IN THE 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)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE PUERTO RICO ELECTRIC POWER 

AUTHORITY (PREPA)

This filing relates to PREPA 

POC 28744

PROMESA 

Title III 

Case No. 17 BK4780-LTS

MOTION FOR LEAVE TO AMEND PROOF OF CLAIM NUMBER 28744

To the Honorable United States District Judge Laura Taylor Swain:

COMES NOW, creditor, O’Neill Security & Consultant Services, Inc.

(hereinafter “O’Neill”), by and through the undersigned attorney, to respectfully state, and 

request: 

1. On May 29, 2018, O’Neill filed a proof of claim number 28744 based on a 

debt owed by PREPA for services rendered by O’Neill for the amount of $1,946.485.38

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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as of July 2, 2017. After the proof of claim was filed, O’Neill received payments from the 

debtor that reduced the amount owed by PREPA to O’Neill. Therefore, O’Neill requests 

permission to amend POC to reduce the amount of the original POC from $1,946,485.38 

to $829,183.42. 

2. Permission to amend proofs of claim shall be freely given when justice so 

requires (internal quotation marks omitted). In re Roper & Twardowsky, LLC, Case No.: 

15-32878 (SLM), at *27 (Bankr. D.N.J. July 5, 2017).

3. That this request shall in no way negatively affect or limit the rights of any 

of the Debtors or the Financial Oversight and Management Board for Puerto Rico, as 

representative for the Debtors pursuant to PROMESA, or any other party in interest in the 

Title III cases to object to the Claims on any basis whatsoever or otherwise assert any 

defenses whatsoever with respect to the Claims. On the contrary, this request benefits 

the Debtors since we are requesting leave to amend and reduce the claim amount.

WHEREFORE, it is respectfully requested that this Honorable Court grants movant 

leave to amend its proof of claim number 28744 to correct the reduced claim amount with 

any other remedy deemed just and proper.

I HEREBY CERTIFY that on this date, in accordance with Fed. R. Bankr. P. 

9014(b), Fed. R. Bankr. P. 7004(b), we electronically filed the foregoing with the Clerk of 

the Court using the CM/ECF System, which will send notification of such filing to counsels 

of record.

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RESPECTFULLY SUBMITTED.

In Ponce, Puerto Rico, on this 30th day of October 2022.

s/Elías L. Fernández Pérez

ELÍAS L. FERNÁNDEZ PÉREZ

USDC 227404

PO Box 7500

Ponce, P.R. 00732

Tel. (939) 250-0179

Cel. (787) 616-9374

Fax: 1(800) 325-7084

Email: eliaslaureano@gmail.com

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