Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23381-1 Filed:01/25/23 Entered:01/25/23 19:59:32 Desc:

Proposed Order 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 the 

Commonwealth.

ORDER GRANTING FIVE HUNDRED FORTY-SECOND OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO TO CLAIMS FOR 

WHICH THE COMMONWEALTH IS NOT LIABLE 

Upon the Five Hundred Forty-Second Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Claims for which the Commonwealth is Not Liable (the “Five 

Hundred Forty-Second Omnibus Objection”),2 filed by the Commonwealth of Puerto Rico (the 

“Commonwealth”), dated October 28, 2022, for entry of an order disallowing in their entirety 

certain claims filed against the Commonwealth, as more fully set forth in the Five Hundred FortySecond Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to 

consider the Five Hundred Forty-Second Omnibus Objection and to grant the relief requested 

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-BK5523-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 used but not defined herein shall have the meanings ascribed to them in 

the Five Hundred Forty-Second Omnibus Objection.

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2

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 Forty-Second Omnibus Objection 

having been provided to those parties identified therein, and no other or further notice being

required; and the claims identified in the column titled “Claims to be Disallowed” in Exhibit A to 

the Five Hundred Forty-Second Omnibus Objection (collectively, the “Claims to Be Disallowed”) 

having been found to be claims for which the Commonwealth is not liable; and the Court having 

determined that the relief sought in the Five Hundred Forty-Second Omnibus Objection is in the 

best interest of the Commonwealth, 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 Forty-Second Omnibus 

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

cause appearing therefor, it is

ORDERED that the Five Hundred Forty-Second 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 Kroll is authorized and directed to designate the Claims to Be 

Disallowed as expunged on the official claims registry in the Title III Cases; and it is further

ORDERED that this Order resolves Docket Entry No. 22746 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.

SO ORDERED.

Dated: 

___________________________________

Honorable Judge Laura Taylor Swain

United States District Judge

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EXHIBIT A 

Schedule of Claims Subject to the Five Hundred Forty-Second Omnibus Objection 

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Five Hundred Forty-Second Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 ALTAMENTE GS, LLC 04/26/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 7020

TU BUFETE LEGAL

ENID D. FLORES, ESQ.

METRO OFFICE PARK

7 CALLE 1 SUITE 204

GUAYNABO, PR 00969

$18,270.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 2 ARENAS BUS LINE, INC. 06/28/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 54296

RR 01 BOX 3405

CIDRA, PR 00739

$355,702.12

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 3 C E & L FIRE EXTINGUISHERS 05/07/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 11889

PO BOX 3092

BAYAMON, PR 00960

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 4 CARIBBEAN ASSET MANAGEMENT & FUNDING 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 27906

INTIMA, INC.

ANGEL L. ACEVEDO ESQ.

URB PASEO ALTO

68 CALLE 2

SAN JUAN, PR 00926-5918

$45,395.30

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $20,310.12 in the agency's system.

Claim #27906 also contained on Exhibit A to the 372nd Omnibus Claims Objection for Claims to Be Modified.

*Indicates claim contains unliquidated and/or undetermined amounts 1

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Five Hundred Forty-Second Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 5 COMMUNICATION LEASING LEASING 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 29416

CORPORATION

ANA ALBERTORIO

PO BOX 362526

SAN JUAN, PR 00936-2565

$23,445.51

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 6 HR BUS LINE INC. 06/07/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 49442

PO BOX 1958

LAS PIEDRAS, PR 00771

$96,326.87

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 7 INTELUTIONS, INC. 05/02/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 9295

PMB 367

35 CALLE JUAN BORBON

SUITE 67

GUAYNABO, PR 00969

$98,858.50

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice totaling $32,940.00 in the agency's system. Additionally proof of claim purports to assert liabilities associated with the 

Commonwealth of Puerto Rico, but liabilities totaling $65,918.50 fail to provide sufficient supporting documentation for asserting the liabilities against the Commonwealth of Puerto 

Rico, such that the Debtors are unable to determine whether claimant has valid liabilities against the Commonwealth of Puerto Rico or any of the other Title III debtors.

 8 MARQUEZ CRUZ, JORGE 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 35307

PMB 131

CALLE SIERRA MORENA 267

SAN JUAN, PR 00926

$362,532.42

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

TOTAL $1,000,530.72*

*Indicates claim contains unliquidated and/or undetermined amounts 2

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