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)

Re: ECF Nos. 22262 and 23363

MOTION SUBMITTING REVISED PROPOSED ORDER GRANTING THE FIVE 

HUNDRED TWENTY-NINTH OMNIBUS OBJECTION (SUBSTANTIVE) OF 

THE COMMONWEALTH OF PUERTO RICO TO DUPLICATE AND 

NO LIABILITY BOND CLAIMS

To the Honorable United States District Judge Laura Taylor Swain:

The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), 

as the sole Title III representative of the Commonwealth of Puerto Rico (the “Commonwealth”)

pursuant to Section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability 

Act (“PROMESA”),2 respectfully submits this motion submitting a revised proposed order 

 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); 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 PROMESA is codified at 48 U.S.C. §§ 2101-2241.

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granting the Five Hundred Twenty-Ninth Omnibus Objection (Substantive) of the Commonwealth 

of Puerto Rico to Duplicate and No Liability Bond Claims [ECF No. 22262] (the “Five Hundred 

Twenty-Ninth Omnibus Objection”).

1. On September 16, 2022, the Commonwealth, by and through the Oversight Board, 

filed the Five Hundred Twenty-Ninth Omnibus Objection.

2. Thereafter, on January 25, 2023, the Commonwealth, by and through the Oversight 

Board, filed the Notice of Presentment of Proposed Order Granting the Five Hundred TwentyNinth Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico to Duplicate and No 

Liability Bond Claims [ECF No. 23363] the (“Notice of Presentment”), which included, as 

Exhibit A thereto [ECF No. 23363-1], a proposed order (the “Proposed Order”) granting the relief 

requested in the Five Hundred Twenty-Ninth Omnibus Objection.

3. Upon further review, the Proposed Order did not include certain clarifying language 

that the Oversight Board agreed to insert at the request of a claimant subject to the Five Hundred 

Twenty-Ninth Omnibus Objection. 

4. Accordingly, attached hereto as Exhibit 1 is a revised proposed order (the “Revised 

Proposed Order”) incorporating that clarifying language, and attached hereto as Exhibit 2 is a 

redline identifying all changes to the Proposed Order.

WHEREFORE, the Oversight Board respectfully requests that this Honorable Court take 

notice of this filing and enter the Revised Proposed Order granting the Five Hundred TwentyNinth Omnibus Objection.

[Remainder of Page Intentionally Left Blank]

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Dated: February 16, 2023 Respectfully submitted,

San Juan, Puerto Rico

/s/ Ricardo Burgos Vargas

Ricardo Burgos Vargas

USDC núm. 218210

A&S LEGAL STUDIO, PSC

434 Ave. Hostos

San Juan, PR 00918

Tel.: (787) 751-6764

Fax: (787) 763-8260

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico

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