Exhibit A

Proposed Order

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Proposed Order Page 1 of 20
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 the 

Commonwealth and ERS.

ORDER GRANTING FIVE HUNDRED THIRTIETH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO AND THE 

EMPLOYEES RETIREMENT SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO TO PARTIAL DUPLICATE, DEFICIENT, NO 

LIABILITY, AND INCORRECT DEBTOR BOND CLAIMS

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

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

Commonwealth of Puerto Rico to Partially Duplicate, Deficient, No Liability, and Incorrect 

Debtor Bond Claims [ECF No. 22263] (“Five Hundred Thirtieth Omnibus Objection”)2 filed by 

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 Thirtieth Omnibus Objection.

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2

the Commonwealth of Puerto Rico (the “Commonwealth”) and the Employees Retirement System 

of the Government of the Commonwealth of Puerto Rico (“ERS,” and together with the 

Commonwealth, the “Debtors”), dated September 16, 2022, for entry of an order partially 

disallowing and partially reclassifying certain claims filed against the Debtors, as more fully set 

forth in the Five Hundred Thirtieth Omnibus Objection and supporting exhibits thereto; and the 

Court having jurisdiction to consider the Five Hundred Thirtieth 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 Thirtieth 

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

notice being required; and the Court having determined that the claims identified in Exhibit A to 

the Five Hundred Thirtieth Omnibus Objection (the “Claims to Be Partially Disallowed and 

Partially Reclassified”) seek recovery, in part, of amounts for which the Debtors are not liable; and 

the Court having determined that certain of the Claims to Be Partially Disallowed and Partially 

Reclassified should be partially reclassified because a portion of the claim identifies the 

Commonwealth as obligor, when that portion of the claim is properly asserted, if at all, against 

PREPA; and the Court having determined that the relief sought in the Five Hundred Thirtieth 

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

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

Thirtieth Omnibus Objection establish just cause for the relief granted herein; and after due 

deliberation and sufficient cause appearing therefor, it is hereby

ORDERED that the Five Hundred Thirtieth Omnibus Objection is GRANTED as 

set forth herein; and it is further

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3

ORDERED that the portions of the claims identified in Exhibit A to the Five 

Hundred Thirtieth Omnibus Objection (the “Claims to Be Partially Disallowed”) are hereby 

reduced and disallowed, respectively; and it is further

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

reduce the amount asserted in the Claims to Be Partially Disallowed by the disallowed portions 

from the official claims register in the Commonwealth Title III Case; and it is further

ORDERED that the portions of the claims identified in the column titled “Asserted” 

in Exhibit A to the Five Hundred Thirtieth Omnibus Objection (the “Partially Reclassified Bond 

Claims”) are hereby reclassified to be claims asserted against PREPA, as indicated in the column 

titled “Modified and/or Expunged by Plan” in Exhibit A; and it is further

ORDERED that the Debtors’ right to object to the Partially Reclassified Bond 

Claims is reserved; and it is further

ORDERED that Kroll is authorized and directed, in the official claims register in 

the PROMESA cases, to move the claims identified in the column titled “Asserted” in Exhibit A

to the Five Hundred Thirtieth Omnibus Objection from the Title III case for the debtor(s) identified 

in the column titled “Asserted” in Exhibit A to the Five Hundred Thirtieth Omnibus Objection to 

PREPA’s Title III Case (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax 

ID: 3747)); and it is further

ORDERED that this Order resolves Docket Entry No. 22263 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.

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4

Dated: 

 Honorable Judge Laura Taylor Swain

 United States District Judge 

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EXHIBIT A

Schedule of Claims Subject to the Five Hundred Thirtieth Omnibus Objection 

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $2,717,582.82*

Subtotal $2,717,582.82*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $16,939,584.42*

Subtotal $16,939,584.42*

 1 ACP MASTER, LTD. 65801

C/O AURELIUS CAPITAL 

MANAGEMENT, LP

ATTN: DAN GROPPER

535 MADISON AVENUE, 

22ND FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority and the Puerto Rico Ports Authority which is duplicative of 

one or more master proofs of claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability 

with respect to such claims other than as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 1

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $85,361,256.06*

Subtotal $85,361,256.06*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $174,177,106.37*

Subtotal $174,177,106.37*

 2 AURELIUS CAPITAL 66514

MASTER, LTD.

C/O AURELIUS CAPITAL 

MANAGEMENT, LP

ATTN: DAN GROPPER

535 MADISON AVENUE, 

22ND FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. Claimant also asserts, in part, secondarily insured notes whose original CUSIP numbers are associated with one or more bonds issued by HTA that 

are duplicative of one or more Master Proofs of Claim which were filed in the HTA Title III Case by the fiscal agent or trustee of these bond(s). In addition, the Confirmation Order 

provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority and the Puerto Rico Ports Authority which is duplicative of 

one or more master proofs of claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability 

with respect to such claims other than as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 2

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 3 COOPERATIVA A/C LA 12702 Commonwealth of Puerto Rico Secured $2,543,853.00 Commonwealth of Puerto Rico Secured $5,000.00

COMERIENA

PO BOX 289

COMERIO, PR 00782-0289

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Industrial Development Company which is duplicative of one or more master proofs of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Public Finance Corporation which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

Proof of claim also seeks recovery, in part, for amounts for which the Commonwealth is not liable because it asserts interests in note(s) that does not constitute a debt of the 

Commonwealth and are associated with an entity, The Puerto Rico Public Finance Corporation, that is not a Title III Debtor.

Claimant also asserts, in part, liability based on an alleged ownership of GDB Bonds that were subject to the Qualifying Modification, which provided for the issuance of new securities 

in exchange for the cancellation of the GDB Bonds and the extinguishment of the Commonwealth’s guarantee of certain GDB Bonds, and thus the Commonwealth is no longer liable 

for these claims. 

The remaining bonds claimed are all expunged per Plan.

 4 COOPERATIVA DE AHORRO 53610 Commonwealth of Puerto Rico Secured $633,865.11 Commonwealth of Puerto Rico Secured $281,465.73

Y CREDITO DE OFICIALES 

DE CUSTODIA DE PR

ATTN. EPIFANIO TORRES

URB. REPARTO 

METROPOLITANO

1100 CALLE 54 SE

SAN JUAN, PR 00921-2731

Reason: Proof of claim seeks, in part, recovery for amounts for which the Commonwealth is not liable because it assert interests in note(s) for which bondholders have been receiving 

their payments in full, do not constitute a debt of the Commonwealth, and are associated with an entity, The Puerto Rico Aqueducts and Sewers Authority, that is not a Title III Debtor.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Public Finance Corporation which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 3

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 5 COOPERATIVA DE AHORRO 37753 Commonwealth of Puerto Rico Secured $533,365.09 Commonwealth of Puerto Rico Secured $70,000.00

Y CREDITO NAGUABEÑA

ATTN. AXEL SANTIAGO

URB. JUAN MENDOZA

CALLE 3 B1

PO BOX 69

NAGUABO, PR 00718

Reason: Claimant asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority which is duplicative of one or more master proofs of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Public Finance Corporation which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $50,000.00*

Puerto Rico Electric Power Authority Secured $60,000.00*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

 6 ENUDIO NEGRÓN ANGULO 39310 Secured $110,000.00*

RETIREMENT PLAN, 

REPRESENTED BY UBS 

TRUST COMPANY OF 

PUERTO RICO

JAVIER GONZÁLEZ

UBS TRUST COMPANY OF 

PUERTO RICO

250 MUÑOZ RIVERA 

AVENUE 10TH FLOOR

SAN JUAN, PR 00918

Reason: Claimant identifies, in part, obligor as the Commonwealth of Puerto Rico when the proof of claim, supporting documentation, bond name(s) at issue, and/ or the CUSIP 

information show that any liability would reside, if at all, under Puerto Rico Electric Power Authority.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 4

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 7 FIDEICOMISO FLORES 39039 Commonwealth of Puerto Rico Secured $130,000.00* Commonwealth of Puerto Rico Secured $80,000.00*

MORALES, REPRESENTED 

BY UBS TRUST COMPANY 

OF PR

UBS TRUST COMPANY OF 

PUERTO RICO

ATTN: JAVIER GONZÁLEZ

250 MUÑOZ RIVERA 

AVENUE, 10TH FLOOR

SAN JUAN, PR 00918

Reason: Claimant asserts, in part, liability associated with bond(s) issued by the Puerto Rico Electric Power Authority which is duplicative of one or more master proofs of claim filed 

by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $80,000.00*

Puerto Rico Electric Power Authority Secured $50,000.00*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

 8 FIDEICOMISO FLORES 34466 Secured $130,000.00*

MORALES, REPRESENTED 

BY UBS TRUST COMPANY 

OF PUERTO RICO

JAVIER GONZÁLEZ

250 MUÑOZ RIVERA 

AVENUE 10TH FLOOR

SAN JUAN, PR 00918

Reason: Claimant identifies, in part, obligor as the Commonwealth of Puerto Rico when the proof of claim, supporting documentation, bond name(s) at issue, and/ or the CUSIP 

information show that any liability would reside, if at all, under Puerto Rico Electric Power Authority.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 5

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $53,875,053.26*

Subtotal $53,875,053.26*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $68,740,756.47*

Subtotal $68,740,756.47*

 9 MCP HOLDINGS MASTER 66618

LP

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority which is duplicative of one or more master proofs of claim 

filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than 

as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 6

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $1,654,995.79*

Subtotal $1,654,995.79*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $8,717,576.75*

Subtotal $8,717,576.75*

 10 MONARCH ALTERNATIVE 66512

SOLUTIONS MASTER 

FUND LTD.

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority which is duplicative of one or more master proofs of claim 

filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than 

as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 7

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $72,841,472.62*

Subtotal $72,841,472.62*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $101,934,423.77*

Subtotal $101,934,423.77*

11 MONARCH CAPITAL 66444

MASTER PARTNERS III LP

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority which is duplicative of one or more master proofs of claim 

filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than 

as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 8

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $49,334,344.46*

Subtotal $49,334,344.46*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $82,555,834.27*

Subtotal $82,555,834.27*

 12 MONARCH CAPITAL 66487

MASTER PARTNERS IV LP

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan . 

Claimant also asserts, in part, secondarily insured notes whose original CUSIP numbers are associated with one or more bonds issued by HTA that are duplicative of one or more Master 

Proofs of Claim which were filed in the HTA Title III Case by the fiscal agent or trustee of these bond(s). In addition, the Confirmation Order provides for discharge and no further 

liability with respect to such claims other than as provided in the Plan.

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority and the Puerto Rico Ports Authority which is duplicative of 

one or more master proofs of claim filed by the trustee of these bond(s) in the Commonwealth case.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 9

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PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $132,733,983.98*

Subtotal $132,733,983.98*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $154,610,921.09*

Subtotal $154,610,921.09*

 13 MONARCH DEBT 66406

RECOVERY MASTER FUND 

LTD

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority which is duplicative of one or more master proofs of claim 

filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than 

as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Aqueduct and Sewer Authority which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Admin Undetermined*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $132,733,983.98*

Subtotal $132,733,983.98*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Admin Undetermined*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $133,598,050.73*

Subtotal $133,598,050.73*

 14 MONARCH DEBT 66460

RECOVERY MASTER FUND 

LTD

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Proof of claim seeks recovery for amounts for which ERS is not liable because it assert interests in note(s) for which bondholders have been receiving their payments in full, do 

not constitute a debt of ERS, and are associated with an entity, The Puerto Rico Aqueducts and Sewers Authority, that is not a Title III Debtor.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 10

Case:17-03283-LTS Doc#:23373-1 Filed:01/25/23 Entered:01/25/23 19:22:03 Desc:

Proposed Order Page 16 of 20
PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Admin Undetermined*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $54,969,480.23*

Subtotal $54,969,480.23*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Admin Undetermined*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $55,159,385.01*

Subtotal $55,159,385.01*

 15 MONARCH SPECIAL 66364

OPPORTUNITIES MASTER 

FUND LTD.

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Proof of claim seeks recovery for amounts for which ERS is not liable because it assert interests in note(s) for which bondholders have been receiving their payments in full, do 

not constitute a debt of ERS, and are associated with an entity, The Puerto Rico Aqueducts and Sewers Authority, that is not a Title III Debtor.

The remaining bonds claimed are all expunged per Plan.

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $54,969,480.22*

Subtotal $54,969,480.22*

Commonwealth of Puerto Rico Admin Undetermined*

Commonwealth of Puerto Rico Secured $66,204,941.69*

Subtotal $66,204,941.69*

 16 MONARCH SPECIAL 66394

OPPORTUNITIES MASTER 

FUND LTD.

C/O MONARCH 

ALTERNATIVE CAPITAL LP

ATTN: MICHAEL KELLY

535 MADISON AVENUE, 

26TH FLOOR

NEW YORK, NY 10022

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by HTA, which is duplicative of one or more master proofs of claim filed by the trustee of these 

bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than as provided in the Plan .

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority which is duplicative of one or more master proofs of claim 

filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims other than 

as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Convention Center District Authority which are duplicative of the master proof(s) of 

claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability with respect to such claims 

other than as provided in the Plan.

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Aqueduct and Sewer Authority which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 11

Case:17-03283-LTS Doc#:23373-1 Filed:01/25/23 Entered:01/25/23 19:22:03 Desc:

Proposed Order Page 17 of 20
PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 17 MORO ROMERO, JULIO 16715 Commonwealth of Puerto Rico Secured $1,000,000.00* Commonwealth of Puerto Rico Secured Undetermined*

PO BOX 1520

MOCA, PR 00676

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Public Finance Corporation which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

Claimant also asserts, in part, liability based on an alleged ownership of GDB Bonds that were subject to the Qualifying Modification, which provided for the issuance of new securities 

in exchange for the cancellation of the GDB Bonds and the extinguishment of the Commonwealth’s guarantee of certain GDB Bonds, and thus the Commonwealth is no longer liable 

for these claims.

Proof of claim also seeks recovery, in part, for amounts for which the Commonwealth is not liable because it assert interests in note(s) for which bondholders have been receiving their 

payments in full, do not constitute a debt of the Commonwealth, and are associated with an entity, The Puerto Rico Aqueducts and Sewers Authority, that is not a Title III Debtor. 

Claimant also asserts, in part, investments in one or more mutual funds that in turn may have invested in bonds issued by the Commonwealth. The claim thus seeks recovery for an 

amount for which the Commonwealth is not liable because the claimant is not a “creditor” of the Commonwealth and lacks standing to assert this derivative claim.

Claim also purports to assert, in part, liability based on an alleged ownership of COFINA Bonds, and thus seeks recovery for amounts for which the Commonwealth of Puerto Rico is 

not liable because the claims were (1) compromised and settled pursuant to the Settlement Order, and (2) released and discharged in accordance with the Plan and Amended 

Confirmation Order.

The remaining bonds claimed are all expunged per Plan.

 18 RADAMES MUNIZ AND 32883 Commonwealth of Puerto Rico Secured $856,976.00 Commonwealth of Puerto Rico Secured $694,526.00

EMMA M. DE MUNIZ

ADSUAR MUÑIZ GOYCO 

SEDA & PEREZ-OCHOA, 

P.S.C.

P O BOX 70294

SAN JUAN, PR 00936-8294

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Public Finance Corporation which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 12

Case:17-03283-LTS Doc#:23373-1 Filed:01/25/23 Entered:01/25/23 19:22:03 Desc:

Proposed Order Page 18 of 20
PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Unsecured $200,000.00*

Puerto Rico Electric Power Authority Unsecured $100,000.00*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

 19 RHODES, DAVID 7276 Unsecured $450,000.00*

214 EAST 21ST STREET

NEW YORK, NY 10010

Reason: Claimant purports to assert, in part, liability associated with bond(s) issued by PRIFA, however the Confirmation Order provides for discharge and no further liability with 

respect to such claims other than as provided in the Plan.

Claimant also identifies, in part, obligor as the Commonwealth of Puerto Rico when the proof of claim, supporting documentation, bond name(s) at issue, and/ or the CUSIP information 

show that any liability would reside, if at all, under Puerto Rico Electric Power Authority.

The remaining bonds claimed are all expunged per Plan.

 20 RHODES, DAVID 7787 Commonwealth of Puerto Rico Unsecured $450,000.00* Commonwealth of Puerto Rico Unsecured $200,000.00*

214 EAST 21ST STREET

NEW YORK, NY 10010

Reason: Claimant asserts, in part, liability associated with bond(s) issued by the Puerto Rico Infrastructure Financing Authority and the Puerto Rico Ports Authority which is duplicative 

of one or more master proofs of claim filed by the trustee of these bond(s) in the Commonwealth case. In addition, the Confirmation Order provides for discharge and no further liability 

with respect to such claims other than as provided in the Plan.

Claimant also asserts, in part, liability associated with bond(s) issued by the Puerto Rico Electric Power Authority which is duplicative of one or more master proofs of claim filed by 

the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

Secured $40,000.00*

Puerto Rico Electric Power Authority Secured $5,000.00*

Employees Retirement System of the 

Government of the Commonwealth of 

Puerto Rico

 21 THE NILDA E. ORTIZ 34630 Secured $45,000.00*

MELÉNDEZ RETIREMENT 

PLAN, REPRESENTED BY 

UBS TRUST COMPANY OF 

PUERTO RICO

JAVIER GONZÁLEZ

UBS TRUST COMPANY OF 

PUERTO RICO

250 MUÑOZ RIVERA 

AVENUE 10TH FLOOR

SAN JUAN, PR 00918

Reason: Claimant identifies, in part, obligor as the Commonwealth of Puerto Rico when the proof of claim, supporting documentation, bond name(s) at issue, and/ or the CUSIP 

information show that any liability would reside, if at all, under Puerto Rico Electric Power Authority.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 13

Case:17-03283-LTS Doc#:23373-1 Filed:01/25/23 Entered:01/25/23 19:22:03 Desc:

Proposed Order Page 19 of 20
PRIORITY 

STATUS

Five Hundred Thirtieth Omnibus Objection

Exhibit A - Claims to Be Partially Disallowed and Partially Reclassified, Remainder Expunged Per Plan

ASSERTED MODIFIED AND/OR EXPUNGED BY PLAN

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 22 THE NILDA E. ORTIZ 41689 Commonwealth of Puerto Rico Secured $45,000.00* Commonwealth of Puerto Rico Secured $40,000.00*

MELÉNDEZ RETIREMENT 

PLAN, REPRESENTED BY 

UBS TRUST COMPANY OF 

PUERTO RICO

JAVIER GONZÁLEZ

UBS TRUST COMPANY OF 

PUERTO RICO

250 MUÑOZ RIVERA 

AVENUE 10TH FLOOR

SAN JUAN, PR 00918

Reason: Claimant asserts, in part, liability associated with bond(s) issued by the Puerto Rico Electric Power Authority which is duplicative of one or more master proofs of claim filed 

by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

 23 VALDES LLAUGER, 74572 Commonwealth of Puerto Rico Secured $2,875,000.00* Commonwealth of Puerto Rico Secured $2,060,000.00*

EDWARD

1360 CALLE LUCHETTI

APT. NO.5

SAN JUAN, PR 00907

Reason: Claimant asserts, in part, liability based on an alleged ownership of GDB Bonds that were subject to the Qualifying Modification, which provided for the issuance of new 

securities in exchange for the cancellation of the GDB Bonds and the extinguishment of the Commonwealth’s guarantee of certain GDB Bonds, and thus the Commonwealth is no 

longer liable for these claims. 

Claimant also purports to assert, in part, liability associated with bond(s) issued by the Puerto Rico Public Finance Corporation which are duplicative of the master proof(s) of claim 

filed by the trustee of these bond(s) in the Commonwealth case.

The remaining bonds claimed are all expunged per Plan.

*Indicates claim contains unliquidated and/or undetermined amounts 14

Case:17-03283-LTS Doc#:23373-1 Filed:01/25/23 Entered:01/25/23 19:22:03 Desc:

Proposed Order Page 20 of 20