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)

NOTICE OF WITHDRAWAL OF CERTAIN CLAIMS SUBJECT TO OMNIBUS 

OBJECTIONS OF THE COMMONWEALTH OF PUERTO RICO

To The Honorable United States District Judge Laura Taylor Swain:

1. On August 5, 2022, the Commonwealth of Puerto Rico (the “Commonwealth,” or 

the “Debtor”) by and through the Financial Oversight and Management Board for Puerto Rico (the 

“Oversight Board”), as the sole Title III representative of the Commonwealth pursuant to section 

315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”),2

filed various omnibus objections.

 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 (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”) (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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2. In light of additional information received since such filings, the Commonwealth

respectfully withdraws, without prejudice, its objections to the following proofs of claim 

(collectively, the “Withdrawn Claims”):

• Five Hundred Second Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21759], solely with respect to 

Claim Nos. 139994, 89128, and 126706;

• Five Hundred Third Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21751], solely with respect to 

Claim No. 4256;

• Five Hundred Fifth Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21761], solely with respect to 

Claim Nos. 126785, 166251 and 97833; and

• Five Hundred Seventh Omnibus Objection (Substantive) of the Commonwealth of 

Puerto Rico to Unresponsive ACR Claims [ECF No. 21763], solely with respect to 

Claim No. 113418.

3. The Commonwealth reserves all rights with respect to the Withdrawn Claims, 

individually and collectively, including to object to the Withdrawn Claims on any grounds 

whatsoever.

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Dated: January 27, 2023 Respectfully submitted,

San Juan, Puerto Rico

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla García Benítez

USDC No. 203708

Gabriel A. Miranda-Rivera

USDC No. 306704

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico 

/s/ Brian S. Rosen

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

Co-Attorneys for the Financial Oversight 

and Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico 

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