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.I 

PRO MESA 

Title III 

No. 17 BK 3283 

( Jointly Administered) 

Opposition to Debtor's Omnibus Objection " Five Hundred Twenty - Six" 

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

NOW COME: Rivera Garcia, Myrna (Claim No. 32127) and Valle Valdivieso, 

Luz (Claim No. 113154), who are judgment claimants in the case of Nilda AgostoMaldonado Plaintiffs Group, case no. K PE 2005-0608;-through the undersigned 

attorney and states as follows: 

1. On September 16, 2022, the Financial Oversight and Management Board 

for Puerto Rico, as Representative of the Commonwealth of Puerto Rico, filed the 

"Five Hundred Twenty - Six Omnibus Objections" (Substantive) seeking to 

disallow individual claims listed on Exhibit A of the reference omnibus objections 

by asserting that the claims included in referenced motion are not named plaintiffs 

in the litigation they asserts and seeks the Court Approval for the dismissal of the 

claim 

2. That the Five Hundred Twenty - Six Omnibus Objection" is premised solely 

in the declaration Jay Herriman who as a Managing Director of A&M, and is one 

of the persons responsible for overseeing the claims reconciliation and objection 

process in the Debtors' cases filed pursuant to PROMESA. 

3 That although Mr. Herriman asserts in his declaration, that to the best of 

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his knowledge, and belief, the information contained in the Five Hundred TwentySixth Omnibus Objection and exhibits to it, are true and correct, and the relief 

requested therein is in the best interests of the Debtors and their creditors, at 

paragraph 5, erroneously states that the Claim filed by Valle Valdivieso, Luz (Claim 

No. 113154), be Disallowed and which claim is identified in Exhibit "A" do not 

appear in the charts or captions included in the Agosto Maldonado Master Claim 

or Judgment, and the claimants are therefore not plaintiffs in the Litigation. 

4. In regards the Claim No. 32127, is, herein informed that on this date, the 

claimant have filed a Motion for Leave to Amend Proof of Claim Knoll No. 

32127, due to the fact that by mistake or inadvertence, the POC had an error in 

the plaintiff's name, since the correct name of the Plaintiff's is Myrna Rivera 

Garcia, not Minerva, (See Docket entry No. 22622) 

5. In view of the above information, it is respectfully submitted that the claims 

asserted by appearing claimants, does not fit the reason stated in Exhibit A to the 

526th Omnibus Objection, and statements, included in Mr. Herriman declaration 

and dismissal or disallowance request, since this Court can verify that information 

provided in EXHIBIT A of the referenced omnibus objections, are inaccurate, 

because Movants names are included in the judgment entered in the case of 

Nilda Agosto Maldonado, enclosed to this Motion as Exhibit 1. 1 

6. Also because the above identified claims, as therein asserted are 

deemed allowed under Section 502(a) of the bankruptcy Code, since the prima 

1 For the certified translation of judgement see ECF No. 18697 

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facie validity of the Movants Claims, has not been overcome by the 

Commonwealth in order for the Commonwealth to obtain the disallowance of the 

Movants Claims under Section 502(b) and 502(c) of the Bankruptcy Code and, 

therefore, the Movants Claims, as set forth in the POC should be allowed in the 

asserted amount of$ $9, 111 .90_and $ 703.68_respectively, pursuant to 11 U.S.C. 

§ 502(b)&(c), as the Commonwealth had not met its burden to overcome the prima 

facie validity of the above-identified claims and, as an allowed. claims may 

participate in the corresponding distribution that may eventually be approved in 

this Title Ill proceeding. 

WHEREFORE, in view of the above and pursuant to governing law, it is 

respectfully requested that this Honorable Court dismiss with prejudice, the 

omnibus objection with respect to the individual claims above identified, since the 

appearing claimants are included in the Nilda Agosto-Maldonado judgment and 

Master claim. 

RESPECTFULLY SUBMITTED, in San Juan, Puerto Rico, on October, 17, 

2022. 

IT IS HEREBY CERTIFIED, that on this same date we have electronically 

filed the Foregoing motion with the Clerk of the Court using the CM/ECF 

System, which will send notification of such filing to all counsels of record. 

By /s/ Ivonne Gonzalez Morales 

Ivonne Gonzalez - Morales 

RUA 3725 USDC-PR 202701 

P.O. BOX 9021828 

San Juan, P.R. 00902-1828 

Telephone: 787-410-0119 

Email- ivonnegm@prw.net 

Attorney for the Group Creditors 

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