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)

NOTICE OF WITHDRAWAL OF CERTAIN CLAIMS SUBJECT TO OMNIBUS 

OBJECTIONS OF THE COMMONWEALTH OF PUERTO RICO, THE PUERTO RICO 

HIGHWAYS AND TRANSPORTATION AUTHORITY AND THE EMPLOYEES 

RETIREMENT SYSTEM OF THE GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO

To The Honorable United States District Judge Laura Taylor Swain:

1. On May 13, 2022 and September 16, 2022, the Commonwealth of Puerto Rico (the 

“Commonwealth”), the Puerto Rico Highways and Transportation Authority (“HTA”), and the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS,” 

and, together with the Commonwealth and HTA, the “Debtors”), by and through the Financial 

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

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

Management, and Economic Stability Act (“PROMESA”),2 filed various omnibus objections.

2. In light of additional information received since such filings, the Debtors 

respectfully withdraw, without prejudice, their respective objections to the following proofs of 

claim (collectively, the “Withdrawn Claims”):

• Four Hundred Sixty-Sixth Omnibus Objection (Substantive) of the Commonwealth 

of Puerto Rico to Deficient ADR Claims [ECF No. 20797], solely with respect to 

Claim No. 77585;

• Four Hundred Eighty-Seventh Omnibus Objection (Non-Substantive) of the 

Commonwealth of Puerto Rico to Cross-Debtor Duplicate Claims [ECF No. 

21737], solely with respect to Claim No. 83024;

• Five Hundred First Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21758], solely with respect to 

Claim Nos. 64882 and 87400;

• Five Hundred Second Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21759], solely with respect to 

Claim No. 163463-1;

• Five Hundred Fourth Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21760], solely with respect to 

Claim Nos. 140704 and 120153;

• Five Hundred Fifth Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21761], solely with respect to 

Claim Nos. 5607 and 18113-1;

• Five Hundred Sixth Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21762], solely with respect to 

Claim Nos. 85099, 112809, and 136023;

• Five Hundred Seventh Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21763], solely with respect to 

Claim Nos. 178864, 138606, and 120124;

• Five Hundred Eighth Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico and the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico to Unresponsive ACR Claims [ECF No. 21764], 

solely with respect to Claim Nos. 136571, 59034-1, 16395, 152951 and 139436;

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

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• Five Hundred Ninth Omnibus Objection (Substantive) of the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico to Unresponsive 

ACR Claims [ECF No. 21765], solely with respect to Claim No. 167347; and

• Five Hundred Twenty-Eighth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico, the Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico and the Puerto Rico Highways 

and Transportation Authority to Deficient ADR Claims [ECF No. 22260], solely

with respect to Claim Nos. 11316, 9663, and 11316.

3. The Debtors reserve all rights with respect to the Withdrawn Claims, individually 

and collectively, including to object to the Withdrawn Claims on any grounds whatsoever.

[Remainder of Page Intentional Left Blank]

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Dated: October 28, 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-Rivera

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

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico and the Employees Retirement 

System of the Government of the 

Commonwealth of Puerto Rico, and the 

Puerto Rico Public Buildings Authority

/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

Co-Attorneys for the Financial Oversight 

and Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico and the Employees Retirement 

System of the Government of the 

Commonwealth of Puerto Rico, and the 

Puerto Rico Public Buildings Authority

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