Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23357-1 Filed:01/25/23 Entered:01/25/23 16:54:20 Desc:

Exhibit A Proposed Order Page 1 of 8
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 HTA and 

PBA.

ORDER GRANTING FIVE HUNDRED FIFTEENTH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE PUERTO RICO HIGHWAYS AND TRANSPORTATION 

AUTHORITY AND THE PUERTO RICO PUBLIC BUILDINGS AUTHORITY TO CLAIMS 

FOR WHICH THE DEBTORS ARE NOT LIABLE

Upon the Five Hundred Fifteenth Omnibus Objection (Substantive) of the Puerto 

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

Claims for Which the Debtors are Not Liable [ECF No. 22252] (the “Five Hundred Fifteenth 

Omnibus Objection”),2 filed by the Puerto Rico Highways and Transportation Authority (“HTA”) 

and the Puerto Rico Public Buildings Authority (“PBA,” and together with HTA, the “Debtors”), 

dated September 16, 2022, for entry of an order disallowing in their entirety certain claims filed 

against the Debtors, as more fully set forth in the Five Hundred Fifteenth Omnibus Objection 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 (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 Fifteenth Omnibus Objection.

Case:17-03283-LTS Doc#:23357-1 Filed:01/25/23 Entered:01/25/23 16:54:20 Desc:

Exhibit A Proposed Order Page 2 of 8
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supporting exhibits thereto; and the Court having jurisdiction to consider the Five Hundred 

Fifteenth 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 Fifteenth 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 Fifteenth Omnibus 

Objection (collectively, the “Claims to Be Disallowed”) having been found to be claims for which 

HTA and/or PBA are not liable; and the Court having determined that the relief sought in the Five 

Hundred Fifteenth Omnibus Objection is in the best interest of the Debtors, their creditors, and all 

the parties in interest; and the Court having determined that the legal and factual bases set forth in 

the Five Hundred Fifteenth 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 Fifteenth 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. 22252 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: 

Case:17-03283-LTS Doc#:23357-1 Filed:01/25/23 Entered:01/25/23 16:54:20 Desc:

Exhibit A Proposed Order Page 3 of 8
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Honorable Judge Laura Taylor Swain

United States District Judge

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EXHIBIT A 

Schedule of Claims Subject to the Five Hundred Fifteenth Omnibus Objection 

Case:17-03283-LTS Doc#:23357-1 Filed:01/25/23 Entered:01/25/23 16:54:20 Desc:

Exhibit A Proposed Order Page 5 of 8
Five Hundred Fifteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

06/29/2018 17 BK 03567-LTS Puerto Rico Highways and 116844

Transportation Authority

 1 BUFETE ENRIQUE UMPIERRE SUAREZ C.S.P.

ENRIQUE UMPIERRE SUAREZ

PO BOX 365003

SAN JUAN, PR 00936-5003

$94,028.69

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with these invoices in HTA's system.

06/01/2020 19-BK-05523-LTS Puerto Rico Public Buildings 174090

Authority (PBA)

 2 CARIBBEAN DATA SYSTEM

636 SAN PATRICIO AVE.

SAN JUAN, PR 00920

$30,805.76

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of PBA's books and records, there are no 

outstanding liabilities associated with this invoice in PBA's system.

05/22/2018 17 BK 03567-LTS Puerto Rico Highways and 24252

Transportation Authority

 3 CONSOLIDATED WASTE SERVICES

PO BOX 1322

GURABO, PR 00778

$5,407.32

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with these invoices in HTA's system.

05/29/2018 17 BK 03567-LTS Puerto Rico Highways and 38195

Transportation Authority

 4 CORPORACION RODUM

PO BOX 9023422

SAN JUAN, PR 00902-3422

$3,989.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with these invoices in HTA's system.

05/23/2018 17 BK 03567-LTS Puerto Rico Highways and 23753

Transportation Authority

 5 EQUIPOS Y CONSTRUCTORA RVD INC

PO BOX 79176

CAROLINA, PR 00984-9176

$3,981.20

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

1

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Exhibit A Proposed Order Page 6 of 8
Five Hundred Fifteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

05/03/2018 17 BK 03567-LTS Puerto Rico Highways and 10524

Transportation Authority

 6 EQUIPOS Y CONSTRUCTORA RVD, INC

PO BOX 79176

CAROLINA, PR 00984-9176

$83,870.40

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

05/02/2018 17 BK 03567-LTS Puerto Rico Highways and 9860

Transportation Authority

 7 FLORES LABAULT, CARLOS M.

DBA CEL FIRE EXTINGUISHERS

PO BOX 3092

BAYAMON, PR 00960

$72.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

05/29/2018 17 BK 03567-LTS Puerto Rico Highways and 53677

Transportation Authority

 8 LCDO RAMON A RODRIGUEZ

COND EL CENTRO I SUITE 3A

500 AVE MUNOZ RIVERA

HATO REY, PR 00969

$3,675.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with these invoices in HTA's system.

05/29/2018 17 BK 03567-LTS Puerto Rico Highways and 40776

Transportation Authority

 9 PEREZ GUTIE, LCDO EDGARDO

9140 CALLE MARINA

CONDOMINIO PONCIONA OFIC 401

PONCE, PR 00731

$600.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

2

Case:17-03283-LTS Doc#:23357-1 Filed:01/25/23 Entered:01/25/23 16:54:20 Desc:

Exhibit A Proposed Order Page 7 of 8
Five Hundred Fifteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

04/12/2018 17 BK 03567-LTS Puerto Rico Highways and 7174

Transportation Authority

 10 PFM ASSET MANAGEMENT LLC

PO BOX 62923

BALTIMORE, MD 21264-2923

$90,000.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

05/29/2018 17 BK 03567-LTS Puerto Rico Highways and 43293

Transportation Authority

11 RAFAEL J NIDO INC

PO BOX 11978

SAN JUAN, PR 00922-1978

$32,961.12

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

05/24/2018 17 BK 03567-LTS Puerto Rico Highways and 18565

Transportation Authority

 12 SKYTEC INC

500 ROAD 869, SUITE 501

CATAÑO, PR 00962-2011

$7,695.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with these invoices in HTA's system.

05/09/2018 17 BK 03567-LTS Puerto Rico Highways and 13449

Transportation Authority

 13 SM ELECTRICAL CONTRACTO

AVE SAN CRISTOBAL 3006

COTTO LAUREL

PONCE, PR 00731

$18,925.96

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of HTA's books and records, there are no 

outstanding liabilities associated with this invoice in HTA's system.

TOTAL $376,011.45

3

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Exhibit A Proposed Order Page 8 of 8