Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

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 the 

Commonwealth.

ORDER GRANTING FIVE HUNDRED THIRTY-FIFTH

OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO 

TO CLAIMS ASSERTED BY EMPLOYEES OF THE PUERTO RICO POLICE 

DEPARTMENT FOR WHICH THE DEBTOR IS NOT LIABLE 

Upon the Five Hundred Thirty-Fifth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Claims Asserted by Employees of the Puerto Rico Police 

Department for which the Debtor Is Not Liable [ECF No. 22267] (the “Five Hundred Thirty-Fifth 

Omnibus Objection”),2 filed by the Commonwealth of Puerto Rico (the “Commonwealth” or the 

“Debtor”), dated September 16, 2022, for entry of an order disallowing in their entirety certain 

claims filed against the Debtor, as more fully set forth in the Five Hundred Thirty-Fifth Omnibus 

Objection and supporting exhibits thereto; and the Court having jurisdiction to consider the Five 

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

in the Five Hundred Thirty-Fifth Omnibus Objection.

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 2 of 8
2

Hundred Thirty-Fifth 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 Thirty-Fifth Omnibus Objection having been provided 

to those parties identified therein, and no other or further notice being required; and each of the 

claims identified in Exhibit A to the Five Hundred Thirty-Fifth Omnibus Objection (collectively, 

the “Claims to Be Disallowed”) having been found to be claims for which the Debtor is not liable 

because the liabilities asserted therein have already been satisfied and released; and the Court 

having determined that the relief sought in the Five Hundred Thirty-Fifth Omnibus Objection is in 

the best interests of the Commonwealth, its creditors, and all parties in interest; and the Court 

having determined that the legal and factual bases set forth in the Five Hundred Thirty-Fifth 

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

sufficient cause appearing therefor, it is hereby

ORDERED that the Five Hundred Thirty-Fifth 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 delete the Claims to Be 

Disallowed from the official claims registry in the Title III Cases; and it is further

ORDERED that this Order resolves Docket Entry No. 22267 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.

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 3 of 8
3

Dated: 

 Honorable Judge Laura Taylor Swain

 United States District Judge

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 4 of 8
EXHIBIT A 

Schedule of Claims Subject to the Five Hundred Thirty-Fifth Omnibus Objection 

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 5 of 8
Five Hundred Thirty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 ALVARADO TORRES, MIGUEL 05/18/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 14330

HC-02 BOX 10048

AIBONITO, PR 00705

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #14330 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 2 BAEZ FEBUS, ROBIN 05/17/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 14236

P.O. BOX 141

BARRANQUITAS, PR 00794

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #14236 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 3 COLLAZO NIEVES, JOSE A. 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 27268

P.O BOX 1739

ALBONITO, PR 00705

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #27268 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 4 COLON ALVARADO, JANICE 05/14/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 11226

URB. SAN ANTONIO

CALLE 9 H23

COAMO, PR 00769

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #11226 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 6 of 8
Five Hundred Thirty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 5 COLON BELEN, EDGARDO L. 06/27/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 55770

URB PASEO REAL

#31 CALLE VICTORIA

COAMO, PR 00769

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #55770 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 6 COLON RODRIGUEZ, RAMON E 05/17/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 13563

HC-02 BOX 7114

OROCOVIS, PR 00720

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #13563 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 7 COLON VEGA , LUIS A. 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 26222

CALLE JUAN SOTO #215

COMUNIDAD CARRASQUILLO

CAYEY, PR 00736

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #26222 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 8 CRUZ COLON, DANIEL 06/27/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 53446

HC1 BOX 4120

BARRANQUITAS, PR 00794

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #53446 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 7 of 8
Five Hundred Thirty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 9 ESPADA RIOS, NANCY I. 05/14/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 13348

P.O.BOX 850

AIBONOTO, PR 00705

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #13348 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 10 LORAN HERNANDEZ, CARMEN D. 06/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 33362

PO BOX 1684

OROCOVIS, PR 00720

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #33362 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

11 MIRANDA ZAYAS, NOEL 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 18930

NOEL MIRANDA ZAYAS

RR1 BOX 12001

OROCOVIS, PR 00720

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #18930 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

 12 TORRES RUIZ, JOSE A. 05/18/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 34684

606 SALAMANCA

URB.VILLA DEL CARMEN

PONCE, PR 00716

Undetermined*

Reason: Proof of Claim asserts liabilities associated with allegedly accrued, but unpaid, wages purportedly owed by the Puerto Rico Police Department. However, the Commonwealth’s 

records show that claimant has already received payment for the back pay and executed a release, and Debtors are therefore no longer liable for the claim because it has been settled and 

released. Claim #34684 also contained on Exhibit A to the 362nd Omnibus Claims Objection for Reclassified Claims.

TOTAL Undetermined*

*Indicates claim contains unliquidated and/or undetermined amounts 3

Case:17-03283-LTS Doc#:23376-1 Filed:01/25/23 Entered:01/25/23 19:36:51 Desc:

Proposed Order Page 8 of 8