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 and HTA.

REPLY OF THE COMMONWEALTH OF PUERTO RICO TO RESPONSE 

[ECF NO. 23299] TO THE FIVE HUNDRED TWENTY-SECOND OMNIBUS 

OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO AND 

THE PUERTO RICO HIGHWAYS AND TRANSPORTATION AUTHORITY TO 

UNLIQUIDATED CLAIMS 

To the Honorable United States District Judge Laura Taylor Swain: 

 The Commonwealth of Puerto Rico (the “Commonwealth”) and the Puerto Rico Highways 

and Transportation Authority (“HTA,” and together with the Commonwealth, the “Debtors”), by 

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 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-BK3283-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). 

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and through 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 file this reply (the 

“Reply”) to the response [ECF No. 23299] (the “Response”) filed by claimant Luz Esther Rivera 

Cuevas (“Rivera Cuevas”) to the Five Hundred Twenty-Second Omnibus Objection (Substantive) 

of the Commonwealth of Puerto Rico and the Puerto Rico Highways and Transportation Authority 

to Unliquidated Claims [ECF No. 22257] (the “Five Hundred Twenty-Second Omnibus 

Objection”). In support of this Reply, the Debtors respectfully represent as follows: 

1. On September 16, 2022, the Commonwealth and HTA filed the Five Hundred 

Twenty-Second Omnibus Objection seeking to liquidate and allow claims asserting unliquidated 

amounts, each as set forth on Exhibit A thereto, based on supporting documentation received from 

the relevant claimant and/or the Puerto Rico Fiscal Agency and Financial Advisory Authority 

establishing the appropriate allowable amount for each claim. 

2. Any party who disputed the Five Hundred Twenty-Second Omnibus Objection was 

required to file a response by 4:00 p.m. (Atlantic Standard Time) on October 17, 2022 in 

accordance with the Court-approved notice attached to the Five Hundred Twenty-Second Omnibus 

Objection as Exhibit C, which was served in English and Spanish on the individual creditors subject 

to the Five Hundred Twenty-Second Omnibus Objection, the U.S. Trustee, and the Master Service 

List (as defined in the Sixteenth Amended Notice, Case Management and Administrative 

Procedures [ECF No. 20190-1]). See Certificate of Service [ECF No. 22563]. 

2

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

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3. Rivera Cuevas filed the Response on January 20, 2023. The Response consists 

solely of an excerpt of Exhibit A to the Five Hundred Twenty-Second Omnibus Objection, which 

identifies the proof of claim filed by the Claimant against the Commonwealth as Proof of Claim 

No. 14673 (the “Claim”) as a claim to be liquidated and allowed in the amount of $230.40. On 

this excerpt, Claimant has written the question “whether I can still receive the money from the 

Promesa Act.” See Response. 

4. Accordingly, the Response does not oppose the Debtors’ proposed liquidated 

amount of the Claim or otherwise object to the Five Hundred Twenty-Second Omnibus Objection. 

Rather, it appears to simply be inquiring as to the status of distributions on account of the Claim. 

In the event the Five Hundred Twenty-Second Omnibus Objection is granted and the Claim is 

liquidated and allowed, Rivera Cuevas will receive distributions pursuant to the terms of the 

Modified Eighth Amended Title III Plan of Adjustment of the Commonwealth of Puerto Rico, et al.

[ECF No. 19784]. 

5. For the foregoing reasons, the Debtors respectfully request that the Court grant the 

Five Hundred Twenty-Second Omnibus Objection, notwithstanding the Response. 

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Dated: April 11, 2023 

San Juan, Puerto Rico 

Respectfully submitted, 

/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 Ave. Hostos

San Juan, PR 00918

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

Fax: (787) 763-8260

/s/ Martin J. Bienenstock

Martin J. Bienenstock (pro hac vice) 

Brian S. Rosen (pro hac vice) 

PROSKAUER ROSE LLP 

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

Attorneys for the Financial 

Oversight and Management Board for 

Puerto Rico, as representative of the 

Commonwealth of Puerto Rico and the 

Puerto Rico Highways and 

Transportation Authority

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