Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23341-1 Filed:01/25/23 Entered:01/25/23 13:15:52 Desc:

Exhibit A Page 1 of 6
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)

This filing relates to ERS.

ORDER GRANTING FIVE HUNDRED ELEVENTH OMNIBUS OBJECTION 

(NON-SUBSTANTIVE) OF THE EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO TO CROSSDEBTOR DUPLICATE CLAIMS 

Upon the Five Hundred Eleventh Omnibus Objection (Non-Substantive) of the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico to CrossDebtor Duplicate Claims [ECF No. 22244] (“Five Hundred Eleventh Omnibus Objection”)2 filed 

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

(“ERS” or the “Debtor”), dated September 16, 2022, for entry of an order disallowing in their 

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); (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”, 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 Capitalized terms not otherwise defined herein shall have the meanings given to such terms in the 

Five Hundred Eleventh Omnibus Objection.

Case:17-03283-LTS Doc#:23341-1 Filed:01/25/23 Entered:01/25/23 13:15:52 Desc:

Exhibit A Page 2 of 6
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entirety certain claims filed against the Debtor, as more fully set forth in the Five Hundred Eleventh 

Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to consider 

the Five Hundred Eleventh Omnibus Objection and to grant the relief requested therein pursuant 

to PROMESA Section 306(a); and venue being proper pursuant to PROMESA Section 307(a); and 

due and proper notice of the Five Hundred Eleventh Omnibus Objection having been provided to 

those parties identified therein, and no other or further notice being required; and each of the claims 

filed against the Debtor identified in the column titled “Claims to Be Disallowed” in Exhibit A to 

the Five Hundred Eleventh Omnibus Objection (collectively, the “Claims to Be Disallowed”) 

being duplicative of claims asserted against the Puerto Rico Highways and Transportation 

Authority (“HTA”), for which the asserted liability would lie, if at all, against HTA, not the Debtor; 

and the Court having determined that the relief sought in the Five Hundred Eleventh Omnibus 

Objection is in the best interest of the Debtor and its creditors, and all the parties in interest; and 

the Court having determined that the legal and factual bases set forth in the Five Hundred Eleventh 

Omnibus Objection establish just cause for the relief granted herein; and after due deliberation and 

sufficient cause appearing therefor, it is hereby

ORDERED that the Five Hundred Eleventh Omnibus Objection is GRANTED as 

set forth herein; and it is further

ORDERED that the Claims to Be Disallowed are hereby disallowed in their 

entirety; and it is further

ORDERED that the Debtors’ right to object to the Remaining Claims on any 

grounds whatsoever is reserved; and it is further

ORDERED that Kroll is authorized and directed to designate as expunged the 

Claims to Be Disallowed from the official claims register in the Title III cases; and it is further

Case:17-03283-LTS Doc#:23341-1 Filed:01/25/23 Entered:01/25/23 13:15:52 Desc:

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ORDERED that this Order resolves Docket Entry No. 22244 in Case No. 17-3283; 

and it is further

ORDERED that this Court shall retain jurisdiction to hear and determine all matters 

arising from or related to the implementation, interpretation, or enforcement of this Order.

Dated: 

Honorable Judge Laura Taylor Swain

United States District Judge 

Case:17-03283-LTS Doc#:23341-1 Filed:01/25/23 Entered:01/25/23 13:15:52 Desc:

Exhibit A Page 4 of 6
EXHIBIT A

Schedule of Claims Subject to the Five Hundred Eleventh Omnibus Objection 

Case:17-03283-LTS Doc#:23341-1 Filed:01/25/23 Entered:01/25/23 13:15:52 Desc:

Exhibit A Page 5 of 6
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Five Hundred Eleventh Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 1 07/05/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

FELICIANO ROSADO, 151583 Undetermined*

JESUS

PERLA DEL SUR 4413 

PEDRO CARATINI

PONCE, PR 00717

FELICIANO ROSADO, 

JESUS

PERLA DEL SUR 4413 

PEDRO CARATINI

PONCE, PR 00717

07/05/18 17 BK 03567-LTS

Puerto Rico Highways and 

Transportation Authority

165443 Undetermined*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the Puerto 

Rico Highways and Transportation Authority.

Remaining claim #165443 contained on Exhibit A to the 510th Omnibus Claims Objection for Claims to Be Disallowed.

 2 07/03/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

ROMAN MARTINEZ, 105157 Undetermined*

NAYDA I.

205-11 SANTANA

ARECIBO, PR 00612

ROMAN MARTINEZ, 

NAYDE I

205-11 SANTANA

ARECIBO, PR 00612

07/03/18 17 BK 03567-LTS

Puerto Rico Highways and 

Transportation Authority

123182 Undetermined*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the Puerto 

Rico Highways and Transportation Authority.

 3 06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

TORRES, LESLIE M. 141650 Undetermined*

HC 1 BOX 12591

PENUELAS, PR 00624

TORRES, LESLIE M.

HC 1 BOX 12591

PENUELAS, PR 00624

06/29/18 17 BK 03567-LTS

Puerto Rico Highways and 

Transportation Authority

138393 Undetermined*

TORRES, LESLIE M.

HC 1 BOX 12591

PENUELAS, PR 00624

06/29/18 17 BK 03567-LTS

Puerto Rico Highways and 

Transportation Authority

138393-1 Undetermined*

Reason: Duplicate liability filed against Debtor Employees Retirement System of the Government of the Commonwealth of Puerto Rico. All asserted liabilities, if any would be between the Claimant and the Puerto 

Rico Highways and Transportation Authority.

Remaining claim #138393 contained on Exhibit A to the 380th Omnibus Claims Objection for Claims to Be Disallowed.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23341-1 Filed:01/25/23 Entered:01/25/23 13:15:52 Desc:

Exhibit A Page 6 of 6