Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23343-1 Filed:01/25/23 Entered:01/25/23 13:23:37 Desc:

Exhibit A Page 1 of 6
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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 ERS.

ORDER GRANTING FIVE HUNDRED SEVENTEENTH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO TO NO LIABILITY 

CLAIMS FILED BY AEELA MEMBERS

Upon the Five Hundred Seventeenth Omnibus Objection (Substantive) of the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico to No 

Liability Claims Filed by AEELA Members [ECF No. 22246] (“Five Hundred Seventeenth 

Omnibus Objection”)2 filed by the Employees Retirement System of the Government of the 

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 Five Hundred Seventeenth Omnibus Objection.

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Commonwealth of Puerto Rico (“ERS” or the “Debtor”), dated September 16, 2022, for entry of 

an order disallowing in their entirety certain claims filed against ERS, as more fully set forth in 

the Five Hundred Seventeenth Omnibus Objection and supporting exhibits thereto; and the Court 

having jurisdiction to consider the Five Hundred Seventeenth 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 Five Hundred Seventeenth 

Omnibus Objection having been provided to those parties identified therein, and no other or further 

notice being required; and the claims identified in the column titled “Claims to be Disallowed” in 

Exhibit A to the Five Hundred Seventeenth Omnibus Objection (collectively, the “Claims to Be 

Disallowed”) asserting claims for which the Debtors are not liable; and the Court having 

determined that the relief sought in the Five Hundred Seventeenth Omnibus Objection is in the 

best interest of ERS, its creditors, and all the parties in interest; and the Court having determined 

that the legal and factual bases set forth in the Five Hundred Seventeenth Omnibus Objection 

establish just cause for the relief granted herein; and after due deliberation and sufficient cause 

appearing therefor, it is

ORDERED that the Five Hundred Seventeenth 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 Kroll is authorized and directed to designate the Claims to Be 

Disallowed as expunged on the official claims register in the Title III Case; and it is further

ORDERED that this Order resolves Docket Entry No. 22246 in Case No. 17-3283; 

and it is further

Case:17-03283-LTS Doc#:23343-1 Filed:01/25/23 Entered:01/25/23 13:23:37 Desc:

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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#:23343-1 Filed:01/25/23 Entered:01/25/23 13:23:37 Desc:

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EXHIBIT A

Schedule of Claims Subject to the Five Hundred Seventeenth Omnibus Objection 

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Five Hundred Seventeenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

06/28/2018 17 BK 03566-LTS Employees Retirement System 122230-1

of the Government of the 

Commonwealth of Puerto Rico

 1 RIVERA MORALES, MARISELA

VICTOR ROJA 2

CALLE 6

CASA 101

ARECIBO, PR 00612

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Employees Retirement System of the Government of the Commonwealth of Puerto Rico. Proof of Claim and 

supporting documentation only show liability between Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim 

has been transferred into the Administrative Claims Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute 

an objection to the portion of the claim in the ACR process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

05/25/2018 17 BK 03566-LTS Employees Retirement System 34058-1

of the Government of the 

Commonwealth of Puerto Rico

 2 RIVERA ROBLES, ANTONIA

208 MANZANILLA ST

CANOVANAS, PR 00729-9835

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Employees Retirement System of the Government of the Commonwealth of Puerto Rico. Proof of Claim and 

supporting documentation only show liability between Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. Claim # 34058 is on 

Omni 337 Claims To Be Reclassified. Because this objection does not constitute an objection to the portion of the claim asserting litigation, the Debtors’ reserve their rights to object to 

the remaining portion of the claim on any other grounds whatsoever.

05/29/2018 17 BK 03566-LTS Employees Retirement System 32233-1

of the Government of the 

Commonwealth of Puerto Rico

 3 TORRES ROSARIO, LOURDES

PMB 170

RR 5 BOX 4999

BAYAMON, PR 00956

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Employees Retirement System of the Government of the Commonwealth of Puerto Rico. Proof of Claim and 

supporting documentation only show liability between Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. Claim # 32233 is on 

Omni 337 Claims To Be Reclassified. Because this objection does not constitute an objection to the portion of the claim asserting litigation, the Debtors’ reserve their rights to object to 

the remaining portion of the claim on any other grounds whatsoever.

TOTAL Undetermined*

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23343-1 Filed:01/25/23 Entered:01/25/23 13:23:37 Desc:

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