Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 1 of 9
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 ERS and 

HTA.

ORDER GRANTING FOUR HUNDRED EIGHTY-SIXTH OMNIBUS OBJECTION 

(NON-SUBSTANTIVE) OF THE EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO AND THE 

PUERTO RICO HIGHWAYS AND TRANSPORTATION AUTHORITY TO CROSSDEBTOR DUPLICATE CLAIMS 

Upon the Four Hundred Eighty-Sixth Omnibus Objection (Non-Substantive) of the 

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

Puerto Rico Highways and Transportation Authority to Cross-Debtor Duplicate Claims [ECF No. 

21736] (“Four Hundred Eighty-Sixth Omnibus Objection”)2 filed by the Employees Retirement 

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) 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”, 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).

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

in the Four Hundred Eighty-Sixth Omnibus Objection.

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 2 of 9
2

System of the Government of the Commonwealth of Puerto Rico (“ERS”) and the Puerto Rico 

Highways and Transportation Authority (“HTA,” and together with ERS, the “Debtors”), dated 

August 5, 2022, for entry of an order disallowing in their entirety certain claims filed against the 

Debtors, as more fully set forth in the Four Hundred Eighty-Sixth Omnibus Objection and 

supporting exhibits thereto; and the Court having jurisdiction to consider the Four Hundred EightySixth Omnibus Objection and to grant the relief requested therein pursuant to PROMESA Section 

306(a); and venue being proper pursuant to PROMESA Section 307(a); and due and proper notice 

of the Four Hundred Eighty-Sixth Omnibus Objection having been provided to those parties 

identified therein, and no other or further notice being required; and each of the claims filed against 

the Debtors identified in the column titled “Claims to Be Disallowed” in Exhibit A to the Four 

Hundred Eighty-Sixth Omnibus Objection (collectively, the “Claims to Be Disallowed”) being 

duplicative of claims asserted against the Commonwealth of Puerto Rico (the “Commonwealth”), 

for which the asserted liability would lie, if at all, against the Commonwealth, not ERS or HTA; 

and the Court having determined that the relief sought in the Four Hundred Eighty-Sixth Omnibus 

Objection is in the best interest of the Debtors and their creditors, and all the parties in interest; 

and the Court having determined that the legal and factual bases set forth in the Four Hundred 

Eighty-Sixth Omnibus Objection establish just cause for the relief granted herein; and after due 

deliberation and sufficient cause appearing therefor, it is

ORDERED that the Four Hundred Eighty-Sixth 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

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 3 of 9
3

ORDERED that the Debtors’ right to object to the Remaining Claims on any 

grounds whatsoever is reserved; and it is further

ORDERED that Kroll is authorized and directed to designate as expunged the 

Claims to Be Disallowed from the official claims register in the Title III Cases; and it is further

ORDERED that this Order resolves Docket Entry No. 21736 in Case No. 17-3283; 

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

Dated: 

Honorable Judge Laura Taylor Swain

United States District Judge 

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 4 of 9
EXHIBIT A

Schedule of Claims Subject to the Four Hundred Eighty-Sixth Omnibus Objection 

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 5 of 9
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Eighty-Sixth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 1 05/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

ALBETORIO DIAZ, 34661 $331.38*

MARIA E

COOP. JARD. DE SAN 

IGNACIO

APT.1812-1

SAN JUAN, PR 00927

ALBETORIO DIAZ, 

MARIA E

COOP. JARD. DE SAN 

IGNACIO

APT.1812-1

SAN JUAN, PR 00927

06/27/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

55356 $331.38*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

 2 04/02/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

ALERS NIEVES, LUIS 5597 $48,910.00*

A

3413 CALLE 

MELODIA

ISABELA, PR 

00662-5303

ALLERS-NIEVES, LUIS 

ANTONIO

CALLE MELODIA 3413

ISABELA, PR 00662

05/29/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

43128 $20,000.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

 3 06/18/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

BARRETO REYES, 63054 Undetermined*

ANA M.

HC 2 BOX 16588

ARECIBO, PR 00612

BARRETO REYES, ANA 

M

HC 2 BOX 16588

ARECIBO, PR 00612

06/18/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

62651 $125,000.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

 4 06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

COLON TORRES, 121773 $16,800.00*

NEYSHA

URB EL 

COMANDANTE

872 CALLE MARIA 

GIUSTI

SAN JUAN, PR 00924

COLON TORRES, 

NEYSHA M

URB. EL 

COMANDANTE

872 CALLE MARIA 

GIUSTI

SAN JUAN, PR 00924

06/29/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

139753 $16,800.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 6 of 9
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Eighty-Sixth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 5 05/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

CRUZ GUZMAN, 28289 $300,000.00*

TEODORO

URB VILLA MADRID

G-IO CALLE 9

COAMO, PR 00769

CRUZ GUZMAN, 

TEODORO

URB VILLA MADRID

G-IO CALLE 9

COAMO, PR 00769

06/05/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

47402 $300,000.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

 6 06/06/18 17 BK 03567-LTS

Puerto Rico Highways and 

Transportation Authority

DIAZ RODRIGUEZ, 32940 Undetermined*

GABRIEL

COND TORRE ALTA 

PH 1

URUGUAY ST 274

SAN JUAN, PR 00917

DIAZ RODRIGUEZ, 

GABRIEL

274 URUGUAY ST.

COND TORRE ALTA PH 

1

SAN JUAN, PR 00917

06/06/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

31772 Undetermined*

Reason: Duplicate liability filed against Debtor Puerto Rico Highways and Transportation Authority.

Surviving Claim # 31772 is on Omni 433 Claims To Be Reclassified from Commonwealth to HTA

 7 03/07/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

LUNA DE JESUS, 2194 $29,350.00*

MIGUEL A

500 AVE NORFE APT. 

1405

VISTA DE 

MONTECASINO

TOA ALTA, PR 00953

LUNA DE JESUS , 

MIGUEL A

500 AVE. NORFE APT. 

1405

VISTA DE MONTE 

CASINO

TOA ALTA, PR 00953

03/07/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

1858 $19,350.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 7 of 9
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Eighty-Sixth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 8 06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

MENDEZ GONZALEZ, 90489 $467,437.03*

ANGEL

C/O MARVIN DIAZ 

FERRER

COND VICK CENTER 

STE C202

867 AVE MUÑOZ 

RIVERA

SAN JUAN, PR 00925

MENDEZ GONZALEZ, 

ANGEL

C/O MARVIN DIAZ 

FERRER

COND VICK 

CENTERSTE C202

867 AVE. MUNOZ 

RIVERA

SAN JUAN, PR 00925

06/29/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

86454 $467,437.03*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

 9 05/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

NAZARIO ACOSTA, 40049 $75,889.24*

RICARDO

AVE. TITO CASTRO 

609

SUITE 102 PMB-416

PONCE, PR 00716

NAZARIO ACOSTA, 

RICARDO

AVE. TITO CASTRO 609

SUITE 102 PMB-416

PONCE, PR 00716

05/29/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

27691 $1,521,855.11

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

 10 05/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

SÁNCHEZ ORTIZ, 28504 $500,000.00*

NORMA IRIS

EDGARDO 

SANTIAGO LLORENS

1925 BLVD. LUIS A. 

FERRÉ

URB. SAN ANTONIO

PONCE, PR 00728

SANCHEZ ORTIZ, 

NORMA IRIS

LCDO. EDGARDO 

SANTIAGO LLORENS

1925 BLV. LUIS A. 

FERRE

SAN ANTONIO

PONCE, PR 00728-1815

06/05/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

37151 $500,000.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

*Indicates claim contains unliquidated and/or undetermined amounts 3

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 8 of 9
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Eighty-Sixth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

11 06/22/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

SUAREZ RAMIREZ, 37398 $20,000.00*

MARIANA

BOX 913

YAUCO, PR 

00698-0913

SUÁREZ RAMÍREZ, 

MARIANA

BOX 913

YAUCO, PR 00698-0913

06/22/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

39191 $12,000.00*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the 

Commonwealth of Puerto Rico.

*Indicates claim contains unliquidated and/or undetermined amounts 4

Case:17-03283-LTS Doc#:23330-1 Filed:01/25/23 Entered:01/25/23 12:32:35 Desc:

Exhibit A Page 9 of 9