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 THE THREE 

HUNDRED FIRST OMNIBUS OBJECTION (NON-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 

MISCELLANEOUS DEFICIENT CLAIMS

To The Honorable United States District Judge Laura Taylor Swain:

1. On March 12, 2021, the Commonwealth of Puerto Rico (the “Commonwealth”), 

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

(“ERS”), and the Puerto Rico Highways and Transportation Authority (“HTA,” and together with 

the Commonwealth and ERS, the “Debtors”), by and through the Financial Oversight 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 (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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Management Board for Puerto Rico (the “Oversight Board”), as the sole Title III representative of 

the Commonwealth pursuant to Section 315(b) of the Puerto Rico Oversight, Management, and 

Economic Stability Act (“PROMESA”),2 filed, inter alia, the Three Hundred First Omnibus 

Objection (Non-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 Miscellaneous Deficient Claims [ECF No. 16021] (the “Three 

Hundred First Omnibus Objection”).

2. In light of additional information received since the filing of the Three Hundred 

First Omnibus Objection, the Debtorsrespectfully withdraw, without prejudice, the Three Hundred 

First Omnibus Objection solely with respect to Proofs of Claim Nos. 175955 and 174471

(collectively, the “Withdrawn Claims”).

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]

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

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Dated: February 2, 2023 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, the Employees Retirement 

System of the Government of the 

Commonwealth of Puerto Rico and the 

Puerto Rico Highways and Transportation 

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, the Employees Retirement 

System of the Government of the 

Commonwealth of Puerto Rico and the 

Puerto Rico Highways and Transportation 

Authority

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