UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

---------------------------------------------------------------x

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

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PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

STATUS REPORT OF FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD IN CONNECTION WITH FEBRUARY 2–3, 2022 OMNIBUS HEARING 

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

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”), the Puerto Rico Electric Power Authority 

(“PREPA”), and the Puerto Rico Public Buildings Authority (“PBA,” and together with the 

Commonwealth, HTA, ERS, and PREPA, the “Debtors”), by and through the Financial Oversight 

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

of the Debtors pursuant to section 315(b) of the Puerto Rico Oversight, Management, and 

Economic Stability Act (“PROMESA”), respectfully submit this Status Report in connection with 

 

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 

(“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”) (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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the February 2–3, 2022 omnibus hearing and in response to this Court’s order, dated January 24, 

2022 [Case No. 17-BK-03283, ECF No. 19865].

I. General Status and Activities of the Oversight Board, Including Measures Taken in 

Response to the COVID-19 Pandemic, Preparations for PRRADA Compliance, and 

Anticipated Timetables for Implementation of the Recently–Confirmed Plans of 

Adjustment

1. The Oversight Board and the Government of Puerto Rico (the “Government”) 

continue to collaborate to protect the health and welfare of the people of Puerto Rico from the 

COVID-19 virus and to utilize effectively federal funding related to the COVID-19 pandemic.

2. On January 18, 2022, the Court confirmed the Modified Eighth Amended Title III 

Joint Plan of Adjustment of the Commonwealth of Puerto Rico, et al., dated January 14, 2022 [Case 

No. 17-BK-03283, ECF No. 19784] (the “Modified Eighth Amended Plan”). The effective date 

of the Modified Eighth Amended Plan is projected to occur on or before March 15, 2022. The 

Oversight Board and the Puerto Rico Fiscal Agency and Financial Advisory Authority 

(“AAFAF”), among other parties, are working collaboratively to finalize various documents and 

transactions necessary for the consummation of the Modified Eighth Amended Plan. To those 

ends, the Oversight Board (a) in consultation with the Governor and AAFAF, certified the 2022 

Fiscal Plan for the Commonwealth, which, among other things, incorporates the terms of the 

Modified Eighth Amended Plan, at a public meeting on January 27, 2022; and (b) is preparing the 

Third Amended Plan Supplement and Plan Related Documents of the Commonwealth of Puerto 

Rico, et al. Now that the 2022 Fiscal Plan for the Commonwealth has been certified, the Oversight 

Board will begin the process of amending the 2022 Budget for the Commonwealth. 

3. On January 20, 2022, the Court approved the Qualifying Modification for the 

Puerto Rico Convention Center District Authority [Case No. 21-01493, ECF No. 72] (the “CCDA 

QM”) and the Qualifying Modification for the Puerto Rico Infrastructure Financing Authority 

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[Case No. 21-01492, ECF No. 82] (the “PRIFA QM”). The effective dates of the CCDA QM and 

PRIFA QM are projected to occur contemporaneously with the effective date of the Modified 

Eighth Amended Plan on or before March 15, 2022.

4. On January 20, 2022, President Biden signed Public Law No. 117-82, the Puerto 

Rico Recovery Accuracy in Disclosures Act (“PRRADA”). PRRADA mandates certain 

disclosures for professionals applying for compensation pursuant to sections 316 and 317 of 

PROMESA. On January 21, 2022, the Court entered the Order Directing Parties to Meet and 

Confer Regarding the Enactment of the Puerto Rico Recovery Accuracy in Disclosures Act [Case 

No. 17-BK-03283, ECF No. 19860] (the “PRRADA Order”), which directs the Oversight Board’s 

counsel, the Fee Examiner, and the Office of the United States Trustee (the “Conferring Parties”)

to meet and confer to discuss PRRADA’s requirements. In compliance with the PRRADA Order, 

the Conferring Parties and counsel for AAFAF met on January 26, 2022 and January 28, 2022. 

On January 31, 2022, pursuant to the PRRADA Order, the Conferring Parties filed for the Court’s 

consideration an informative motion containing various proposals to ensure compliance with 

PRRADA [Case No. 17-BK-03283, ECF No. 19964]. While the conferees anticipate certain 

disputes relating to retroactivity and related issues in the implementation of PRRADA, they agreed 

(i) on a procedure for consideration of the Oversight Board’s proposal of a material interested party 

list (the “MIP List”) and ultimate approval of an MIP List, (ii) on a procedure designed to avoid 

any unnecessary delays by having professionals submit their interim fee applications to the Fee 

Examiner without delays, while awaiting the approval of the MIP List and their preparations of 

their disclosures of connections before filing their applications in accordance with PRRADA, (iii) 

the continuation of the professionals’ monthly invoices and partial payments because they are not 

applications for interim or final fees, and (iv) on certain material issues about PRRADA’s 

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implementation, especially insofar as it imposes requirements retroactively on professionals, 

which issues will require resolution if and to the extent a professional is not disinterested or 

represented an adverse interest to the Debtors prior to enactment of PRRADA.

II. General Status of Relations Among the Oversight Board and Commonwealth and 

Federal Governments

5. The Oversight Board’s relationship with the Government continues to be 

collaborative and the Oversight Board is working closely with Puerto Rico Governor Pedro R. 

Pierluisi and the rest of the Commonwealth administration. The Oversight Board and Government 

remain in agreement that the health, safety, and economic welfare of the people of Puerto Rico 

must be the priority. Governor Pierluisi is serving as his own ex officio representative on the 

Oversight Board, which affords more opportunity for direct interactions, and sharing of viewpoints 

and insights on important issues.

6. In addition to working together to accomplish the items necessary for the 

implementation of the Modified Eighth Amended Plan, the CCDA QM, and the PRIFA QM, the 

Oversight Board and AAFAF are also working together to restructure bonds issued by the Puerto 

Rico Public Finance Corporation (“PFC”) pursuant to Title VI of PROMESA. To those ends, on 

January 20, 2022, the Oversight Board, AFFAF, on behalf of the PFC, and certain holders of bonds 

issued by PFC (the “PFC Bonds”) entered into a Restructuring Support Agreement, which provides 

for the restructuring of the PFC Bonds. The Oversight Board and AAFAF are preparing a draft of 

the qualifying modification and corresponding solicitation materials. 

III. General Status of Work Toward Plans of Adjustment for PREPA and HTA

A. PREPA Plan of Adjustment

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7. As noted in the January 19, 2022 Status Report,2to the extent practicable the 

Oversight Board determined to move forward with the settlement set forth in the May 2019 

Restructuring Support Agreement (“PREPA RSA”), which would enable filing a plan of 

adjustment for PREPA. The PREPA RSA eliminates PREPA as the obligor on the bond debt and 

thereby eliminates PREPA’s default risk and creditors’ remedies. The Oversight Board is 

continuing its efforts to propose a plan by the end of March 2022, but is cognizant of the fact that 

the date may slip to the second quarter due to circumstances outside the Oversight Board’s control. 

Implementation of the PREPA RSA remains dependent on the Puerto Rico Legislature passing

certain legislation required by the terms of the RSA. The Oversight Board has prepared a draft of 

the necessary legislation and contacted certain legislative leaders to request its enactment. 

8. The Oversight Board will assess the feasibility and implementation of the PREPA 

RSA based on the outcome of the legislative process. The Oversight Board continues to believe 

the PREPA RSA represents the best case scenario for all relevant parties, and is therefore focused 

on restructuring PREPA’s debt in accordance with the RSA as opposed to alternative scenarios 

that may include less favorable terms for PREPA, bondholders, and customers. 

B. HTA Plan of Adjustment 

9. The Oversight Board has been working actively to prepare the plan of adjustment 

for HTA (the “HTA Plan”) and has received comments from various parties in interest. As part 

of this process, on January 3, 2022, the Oversight Board requested proposals for an independent, 

third-party analysis on the socioeconomic effects of toll increases in Puerto Rico. 

 

2

Status Report of the Government Parties Regarding the COVID-19 Pandemic and the 9019 Motion, [Case No. 17-

BK-4780, ECF No. 2691] (the “January 19, 2022 Status Report”). Capitalized terms not otherwise defined herein 

shall have the meaning given to them in the January 19, 2022 Status Report.

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10. The Oversight Board will continue to work collaboratively with the parties in 

interest to develop the HTA Plan and hopes to file the HTA Plan in the first quarter of 2022. The 

timing may be impacted by receipt from the Government of relevant information, including the 

generation of necessary financial and other information, and the certification of a fiscal plan for 

HTA.

IV. General Status of ADR and ACR Processes, Anticipated Number of Matters Directed 

into ADR, and Anticipated Timetable for Initiation of ADR Procedures with Respect 

to Such Matters

11. Pursuant to the Order (A) Authorizing Administrative Resolution of Claims, (B) 

Approving Additional Form of Notice, and (C) Granting Related Relief [ECF No. 12274] (the 

“ACR Order”), the Debtors have filed twenty-two notices transferring claims into Administrative 

Claims Reconciliation (as defined in the ACR Order), see First Notice of Transfer of Claims to 

Administrative Claims Reconciliation [ECF No. 13603] (the “First ACR TransferNotice”), Second 

Notice of Transfer of Claims to Administrative Claims Reconciliation [ECF No. 14182] (the 

“Second ACR Transfer Notice”), Third Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 14785] (the “Third ACR Transfer Notice”), Fourth Notice of Transfer of 

Claims to Administrative Claims Reconciliation [ECF No. 15027] (the “Fourth ACR Transfer

Notice”), Fifth Notice of Transfer of Claims to Administrative Claims Reconciliation [ECF No. 

15086] (the “Fifth ACR Transfer Notice”), Sixth Notice of Transfer of Claims to Administrative 

Claims Reconciliation [ECF No. 15116] (the “Sixth ACR Transfer Notice”), Seventh Notice of 

Transfer of Claims to Administrative Claims Reconciliation [ECF No. 15534] (the “Seventh ACR 

Transfer Notice”), Eighth Notice of Transfer of Claims to Administrative Claims Reconciliation

[ECF No. 15721] (the “Eighth ACR Transfer Notice”), Ninth Notice of Transfer of Claims to 

Administrative Claims Reconciliation [ECF No. 15948] (the “Ninth ACR Transfer Notice”), Tenth 

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Notice of Transfer of Claims to Administrative Claims Reconciliation [ECF No. 16259] (the 

“Tenth ACR Transfer Notice”), Eleventh Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 16514] (the “Eleventh ACR Transfer Notice”), Twelfth Notice of 

Transfer of Claims to Administrative Claims Reconciliation [ECF No. 16677] (the “Twelfth ACR 

Transfer Notice”), Thirteenth Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 16926] (the “Thirteenth ACR Transfer Notice”), Fourteenth Notice of 

Transfer of Claims to Administrative Claims Reconciliation [ECF No. 17128] (the “Fourteenth 

ACR Transfer Notice”), Fifteenth Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 17212] (the “Fifteenth ACR Transfer Notice”), Sixteenth Notice of 

Transfer of Claims to Administrative Claims Reconciliation [ECF No. 17320] (the “Sixteenth ACR 

Transfer Notice”), Seventeenth Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 17968] (the “Seventeenth ACR Transfer Notice”), Eighteenth Notice of 

Transfer of Claims to Administrative Claims Reconciliation [ECF No. 18364] (the “Eighteenth 

ACR Transfer Notice”), Nineteenth Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 18956] (the “Nineteenth ACR Transfer Notice”), Twentieth Notice of 

Transfer of Claims to Administrative Claims Reconciliation [ECF No. 19490] (the “Twentieth 

ACR Transfer Notice”), Twenty-First Notice of Transfer of Claims to Administrative Claims 

Reconciliation [ECF No. 19626] (the “Twenty-First ACR Transfer Notice”), Twenty-Second 

Notice of Transfer of Claims to Administrative Claims Reconciliation [ECF No. 19675] (the 

“Twenty-Second ACR Transfer Notice,” and collectively, the “ACR Transfer Notices”), and have 

transferred approximately 44,701 claims (collectively, the “ACR Designated Claims”), into 

Administrative Claims Reconciliation. The ACR Designated Claims will be resolved utilizing the 

Pension/Retiree Procedures, the Tax Refund Procedures, the Public Employee Procedures, and/or 

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the Grievance Procedures (each as defined in the ACR Order), as set forth in the ACR Transfer 

Notices.

12. Subsequent thereto, the Debtors have filed notices, see Notice of Filing of First 

Administrative Claims Resolution Status Notice [ECF No. 14515] and accompanying First 

Administrative Claims Resolution Status Notice [ECF No. 14515-1] (the “First ACR Status 

Notice”), Notice of Filing of Second Administrative Claims Resolution Status Notice [ECF No. 

15367] and accompanying Second Administrative Claims Resolution Status Notice [ECF No. 

15367-1] (the “Second ACR Status Notice”), Notice of Filing of Third Administrative Claims 

Resolution Status Notice [ECF No. 15812] and accompanying Third Administrative Claims 

Resolution Status Notice [ECF No. 15812-1] (the “Third ACR Status Notice”), Fourth 

Administrative Claims Reconciliation Notice [ECF No. 16322] (the “Fourth ACR Status Notice”), 

Fifth Administrative Claims Reconciliation Notice [ECF No. 16888], Sixth Administrative Claims 

Reconciliation Notice [ECF No. 16888] (the “Sixth ACR Status Notice”), Seventh Administrative 

Claims Reconciliation Notice [ECF No. 18363] (the “Seventh ACR Status Notice”), Eighth 

Administrative Claims Reconciliation Notice [ECF No. 19380] (the “Eighth ACR Status Notice”), 

and Ninth Administrative Claims Reconciliation Status Notice [ECF No. 19945] (the “Ninth ACR 

Status Notice”) wherein the Debtors reported the successful resolution of over 26,127 ACR 

Designated Claims. The Debtors’ next ACR Status Notice (as defined in the ACR Order) is 

scheduled to be filed on March 29, 2022, and the Debtors anticipate reporting the successful 

resolution of hundreds of additional ACR Designated Claims.

13. With respect to certain ACR Designated Claims, mailings have been made, or are 

in the process of distribution, informing claimants that the administrative files for their claims are 

incomplete, and requesting additional information in order to enable the Debtors to reconcile their 

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claims. Certain claimants have provided responses to these mailings, and the Debtors are 

evaluating the additional information received and determining whether the information received 

is sufficient to complete the claimants’ administrative file; where necessary, the Debtors will 

follow up with the claimants to ensure they have a complete administrative file for such claimants. 

The Debtors continue to await responses from additional claimants. In many instances, the 

Debtors have re-sent mailings to claimants who did not respond to the Debtors’ initial letter, 

reiterating their request for information sufficient to complete the claimants’ administrative file, 

and warning them that failure to respond may force the Debtors to object to their claims. The 

Debtors continue to await responses from such claimants, and may ultimately be forced to object 

to their claims. With respect to additional ACR Designated Claims, mailings have been made, or 

are in the process of distribution, informing claimants of the initiation of the ACR process and the 

timetable for the resolution of their ACR-related claims. 

14. As of July 13, 2021, the Commonwealth, ERS, and PBA had transferred into ACR 

all outstanding claims which they understood, as of that date, were eligible for such transfer. The 

Debtors’ analysis of outstanding claims remains ongoing, however. Accordingly, the Debtors 

identified additional claims suitable for transfer into ACR which were transferred pursuant to the 

Seventeenth ACR Transfer Notice, the Eighteenth ACR Transfer Notice, the Nineteenth ACR 

Transfer Notice, the Twentieth ACR Transfer Notice, the Twenty-First ACR Transfer Notice, and 

the Twenty-Second ACR Transfer Notice. To the extent the Commonwealth, ERS, and PBA 

identify additional claims eligible for ACR, they will be transferred into the ACR Procedures. The 

Debtors’ next ACR Transfer Notice (as defined in the ACR Order) is scheduled to be filed on 

December 28, 2021. The Debtors may transfer additional claims into Administrative Claims 

Reconciliation on or before that date.

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15. Pursuant to the Order (A) Authorizing Alternative Dispute Resolution Procedures, 

(B) Approving Additional Forms of Notice, and (C) Granting Related Relief [ECF No. 12576] (the 

“ADR Order”), the Debtors have filed nineteen notices transferring claims into the ADR 

Procedures (as defined in the ADR Order), see First Notice of Transfer of Claims to Alternative 

Dispute Resolution [ECF No. 13609] (the “First ADR Notice”), Second Notice of Transfer of 

Claims to Alternative Dispute Resolution [ECF No. 14090] (the “Second ADR Notice”), Third 

Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 14521] (the “Third ADR 

Notice”), Fourth Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 14786] 

(the “Fourth ADR Notice”), Fifth Notice of Transfer of Claims to Alternative Dispute Resolution 

[ECF No. 15085] (the “Fifth ADR Notice”), Sixth Notice of Transfer of Claims to Alternative 

Dispute Resolution [ECF No. 15113] (the “Sixth ADR Notice”), Seventh Notice of Transfer of 

Claims to Alternative Dispute Resolution [ECF No. 15217] (the “Seventh ADR Notice”), Eighth 

Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 15533] (the “Eighth ADR 

Notice”), Ninth Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 15720] 

(the “Ninth ADR Notice”), Tenth Notice of Transfer of Claims to Alternative Dispute Resolution 

[ECF No. 15861] (the “Tenth ADR Notice”), Amended Eleventh Notice of Transfer of Claims to 

Alternative Dispute Resolution [ECF No. 16540] (the “Eleventh ADR Notice”), Twelfth Notice of 

Transfer of Claims to Alternative Dispute Resolution [ECF No. 16517] (the “Twelfth ADR 

Notice”), Thirteenth Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 

16767] (the “Thirteenth ADR Notice”), Fourteenth Notice of Transfer of Claims to Alternative 

Dispute Resolution [ECF No. 17208] (the “Fourteenth ADR Notice”), Fifteenth Notice of Transfer 

of Claims to Alternative Dispute Resolution [ECF No. 17832] (the “Fifteenth ADR Notice”), 

Sixteenth Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 18259] (the 

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“Sixteenth ADR Notice”), Seventeenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 19169] (the “Seventeenth ADR Notice”), Eighteenth Notice of Transfer of 

Claims to Alternative Dispute Resolution [ECF No. 19594] (the “Eighteenth ADR Notice”), 

Nineteenth Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 19671] (the 

“Nineteenth ADR Notice,” and collectively, the “ADR Notices”), and have transferred 

approximately 378 claims into the ADR Procedures.

16. Subsequent thereto, the Debtors have filed notices, see First Alternative Dispute 

Resolution Status Notice [ECF No. 14185] (the “First ADR Status Notice”), Second Alternative 

Dispute Resolution Status Notice [ECF No. 15028-1] (the “Second ADR Status Notice”), Third 

Alternative Dispute Resolution Status Notice [ECF No. 15551-1] (the “Third ADR Status Notice”),

Fourth Alternative Dispute Resolution Status Notice [ECF No.15958-1] (the “Fourth ADR Status 

Notice”), Fifth Alternative Dispute Resolution Status Notice [ECF No. 16684] (the “Fifth ADR 

Status Notice”), Amended Sixth Alternative Dispute Resolution Status Notice [ECF No. 17267] 

(the “Sixth ADR Status Notice”), Seventh Alternative Dispute Resolution Status Notice [ECF No. 

17997] (the “Seventh ADR Status Notice”), Eighth Alternative Dispute Resolution Status Notice 

[ECF No. 18981] (the “Eighth ADR Status Notice”), Ninth Alternative Dispute Resolution Status 

Notice [ECF No. 19624] (the “Ninth ADR Status Notice,” and collectively, the “ADR Status 

Notices”) indicating five (5) claims were settled in Evaluative Mediation (as defined in the ADR 

Order), sixteen (16) claims have been fully resolved, well over one hundred claims are currently 

in the Offer-Exchange (as defined in the ADR Order) phase of the ADR Procedures and have 

received either an Offer or an Information Request (as defined in the ADR Order), and 

approximately eleven (11) claimants have accepted the Debtors’ offers. The Debtors are in the 

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process of documenting the resolution of claims as to which offers have been accepted or 

agreements in principle have been reached.

17. The Debtors are also evaluating all responses received to Information Requests and 

Offers, and attempting to engage claimants in the hopes of achieving a consensual resolution of

the remaining claims currently in the Offer-Exchange procedures. Certain claimants have not 

responded to Information Requests or Offers, and the Debtors have already or are in the process 

of re-sending mailings to claimants who did not respond. The Debtors continue to await responses 

from such claimants, and may ultimately be forced to object to their claims. In addition, the 

Debtors are in the process of preparing offers or making Information Requests to additional ADR 

Designated Claimants. The Debtors’ next ADR Transfer Notice (as defined in the ADR Order) is 

due February 4, 2021, and the Debtors anticipate transferring additional claims into the ADR 

Procedures on that date.

18. The Debtors’ review and analysis of the claims filed to date remains ongoing. At 

present, the Debtors continue to estimate conservatively that the maximum number of claims that 

might be transferred into the ADR Procedures is 7,000, while the actual number transferred might 

be as low as 1,000 claims. At this time, the Debtors cannot predict with certainty the timing for 

the initiation of ADR Procedures with respect to this population of claims, but anticipate additional 

accounts payable and litigation-related claims will be transferred into the ADR Procedures in the 

near term.

V. Anticipated Timing and Volume of Objections to Claims

19. The Debtors’ claims reconciliation process remains ongoing. Accordingly, the 

Debtors anticipate that they will continue to schedule omnibus and/or individual claim objections 

for the next several omnibus hearings. However, the Debtors also anticipate that, going forward, 

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the number of claim objections scheduled for each omnibus hearing will be comparatively fewer 

in number, with fewer claims being included on each omnibus objection.

20. While the Commonwealth, ERS, PBA, and HTA have resolved a substantial 

number of their claims, the Debtors continue to identify claims filed at each entity that are best 

resolved via objection. For example, the Debtors anticipate continuing to file omnibus and/or 

individual objections to claims that have been subsequently amended, that are duplicative of 

master claims, that have been satisfied and released, that are late filed, or that assert liabilities 

owed by entities that are not Title III debtors, among other possible bases. Further, as noted above, 

the Debtors may also be forced to object to claims held by claimants who have not responded to 

mailings sent in the ADR and ACR processes. In addition, as the Debtors’ focus shifts to PREPA’s 

restructuring, the Debtors anticipate that, while the total number of omnibus objections may 

decrease, the number of omnibus and individual claim objections filed by PREPA may increase. 

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Dated: February 1, 2022

San Juan, Puerto Rico

Respectfully submitted,

/s/ Martin J. Bienenstock

Martin J. Bienenstock

Brian S. Rosen

Paul V. Possinger

Ehud Barak

(Admission Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: mbienenstock@proskauer.com

 brosen@proskauer.com

 ppossinger@proskauer.com 

 ebarak@proskauer.com

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

-and-

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Co-Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

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