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)

MOTION SUBMITTING CERTIFIED TRANSLATIONS IN CONNECTION WITH 

DOCKETED CLAIM OBJECTION RESPONSES TO BE HEARD AT THE 

FEBRUARY 16-17, 2022 ADJOURNED OBJECTION HEARING

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 Debtors pursuant to section 315(b) of the Puerto Rico 

Oversight, Management, and Economic Stability Act (“PROMESA”),2 respectfully files this 

motion in compliance with the Court’s December 8, 2021 Order Regarding Adjourned Omnibus 

 

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).

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

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Objections to Claims [ECF No. 19461] (the “Adjourned Objection Hearing Procedures Order”) 

directing the Oversight Board to file (i) any responses that were not filed on the docket and/or (ii) 

certified translations of any Spanish-language responses to claims that the Debtors intend to 

prosecute at the hearing to be held on February 16-17, 2022. Adjourned Objection Hearing 

Procedures Order at 2.

Attached hereto as Exhibit 1 is a certified translation of the response [ECF No. 18290] (the 

“Feliciano Rosado Response”), filed by Maira Feliciano Rosado (“Feliciano Rosado”), to the 

Three Hundred Sixty-Seventh Omnibus Objection (Non-Substantive) of the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico to Employment-Related Claims 

Asserted Against the Incorrect Debtor [ECF No. 17933] (the “Three Hundred Sixty-Seventh 

Omnibus Objection”).

Attached hereto as Exhibit 2 is a certified translation of the response [ECF No. 18875] (the 

“López Báez Response”), filed by claimant Sonia N. López Báez (“López Báez”), to the Three 

Hundred Sixty-Second Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico and 

the Employees Retirement System of the Government of the Commonwealth of Puerto Rico to 

Misclassified Claims [ECF No. 17927] (the “Three Hundred Sixty-Second Omnibus Objection”).

Attached hereto as Exhibit 3 is a certified translation of the response [ECF No. 18110] (the 

“Medina Serrano Response”), filed by claimant Zobeida Medina Serrano (“Medina Serrano”), to 

the Three Hundred Seventy-Fourth Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico, the Puerto Rico Sales Tax Financing Authority, the Puerto Rico Highways and 

Transportation Authority, the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico, and the Puerto Rico Public Buildings Authority to Late-Filed 

Claims [ECF No. 17923] (the “Three Hundred Seventy-Fourth Omnibus Objection”).

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Attached hereto as Exhibit 4 is a certified translation of the response ECF No. 18159] (the 

“Martínez Colón Response”), filed by claimant Facunda Martínez Colón (“Martínez Colón”), in 

response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 5 is a certified translation of the response [ECF No. 18165] (the 

“Gandia Response”), filed by claimant Myriam S. Gandia (“Gandia”), in response to (1) the Three 

Hundred Seventy-Fourth Omnibus Objection and (2) the Three Hundred Eighty-First Omnibus 

Objection (Substantive) of the Commonwealth of Puerto Rico, the Employees Retirement System 

of the Government of the Commonwealth of Puerto Rico, and the Puerto Rico Public Buildings 

Authority to Employee Claims Asserting Liabilities Owed By Entities That Are Not Title III

Debtors [ECF No. 17917] (the “Three Hundred Eighty-First Omnibus Objection”).

Attached hereto as Exhibit 6 is a certified translation of the response [ECF No. 18166] (the 

“Lugo Santana Response”), filed by claimant Ines M. Lugo Santana (“Lugo Sanatana”), in 

response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 7 is a certified translation of the Reply to Three Hundred 

Seventy-Fourth Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico, Puerto 

Rico Sales Tax Financing Authority, Puerto Rico Highways and Transportation Authority, 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico, and Puerto 

Rico Public Buildings Authority to Late-Filed Claims [ECF No. 18177] (the “Febo Vázquez 

Response”), filed by Nydia Febo Vázquez (“Febo Vázquez”), in response to the Three Hundred 

Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 8 is a certified translation of the response [ECF No. 18197] (the 

“Johnson Response”), filed by claimant Obe E. Johnson (“Johnson”), in response to the Three 

Hundred Seventy-Fourth Omnibus Objection.

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Attached hereto as Exhibit 9 is a certified translation of the response [ECF No. 18234] (the 

“Rodríguez González Response”), filed by claimant Hermenegildo Rodríguez González

(“Rodríguez González”), in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 10 is a certified translation of the response [ECF No. 18327] 

(the “Vargas Response”), filed by claimants Ivan Noriega Vargas, Judith Vargas Garcia, and 

Janitza Noriega Vargas (collectively, “Vargas”), in response to the Three Hundred Seventy-Fourth 

Omnibus Objection.

Attached hereto as Exhibit 11 is a certified translation of the response [ECF No. 18376] 

(the “Morales Camacho Response”), filed by claimant Sergio Morales Camacho (“Morales 

Camacho”), in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 12 is a certified translation of the response [ECF No. 18480] 

(the “Rivera Collazo Response”), filed by claimant Victor L. Rivera Collazo (“Rivera Collazo”), 

in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 13 is a certified translation of the response [ECF No. 18507] 

(the “Rodríguez Carcano Response”), filed by claimant Damaris Rodríguez Carcano (“Rodríguez 

Carcano”), in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 14 is a certified translation of the response [ECF No. 19033] 

(the “Martínez Sánchez Response”), filed by claimant Gadiel Martínez Sanchez (“Martínez

Sánchez”), in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 15 is a certified translation of the response [ECF No. 19046] 

(the “Soto Sánchez Response”), filed by claimant Eric J. Soto Sánchez (“Soto Sánchez”), in 

response to the Three Hundred Seventy-Fourth Omnibus Objection.

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Attached hereto as Exhibit 16 is a certified translation of the response [ECF No. 19037] 

(the “Berrios Castrodad Response”), filed by claimant Robert Berrios Castrodad (“Berrios 

Castrodad”), in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 17 is a certified translation of the response [ECF No. 19202] 

(the “Plaza Cruz Response”), filed by claimant Miriam E. Plaza Cruz (“Plaza Cruz”), in response 

to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 18 is a certified translation of the response [ECF No. 19203]

(the “Sanchez Rivera Response”), filed by claimant Madeline Sanchez Rivera (“Sanchez Rivera”), 

in response to the Three Hundred Seventy-Fourth Omnibus Objection.

Attached hereto as Exhibit 19 is a certified translation of the response [ECF No. 18098] 

(the “First Luna Santiago Response”), filed by claimant Julio Luna Santiago (“Luna Santiago”),

to the Three Hundred Eightieth Omnibus Objection (Substantive) of the Commonwealth of Puerto 

Rico, the Employees Retirement System of the Government of the Commonwealth of Puerto Rico, 

the Puerto Rico Highways and Transportation Authority, and the Puerto Rico Public Buildings 

Authority to Employee Claims Asserting Liabilities Owned by Entities that Are Not Title III 

Debtors [ECF No. 17916] (the “Three Hundred Eightieth Omnibus Objection”). 

Attached hereto as Exhibit 20 is a certified translation of the response [ECF No. 19177] 

(the “Second Luna Santiago Response”, and together with the First Luna Santiago Response, the 

“Luna Santiago Responses”), filed by Luna Santiago, in response to the Three Hundred Eightieth 

Omnibus Objection.

Attached hereto as Exhibit 21 is a certified translation of the response [ECF No. 18173] 

(the “Ortiz Castellano Response”), filed by Brenda I. Ortiz Castellano (“Ortiz Castellano”), in 

response to the Three Hundred Eighty-First Omnibus Objection.

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Attached hereto as Exhibit 22 is a certified translation of the response [ECF No. 18175] 

(the “García Miranda Response”), filed by Marlene García Miranda (“García Miranda”), in 

response to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 23 is a certified translation of the response [ECF No. 18212] 

(the “Pagán Duran Response”), filed by Wilfredo Pagán Duran (“Pagán Duran”), in response to 

the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 24 is a certified translation of the response [ECF No. 18216] 

(the “Asencio Bernardini Response”), filed by Brenda T. Asencio Bernardini (“Asencio 

Bernardini”), in response to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 25 is a certified translation of the response [ECF No. 18217] 

(the “Rodríguez Arroyo Response”), filed by José Rodríguez Arroyo (“Rodríguez Arroyo”), in 

response to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 26 is a certified translation of the response [ECF No. 18417] 

(the “Castro Response”), filed by Elia E. Castro (“Castro”), in response to the Three Hundred 

Eighty-First Omnibus Objection.

Attached hereto as Exhibit 27 is a certified translation of the response [ECF No. 18473] 

(the “Laboy Christian Response”), filed by Elena Laboy Christian (“Laboy Christian”), in response 

to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 28 is a certified translation of the response [ECF No. 19153] 

(the “Lebrón Crespo Response”), filed by Gloria Maria Lebrón Crespo (“Lebrón Crespo”), in 

response to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 29 is a certified translation of the response [ECF No. 19474] 

(the “Delgado García Response”), filed by Sara Wilna Delgado García (“Delgado García”), in 

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response to (1) the Three Hundred Eighty-First Omnibus Objection and (2) the Three Hundred 

Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 30 is a certified translation of the response [ECF No. 18213] 

(the “Martínez Quiñones Response”), filed by Lucinda Martínez Quiñones (“Martínez Quiñones”),

in response to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 31 is a certified translation of the response [ECF No. 18263] 

(the “Reyes Miranda Response”), filed by Angel R. Reyes Miranda (“Reyes Miranda”), in 

response to the Three Hundred Eighty-First Omnibus Objection.

Attached hereto as Exhibit 32 is a certified translation of the response [ECF No. 18054] 

(the “Elizabeth Centeno Response”), filed by claimant Elizabeth Martínez Centeno (“Elizabeth 

Centeno”), in response to the Three Hundred Eighty-Second Omnibus Objection (Substantive) of 

the Commonwealth of Puerto Rico and the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico to Employee Claims Asserting Liabilities Owed by Entities that Are 

Not Title III Debtors [ECF No. 17920] (the “Three Hundred Eighty-Second Omnibus Objection”).

Attached hereto as Exhibit 33 is a certified translation of the response [ECF No. 18055] 

(the “Damaris Centeno Response”), filed by claimant Damaris Martínez Centeno (“Damaris 

Centeno”), in response to the Three Hundred Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 34 is a certified translation of the response [ECF No. 18171] 

(the “Rodríguez Fernández Response”), filed by claimant Aixa Edmee Rodríguez Fernández 

(“Rodríguez Fernández”), in response to the Three Hundred Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 35 is a certified translation of the response [ECF No. 18250] 

(the “Ruiz Response”), filed by claimant Ann M. Ruiz (“Ruiz”), in response to the Three Hundred 

Eighty-Second Omnibus Objection.

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Attached hereto as Exhibit 36 is a certified translation of the response [ECF No. 18262] 

(the “Velázquez Pierantoni Response”), filed by claimant Wilson Velázquez Pierantoni 

(“Velázquez Pierantoni”), in response to the Three Hundred Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 37 is a certified translation of the response [ECF No. 18265] 

(the “Santana Velázquez Response”), filed by claimant Amarilis Santana Velázquez (“Santana 

Velázquez”), in response to the Three Hundred Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 38 is a certified translation of the response [ECF No. 18309] 

(the “Ramos Pérez Response”) filed by claimant Millie Ramos Pérez(“Ramos Pérez”), in response 

to the Three Hundred Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 39 is a certified translation of the response [ECF No. 19344] 

(the “Cruz Roman Response”), filed by claimant Hilda Cruz Roman (“Cruz Roman”), in response 

to the Three Hundred Eighty-Second Omnibus Objection.

Attached hereto as Exhibit 40 is a certified translation of the response [ECF No. 19429] 

(the “López Camacho Response”), filed by Carmen López Camacho (“López Camacho”), in 

response to the Three Hundred Eighty-Third Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Employee Claims Asserting Liabilities Owed By Entities That 

Are Not Title III Debtors [ECF No. 17922] (the “Three Hundred Eighty-Third Omnibus 

Objection”).

Attached hereto as Exhibit 41 is a certified translation of the response [ECF No. 18553] 

(the “Maldonado Morales Response”), filed by claimant William Maldonado Morales 

(“Maldonado Morales”), in response to the Three Hundred Ninety-Third Omnibus Objection (NonSubstantive) of the Commonwealth of Puerto Rico and Employees Retirement System of the 

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Government of the Commonwealth of Puerto Rico to Late-Filed Claims [ECF No. 17975] (the 

“Three Hundred Ninety-Third Omnibus Objection”).

Attached hereto as Exhibit 42 is a certified translation of the response [ECF No. 18169] 

(the “Galán Kercadó Response”), filed by claimant Carlos E. Galán Kercadó (“Galán Kercadó”), 

in response to the Three Hundred Ninety-Third Omnibus Objection.

Attached hereto as Exhibit 43 is a certified translation of the response [ECF No. 18170] 

(the “Colón Cosme Response”), filed by claimant Janet Colón Cosme (“Colón Cosme”), in 

response to the Three Hundred Ninety-Third Omnibus Objection.

Attached hereto as Exhibit 44 is a certified translation of the response [ECF No. 19420] 

(the “Melendez Fraguada Response”), filed by claimant Eva E. Melendez Fraguada (“Melendez 

Fraguada”), to the Three Hundred Ninety-Fourth Omnibus Objection (Non-Substantive) of the 

Commonwealth of Puerto Rico and the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico to Employee Claims Asserting Liabilities Owed by Entities that are 

Not Title III Debtors [ECF No. 18958] (the “Three Hundred Ninety-Fourth Omnibus Objection”).

Attached hereto as Exhibit 45 is a certified translation of the response [ECF No. 19409] 

(the “Ramirez Montes Response”), filed by claimant Evelyn Ramirez Montes (“Ramirez Montes”), 

to the Three Hundred Ninety-Fifth Omnibus Objection (Non-Substantive) of the Commonwealth 

of Puerto Rico and the Employees Retirement System of the Government of the Commonwealth of 

Puerto Rico to Claims Asserting Duplicate Liabilities [ECF No. 18959] (the “Three Hundred 

Ninety-Fifth Omnibus Objection”).

Additional responses that were not filed on the docket, as well as certified translations 

thereof, are being submitted via notices of correspondence submitted contemporaneously 

herewith.

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Courtesy copies of these certified translations will also be submitted to chambers in the 

electronic hearing binders the Oversight Board intends to submit on or before February 15, 2022 

in compliance with the Adjourned Objection Hearing Procedures Order.

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

notice of the filing of these responses and certified translations in compliance with the Court’s 

orders.

[Remainder of Page Intentionally Left Blank]

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Dated: February 2, 2022

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

 ebarak@proskauer.com

 ppossinger@proskauer.com

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla Carcía-Benítez

USDC No. 203708

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Email: Hermann.bauer@oneillborges.com

Co-Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

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