EXHIBIT F-1 

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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 that 

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 pursuant to section 304(a) of PROMESA, initiating a case under 

Title III of that body of law (the "ERS Title III Case" and the ACT 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 that 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

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

17 BK 3283-LTS.

3

[Handwritten:] Wilfredo Silva Rivera

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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 evidence of claims under the Title III 

Cases. Following the informational motion of certain creditors, and the Debtors' support, the Court 

thereafter entered the Order A) setting deadlines and procedures 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 Motion for Deadline and set 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 until July 29, 

2020 (inclusive) at 4:00 p.m. (AST) by way of the Order A) setting deadlines and procedures for 

filing proofs of claim and B) 

4

[Handwritten:] Wilfredo Silva Rivera

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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, and PBA.

NOTICE OF THE THREE HUNDRED EIGHTIETH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO, THE 

EMPLOYEES’ RETIREMENT SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO, 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 

F1LED.

IF YOUR CLAIM IS LISTED ON EXHIBIT A, YOU SHOULD READ THIS NOTICE 

AND THE OMNIBUS OBJECTION CAREFULLY AND DISCUSS IT WITH YOUR 

ATTORNEY. IF YOU DO NOT HAVE AN ATTORNEY, YOU MAY WISH 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 Puerto Rico 

[Handwritten:] Wilfredo Silva Rivera

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Oversight, Management, and Economic Stability Act (“PROMESA"),1filed the Three hundred 

and 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 DEMANDED BY THE 

OMNIBUS OBJECTION WITHOUT FURTHER NOTICE OR HEARING.

[Additional pages follow]

____________________________

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

[Handwritten:] Wilfredo Silva Rivera

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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 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 Employees' 

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

Highways and Transportation Authority (the “ERS” [sic]), and the Puerto Rico Public Buildings Authority 

(the "PBA," and together with the Commonwealth and ERS, the "Debtors").

3. 1 submit this declaration in support of the Three Hundred and Eightieth Omnibus Objection 

(Substantive) of the Commonwealth of Puerto Rico, the Employees’ Retirement 

___________________________________

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

2

[Handwritten:] Wilfredo Silva Rivera

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System of the Government of the Commonwealth of Puerto Rico, 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 and Eightieth Omnibus 

Objection”).3I have personally reviewed the Three Hundred and 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 rejected, as identified in Exhibit A to the Three hundred and 

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 

Housing Finance Authority, the Puerto Rico Sugar Corporation, the Puerto Rico Telephone Company.

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

___________________________________

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

hundred and Eightieth Omnibus Objection

3

[Handwritten:] Wilfredo Silva Rivera

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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:

[Handwritten:] Wilfredo Silva Rivera

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

[Handwritten:] Wilfredo Silva Rivera

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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. 1

PROMESA

Title III

No. 17 BK 3283-LTS 

(Jointly Administered) 

This filing relates to the Commonwealth, 

ERS, HTA and PBA.

DECLARATION 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, AND THE PUERTO 

RICO PUBLIC BUILDINGS AUTHORITY TO EMPLOYEE CLAIMS ASSERTING 

LIABIL1TIES OWED BY ENTITIES THAT ARE NOT TITLE III DEBTORS

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) Commonwealth of Puerto Rico Government Employees’ Retirement 

System ("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-BK5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as Bankruptcy 

Case numbers due to software limitations.)

[Handwritten:] Wilfredo Silva Rivera

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EXHIBIT B

Declaration of Jay Herriman

[Handwritten:] Wilfredo Silva Rivera

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[Handwritten:] Wilfredo Silva Rivera

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EXHIBIT D

Proposed Order

[Handwritten:] Wilfredo Silva Rivera

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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. 1

PROMESA

Title III

No. 17 BK 3283-LTS 

(Jointly Administered) 

This filing relates to the 

Commonwealth, the ERS, the ACT 

and the PBA.

ORDER GRANTING THE THREE HUNDRED AND EIGHTIETH OMNIBUS OBJECTION 

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

RETIREMENT SYSTEM OF THE GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO, 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

Having heard the Three Hundred and Eightieth Omnibus Objection (substantive) of the 

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

Commonwealth of Puerto Rico, 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 and Eightieth [...]

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) Commonwealth of Puerto Rico Government Employees’ Retirement 

System ("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.)

[Handwritten:] Wilfredo Silva Rivera

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

Employees’ Retirement System of the Government of the Commonwealth of Puerto Rico (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 in their entirety certain 

claims asserted against the Debtors, 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 Eighty-First Omnibus Objection having been timely served on 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 Eighty-First 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,

___________________________________

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

Eightieth Omnibus Objection

2

[Handwritten:] Wilfredo Silva Rivera

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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 THOROUGHLY IN ORDER TO 

DETERMINE WHETHER THIS 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, and PBA.

THREE HUNDRED AND EIGHTIETH OMNIBUS OBJECTION (SUBSTANTIVE) OF 

THE COMMONWEALTH OF PUERTO RICO, THE EMPLOYEES’ RETIREMENT 

SYSTEM OF THE GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO, 

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

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) Commonwealth of Puerto Rico Government Employees’ Retirement 

System ("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-BK5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as Bankruptcy 

Case numbers due to software limitations.)

[Handwritten:] Wilfredo Silva Rivera

Case:17-03283-LTS Doc#:20006-12 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit F-1 Page 22 of 27
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 Employees’ Retirement 

System of the Government of the Commonwealth of Puerto Rico (“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”)2file 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 asserting liabilities 

associated with allegedly unpaid wages or other employment benefits purportedly owed by entities 

that are not Title III debtors, but failing to comply with the applicable rules by not providing a 

basis for purporting to assert a claim against the Commonwealth, ERS, HTA, 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 consider this matter and the relief requested herein pursuant to PROMESA section 

306(a).

___________________________________

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

2

[Handwritten:] Wilfredo Silva Rivera

Case:17-03283-LTS Doc#:20006-12 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit F-1 Page 23 of 27
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

[Handwritten:] Wilfredo Silva Rivera

Case:17-03283-LTS Doc#:20006-12 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit F-1 Page 24 of 27
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.

[Handwritten:] Wilfredo Silva Rivera

Case:17-03283-LTS Doc#:20006-12 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit F-1 Page 25 of 27
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#:20006-12 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit F-1 Page 26 of 27
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. 172169 (2)

 

Signed this 29th day of December, 2021 

__________________________ 

 Andreea I. Boscor

Case:17-03283-LTS Doc#:20006-12 Filed:02/02/22 Entered:02/02/22 19:49:57 Desc:

Exhibit F-1 Page 27 of 27