other employment benefits purportedly owed by entities that are not Title III debtors, but which 

fail to comply with the applicable rules by not providing a basis for asserting a claim against the 

Commonwealth or any other Title III Debtor, each as listed on Exhibit A thereto. 

2. Any party who disputed the Three Hundred Eighty-Third Omnibus Objection was 

required to file a response by 4:00 p.m. (Atlantic Standard Time) on September 20, 2021, in 

accordance with the Court-approved notices attached to the Three Hundred Eighty-Third Omnibus 

Objection as Exhibit C, which were served in English and Spanish on the individual creditors 

subject to the Three Hundred Eighty-Third Omnibus Objection, the U.S. Trustee, and the Master 

Service List (as defined in the Fifteenth Amended Case Management Procedures [ECF No. 17127-

1]). See Certificate of Service [ECF No. 17989].

3. López Camacho filed a proof of claim against the Commonwealth on June 10, 2021, 

and it was logged by Prime Clerk as Proof of Claim No. 179349 (the “López Camacho Claim”). 

The López Camacho Claim purports to assert liabilities associated with allegedly accrued, but 

unpaid, wages purportedly owed by the Telephone Company. 

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

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4. The López Camacho Response was filed on December 6, 2021, and logged as ECF 

No. 19429 on December 7, 2021. Therein, López Camacho states that “[t]he Court must not grant 

the omnibus objection since the money is pursuant to [] laws passed by the government of the 

Commonwealth of Puerto Rico. . . . I am claiming the increases under the laws that were signed 

during the period in which the P.R. Tel. Company belonged to the government of the 

Commonwealth. This was until 1999 when the government of Puerto Rico sold the company, and 

it became private.” López Camacho Response at 1-2. The López Camacho Response also

enclosed documentation demonstrating López Camacho’s employment with Claro, the successor 

entity to the Telephone Company.

5. However, neither the López Camacho Claim nor the López Camacho Response 

provides a basis for asserting a claim against the Commonwealth or any other Title III Debtor in 

respect of allegedly accrued but unpaid wages purportedly owed by former government entities, 

such as the Telephone Company. Accordingly, the López Camacho Claim should be disallowed.

6. For the foregoing reasons, the Commonwealth respectfully requests the Court 

sustain the Three Hundred Eighty-Third Omnibus Objection and disallow the López Camacho 

Claim, notwithstanding the Response.

[Remainder of Page Intentionally Left Blank]

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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

Gabriel A. Miranda

USDC No. 306704

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

for Puerto Rico, as representative for 

the Commonwealth of Puerto Rico

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