Presentment Date: April 7, 2023

Objection Deadline: April 6, 2023 at 4:00 p.m. (AST)

UNITED STATES DISTRICT COURT 

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.

NOTICE OF PRESENTMENT OF PROPOSED ORDER GRANTING 

THE FIVE HUNDRED FIFTY-FOURTH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO TO 

UNLIQUIDATED CLAIMS (ECF NO. 23096)

PLEASE TAKE NOTICE that, on March 30, 2023, the Commonwealth of Puerto Rico 

(the “Commonwealth” or the “Objecting Debtor”), by and through the Financial Oversight and 

Management Board for Puerto Rico (the “Oversight Board”), as the sole Title III representative of 

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

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 (“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-BK3566-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).

Case:17-03283-LTS Doc#:23892 Filed:03/30/23 Entered:03/30/23 10:54:49 Desc: Main

Document Page 1 of 5
2

Economic Stability Act (“PROMESA”),2 hereby submits this Notice of Presentment of Proposed 

Order Granting the Five Hundred Fifty-Fourth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Unliquidated Claims (this “Notice”).

PLEASE TAKE FURTHER NOTICE that, on December 16, 2022, the Commonwealth,

by and through the Oversight Board, filed the Five Hundred Fifty-Fourth Omnibus Objection 

(Substantive) of the Commonwealth of Puerto Rico to Unliquidated Claims [ECF No. 23096] (the 

“Five Hundred Fifty-Fourth Omnibus Objection”) to the proofs of claim listed on Exhibit A

thereto. 

PLEASE TAKE FURTHER NOTICE that, the Five Hundred Fifty-Fourth Omnibus

Objection was initially scheduled for hearing on February 1, 2023. 

PLEASE TAKE FURTHER NOTICE that, any party against whom the Five Hundred 

Fifty-Fourth Omnibus Objection was served, or any other party to the Debtors' Title III cases who 

objected to the relief sought therein, was required to file and serve a response to the Five Hundred 

Fifty-Fourth Omnibus Objection with the clerk’s office of the United States District Court for the 

District of Puerto Rico (the “Court”) by 4:00 p.m. (Atlantic Standard Time) on January 17, 2023

(the “Response Deadline”).

PLEASE TAKE FURTHER NOTICE that, as set forth in Exhibit C to the Five Hundred 

Fifty-Fourth Omnibus Objection, if no responses were filed by the Response Deadline, the Five 

Hundred Fifty-Fourth Omnibus Objection “will be deemed unopposed and may be granted unless:

(1) the requested relief is forbidden by law; (2) the requested relief is against public policy; or (3) 

in the opinion of the court, the interest of justice requires otherwise.” Ex. C to the Five Hundred 

Fifty-Fourth Omnibus Objection, [ECF No. 23096-4, at 2].

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

Case:17-03283-LTS Doc#:23892 Filed:03/30/23 Entered:03/30/23 10:54:49 Desc: Main

Document Page 2 of 5
3

PLEASE TAKE FURTHER NOTICE that, according to this Court’s Sixteenth Amended 

Case Management Procedures [ECF No. 20190-1] (the “Case Management Procedures”), the 

Court may enter an order granting request for relief without a hearing upon receipt of a certificate 

of no objection (“CNO”, as defined by the Case Management Procedures). See Case Management 

Procedures, Section III, paragraph P.

PLEASE TAKE FURTHER NOTICE that, in accordance with the Case Management 

Procedures, the undersigned hereby certifies that this Notice is filed not less than forty-eight (48) 

hours after the expiration of the Response Deadline.

PLEASE TAKE FURTHER NOTICE that, the undersigned hereby certifies that counsel 

for the Oversight Board has reviewed, not less than forty-eight (48) hours after expiration of the 

Response Deadline, (i) the docket in the above-captioned case, (ii) mailings received by Kroll 

Restructuring Associates, LLC (“Kroll”), (iii) mailings received by the Oversight Board, and (iv) 

mailings received by counsel for the Official Committee of Unsecured Creditors of the 

Commonwealth of Puerto Rico and forwarded to counsel for the Oversight Board and, to the best 

of the undersigned’s knowledge, no applicable objection, responsive pleading, or request for a 

hearing with respect to the Five Hundred Fifty-Fourth Omnibus Objection has been submitted.

PLEASE TAKE FURTHER NOTICE that, attached hereto as Exhibit A is a proposed 

order (the “Proposed Order”) granting the relief requested in the Five Hundred Fifty-Fourth 

Omnibus Objection.

PLEASE TAKE FURTHER NOTICE that, pursuant to Paragraph III.H of the Case 

Management Procedures, “the presentment of a proposed order for administrative relief must be 

filed and served at least seven (7) calendar days before the presentment date, and Objections 

thereto must be filed and served at least one (1) calendar day before the presentment date,” and 

Case:17-03283-LTS Doc#:23892 Filed:03/30/23 Entered:03/30/23 10:54:49 Desc: Main

Document Page 3 of 5
4

accordingly, unless a written objection to the Proposed Order is filed with the Court by 4:00 p.m. 

(Atlantic Standard Time) on April 6, 2023, the relief requested in the Five Hundred Fifty-Fourth

Omnibus Objection shall be deemed unopposed, and the Proposed Order may be entered without 

a further hearing.

PLEASE TAKE FURTHER NOTICE that, copies of all documents filed in these Title 

III cases are available (a) free of charge by visiting https://cases.ra.kroll.com/puertorico or by 

calling +1 (844) 822-9231, and (b) on the Court’s website at http://www.prd.uscourts.gov, subject 

to the procedures and fees set forth therein.

[Remainder of Page Intentionally Left Blank]

Case:17-03283-LTS Doc#:23892 Filed:03/30/23 Entered:03/30/23 10:54:49 Desc: Main

Document Page 4 of 5
5

Dated: March 30, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Brian S. Rosen 

Martin J. Bienenstock

Brian S. Rosen

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: mbienenstock@proskauer.com

 brosen@proskauer.com

/s/ Luis F. del Valle-Emmanuelli

Luis F. del Valle-Emmanuelli

USDC-PR No. 209514

P.O. Box 79897

Carolina, Puerto Rico 00984-9897

Tel. 787.647.3503

Fax N.A

dvelawoffices@gmail.com

OF COUNSEL FOR

A&S LEGAL STUDIO, PSC

434 Avenida Hostos

San Juan, PR 00918

Tel. (787) 751-6764/763-0565

Fax (787) 763-8260

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative of the Commonwealth of Puerto 

Rico

Case:17-03283-LTS Doc#:23892 Filed:03/30/23 Entered:03/30/23 10:54:49 Desc: Main

Document Page 5 of 5