________________________

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 SUBMITTING EXHIBIT LIST

FOR DECEMBER 14-15, 2022 OMNIBUS HEARING WITH REGARDS TO 

EMPRESAS OMAJEDE’S RESPONSE TO 519TH OMNIBUS OBJECTION

TO THE HONORABLE UNITED STATES DISTRICT JUDGE LAURA TAYLOR SWAIN:

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

counsel, and, submits its Exhibit List.

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 intends to appear 

in person at the December Omnibus Hearing to file an exhibit list with all of its 

documentary evidence as attachments to said list. Dkt. 22907

3. The Debtor’s 519th Omnibus Objection (Dkt. 22254) was originally 

scheduled for the Nov. 2-3, 2022 Omnibus Hearing, when the Debtor adjourned said 

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objection solely with respect to Empresas Omajede’s First Amended Claim (Claim # 

70324) 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 Debtor 

to a later omnibus hearing 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-ap00076-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 submit its exhibit list and 

to submit as attachments to its exhibit list those documents to be listed in Exhibit 

C to its Informative Motion and which it may present as evidence (solely in the 

Omnibus Hearing). Empresas Omajede reserves all rights, including the right to use 

exhibits identified on other parties’ exhibits lists, the right to use additional exhibits 

for cross-examination or rebuttal if necessary, and the right to revise, amend, and/or 

supplement this list, for reasons including but not limited to adjournment of the 

519th Omnibus Objection with respect to the Empresas Omajede Claim to a later 

omnibus hearing.

WHEREFORE, Empresas Omajede, Inc. respectfully requests that the Court

take notice of the submitted documentary evidence and exhibit list; and grant any 

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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.

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

Case:17-03283-LTS Doc#:23006 Filed:12/07/22 Entered:12/07/22 11:12:48 Desc: Main

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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.

EMPRESAS OMAJEDE’S

EXHIBIT LIST

Exhibit Identifier Description of Exhibits

EO A Lease Agreement with certified translation

EO B Acceptance and Registration with certified translation

EO C Lease Amendment and Registration with certified 

translation

EO D First Letter with certified translation

EO E Second Letter with certified translation

EO F Customer Ledger with certified translation

EO G Invoices with certified translation

EO H Letter to PSC with certified translation

EO I Initial POC

EO J First Amended POC

EO K Second Amended POC

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