Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 1 of 8
1

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 ERS.

ORDER GRANTING FOUR HUNDRED NINETIETH

OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH 

OF PUERTO RICO AND THE EMPLOYEES RETIREMENT SYSTEM OF THE 

GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO TO NO LIABILITY 

CLAIMS FILED BY AEELA MEMBERS

Upon the Four Hundred Ninetieth Omnibus Objection (Substantive) of the 

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

Commonwealth of Puerto Rico to No Liability Claims Filed by AEELA Members [ECF No. 21740]

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)

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 2 of 8
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(“Four Hundred Ninetieth Omnibus Objection”)2 filed by the Commonwealth of Puerto Rico (the 

“Commonwealth”) and the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico (“ERS,” and together with the Commonwealth, the “Debtors”), 

dated August 5, 2022, for entry of an order disallowing in their entirety certain claims filed against 

the Debtors, as more fully set forth in the Four Hundred Ninetieth Omnibus Objection and 

supporting exhibits thereto; and the Court having jurisdiction to consider the Four Hundred 

Ninetieth 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 Four Hundred Ninetieth 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 Four Hundred Ninetieth Omnibus 

Objection (collectively, the “Claims to Be Disallowed”) asserting claims for which the Debtors 

are not liable; and the Court having determined that the relief sought in the Four Hundred Ninetieth 

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 Four 

Hundred Ninetieth Omnibus Objection establish just cause for the relief granted herein; and after 

due deliberation and sufficient cause appearing therefor, it is

ORDERED that the Four Hundred Ninetieth 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

2 Capitalized terms not otherwise defined herein shall have the meanings given to such terms 

in the Four Hundred Ninetieth Omnibus Objection.

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 3 of 8
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ORDERED that Kroll is authorized and directed to designate the Claims to Be 

Disallowed as expunged on the official claims register in the Title III Case; and it is further

ORDERED that this Order resolves Docket Entry No. 21740 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#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 4 of 8
EXHIBIT A

Schedule of Claims Subject to the Four Hundred Ninetieth Omnibus Objection 

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 5 of 8
Four Hundred Ninetieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

03/30/2018 17 BK 03566-LTS Employees Retirement System 5673-1

of the Government of the 

Commonwealth of Puerto Rico

 1 BELTRAN RODRIGUEZ, MILAGROS

HC 71 BOX 2704

NARANJITO, PR 00719

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Employees Retirement System of the Government of the Commonwealth of Puerto Rico. Proof of Claim and 

supporting documentation only show liability between Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim 

has been transferred into the Administrative Claims Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute 

an objection to the portion of the claim in the ACR process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

 2 CAER FERMAINT, ROSA MARIA 07/06/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 107380-2

P.O. BOX 143256

ARECIBO, PR 00614

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings.

 3 CASTILLO LOPEZ, SYLVIA 06/26/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 104956-1

1213 CALLE BAMBLE LOS CAOBOS

PONCE, PR 00716

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

 4 FARGAS LLANOS, NANCY 06/01/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 65397-1

PO BOX 1077

SAINT JUST, PR 00978

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 6 of 8
Four Hundred Ninetieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

03/19/2018 17 BK 03566-LTS Employees Retirement System 3446-1

of the Government of the 

Commonwealth of Puerto Rico

 5 GARCIA BELTRAN, LUIS A

BARRIO LOMAS GARCIA

HC 71 BOX 2704

CARR 165 KM 2.2

NARANJITO, PR 00719

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Employees Retirement System of the Government of the Commonwealth of Puerto Rico. Proof of Claim and 

supporting documentation only show liability between Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim 

has been transferred into the Administrative Claims Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute 

an objection to the portion of the claim in the ACR process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

 6 GARCIA SANTIAGO, ANGEL 03/19/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 3265-1

BO LOMAS CENTRO

HC 71 BOX 2704

NARANJITO, PR 00719

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

 7 GARCIA SANTIAGO, ANGEL L 03/30/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 5679-1

HC 71 BOX 2704

BO. LOMAS GARCIA

NARANJITO, PR 00719

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 7 of 8
Four Hundred Ninetieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 8 GARCIA SANTIAGO, ANGEL L 04/03/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 6047-1

HC 71 BOX 2704

BO. LOMAS GARCIA

NARANJITO, PR 00719

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

 9 MELENDEZ RIVERA, CARMEN D. 06/03/2021 17 BK 03283-LTS Commonwealth of Puerto Rico 179297-2

VANESSA HERNANDEZ RODRIGUEZ, ESQ

4140 AURORA STREET SUITE 1

PONCE, PR 00717-1203

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

 10 TORRES ROMAN, LOUIS I 05/18/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 79920-2

HC-03 BOX 17775

LAJAS, PR 00667

Undetermined*

Reason: Proof of Claim fails to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability between 

Claimant and Asociacion de Empleados Del ELA (AEELA), which is not part of the Title III proceedings. A portion of this claim has been transferred into the Administrative Claims 

Reconciliation (ACR) process and will be resolved consistent with the ACR procedures. Because this objection does not constitute an objection to the portion of the claim in the ACR 

process, the Debtors’ reserve their rights to object to the remaining portion of the claim on any other grounds whatsoever.

TOTAL Undetermined*

*Indicates claim contains unliquidated and/or undetermined amounts 3

Case:17-03283-LTS Doc#:23333-1 Filed:01/25/23 Entered:01/25/23 12:45:23 Desc:

Exhibit A Page 8 of 8