________________________

1 The Last Four Digits of the Federal Tax ID of the Commonwealth of Puerto Rico 

(the Debtor in Bankruptcy Case No. 17- BK-3283 (LTS)) is 3481.

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In Re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO

as a 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.

MOTION TO INFORM EMPRESAS OMAJEDE’S APPEARANCE

AT DECEMBER 14-15, 2022 OMNIBUS HEARING

TO THE HONORABLE UNITED STATES DISTRICT JUDGE LAURA TAYLOR SWAIN:

COMES NOW, EMPRESAS OMAJEDE INC., by and through the undersigned 

counsel, and, states, alleges and prays.

1. On November 23, 2022, the Honorable Court entered an Order setting 

forth the procedures for the omnibus hearing scheduled for December 14-15, 2022. 

(The “221123 Procedures Order”) Dkt. 22907

2. The 221123 Procedures Order requires any party that will appear in 

person at the December Omnibus Hearing to file an informative motion with a Party 

Appearance Cover Sheet. Dkt. 22907

3. Empresas Omajede’s response (Dkt. 22621) to the Debtor’s 519th

Omnibus Objection (Dkt. 22254) with respect to Empresas Omajede.’s First 

Amended Claim (Claim # 70324) was originally scheduled for the Nov. 2-3, 2022 

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omnibus hearing. However, said matter was later adjourned by the Debtor to the Dec. 

14-15, 2022 Omnibus Hearing. Dkt. 22755

4. As said matter is currently scheduled for the Dec. 14-15, 2022 Omnibus 

Hearing, Empresas Omajede intends to appear, solely with respect to said matters 

and solely in the Omnibus Hearing, unless said matter is further adjourned by the 

Debtor or the Court grants Empresas Omajede’s request that the adjudication of the 

519th Omnibus Objection be stayed with respect to the Empresas Omajede Claim, 

until the adjudication of adversary proceeding 22-ap-00076-LTS in accordance with 

Fed. R. Bankr. P. 3007(b).

5. Therefore, in compliance with the requirements of the 221123

Procedures Order, Empresas Omajede files this motion to inform that, with respect 

to Empresas Omajede’s First Amended Claim (Claim # 70324), the Debtor’s 519th

Omnibus Objection (Dkt. 22254) and its Response at Dkt. 22621, it intends to appear 

through the undersigned counsel (solely in the Omnibus Hearing); to present as a 

witness its President, Antonio Betancourt and to present as evidence the documents 

listed in Exhibit C.

6. The required Party Appearance Sheet is attached as Exhibit A hereto.

Also attached as Exhibit B is the Party Witness Cover Sheet and as Exhibit C is 

the Party Exhibit Cover Sheet (as required by the 221123 Procedures Order, the 

Exhibits have been filed with a separate motion at Dkt 23006).

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7. Empresas Omajede, Inc. reserves the right to amend this motion as 

needed, including as a result of any further adjournment to a later Omnibus Hearing.

WHEREFORE, Empresas Omajede respectfully requests that the Court take 

notice of Empresas Omajede’s intent to appear at the Omnibus Hearing and of the 

attached exhibits (Exhibit A, the Party Appearance Sheet, Exhibit B, the Party 

Witness Cover Sheet, and Exhibit C, the Party Exhibit Cover Sheet); deem 

Empresas Omajede in compliance with the 221123 Procedures Order; allow

Empresas Omajede to appear at the December 14-15, 2022 Omnibus Hearing; and 

grant any other relief that it deems just and proper or that may be granted under 

Puerto Rico law or in equity.

CERTIFICATION OF SERVICE: IT IS HEREBY CERTIFIED that, on this same date, I 

electronically filed the foregoing with the Clerk of the Court using the CM/ECF 

system, which will send a true and exact copy of this paper to all registered 

participants, including Ricardo Burgos Vargas and Martin J. Bienenstock, the

attorneys for the Financial Oversight and Management Board for Puerto Rico as 

representative for the Commonwealth of Puerto Rico.

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RESPECTFULLY SUBMITTED.

In San Juan, PR, this 7th day of December, 2022.

DML |Diaz Mayoral Law

Attorney for Empresas Omajede Inc.

s/ Monique Diaz Mayoral

USDC-PR No. 225712

151 San Francisco Street

San Juan, PR 00901

(754)755-5508

m@diazmayorallaw.com

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221123 EXHIBIT A. APPEARANCE SHEET VERSION NOVEMBER 23, 2022 

EXHIBIT A1

PARTY APPEARANCE SHEET

Name of Party Empresas Omajede, Inc.

ATTORNEY 1 Appearance Method In Person at San Juan Courthouse

Name Monique Diaz-Mayoral

Law Firm Diaz Mayoral Law LLC

Email m@diazmayorallaw.com

Phone Number 1(754)755-5508

Dkt. Entry No of NoA 22704

ATTORNEY 2 Appearance Method None.

Name

Law Firm N/A

Email

Phone Number

Dkt. Entry No of NoA N/A

ADDITIONAL 

ATTORNEY

OBSERVATION

Complete the below

information for each

attorney appearing for

observation purposes.

Name

• In Person – PR 

• In Person – NY

• CourtSolutions2

Listen Only

Law Firm

Email

Phone Number

None.

Attorneys who wish to view but not participate in the hearing may gain admittance to the 

San Juan Courtroom or New York Courtroom, on a first-come first-served basis. All 

attorneys who wish to observe in person must be listed on this appearance sheet.

1 This Party Appearance Sheet must be attached to a party in interest’s Informative Motion as 

Exhibit A. 2 Pursuant to the Hearing Procedures Order ¶ 2, attorneys intending to appear by CourtSolutions 

must also separately register on the CourtSolutions website.

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221123 EXHIBIT B. WITNESS COVER SHEET VERSION NOVEMBER 23, 2022 

EXHIBIT B3

PARTY WITNESS COVER SHEET

Name of Party Empresas Omajede, Inc.

Does the Party intend to offer a witness? Yes

Total Number of Witnesses 1

Witness Name Expert or 

Fact Witness

Is interpreter 

required? 

(Proponent of 

witness must 

provide 

certified 

interpreter)*)

Scope of Testimony

Antonio Betancourt

Fact Witness

(only at 

Omnibus 

Hearing)

No

Testimony shall cover the 

validity of the claim, 

including invoices and 

payments received; the Lease 

Agreement and modifications 

and their respective 

registrations; the date the 

Leased Premises was vacated;

the amount owed to Empresas 

Omajede for the unpaid 

balance of the Lease 

Agreement; the POCs filed by 

Empresas Omajede and its 

Response to the Debtor’s 

Objections. (2 hours)

3 This Party Witness Cover Sheet must be attached to a party in interest’s 

Informative Motion as Exhibit BA.

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221123 EXHIBIT C. EXHIBIT COVER SHEET VERSION NOVEMBER 23, 2022 

EXHIBIT C4

PARTY EXHIBIT COVER SHEET

Name of Party Empresas Omajede, Inc.

Does the Party intend to offer evidence? Yes

Docket Entry No. for Party Exhibit List 23006

Exhibit Identifier5 Docket Entry No. of Exhibit Is there a pending request to seal 

this Exhibit?

EO A 23006-01 No

EO B 23006-02 No

EO C 23006-03 No

EO D 23006-04 No

EO E 23006-05 No

EO F 23006-06 No

EO G 23006-07 No

EO H 23006-08 No

EO I 23006-09 No

EO J 23006-10 No

EO K 23006-11, 23006-12, 23006-

13, 23006-14, 23006-15 No

Pursuant to Bankruptcy Local Rule 9037-1(a), parties and counsel are solely responsible 

for redacting the personal identifiers enumerated in Fed. R. Bank. P. 9037(a).

4 This Party Exhibit Cover Sheet must be attached to a party in interest’s Informative Motion as 

Exhibit C.

5 Each Exhibit should be named in sequential party-identified numbering (e.g., “FOMB Ex. 1” or 

“UCC Ex. A”

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