Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23355-1 Filed:01/25/23 Entered:01/25/23 16:45:38 Desc:

Exhibit Proposed Order Page 1 of 10
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 FOUR HUNDRED NINETY-SIXTH OMNIBUS 

OBJECTION (NON-SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO TO 

PARTIALLY SATISFIED AND PARTIALLY NO LIABILITY CLAIMS

Upon the Four Hundred Ninety-Sixth Omnibus Objection (Non-Substantive) of the 

Commonwealth of Puerto Rico to Partially Satisfied and Partially No Liability Claims [ECF No. 

21749] (the “Four Hundred Ninety-Sixth Omnibus Objection”)2 of the Commonwealth of Puerto 

Rico (the “Commonwealth” or the “Debtor”), dated August 5, 2022, for entry of an order 

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)

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

in the Four Hundred Ninety-Sixth Omnibus Objection.

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disallowing in their entirety certain claims filed against the Debtor, as more fully set forth in the 

Four Hundred Ninety-Sixth Omnibus Objection and supporting exhibits thereto; and the Court 

having jurisdiction to consider the Four Hundred Ninety-Sixth 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 NinetySixth Omnibus Objection having been provided to those parties identified therein, and no other or 

further notice being required; and the Court having determined that the claims identified in the 

column titled “Asserted” in Exhibit A to the Four Hundred Ninety-Sixth Omnibus Objection 

(collectively, the “Partially Satisfied and Partially No Liability Claims”) have been satisfied in part 

and assert, in part, liabilities that failed to comply with the applicable rules for filing a proof of 

claim; and the Court having determined that the relief sought in the Four Hundred Ninety-Sixth 

Omnibus Objection is in the best interest of the Debtor, its creditors, and all the parties in interest; 

and the Court having determined that the legal and factual bases set forth in the Four Hundred 

Ninety-Sixth 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 Ninety-Sixth Omnibus Objection is GRANTED 

as set forth herein; and it is further

ORDERED that the Partially Satisfied and Partially No Liability Claims are hereby 

reduced and disallowed, such that the Partially Satisfied and Partially No Liability Claims shall 

now only be considered claims asserting the amount set forth in the column titled “Remaining 

Claim” in Exhibit A to the Four Hundred Ninety-Sixth Omnibus Objection, respectively; and it is 

further

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ORDERED that the Debtors’ rights to object the remaining portions of these claims, 

as set forth in the column titled “Remaining Claim” in Exhibit A to the Four Hundred Ninety-Sixth 

Omnibus Objection, is reserved; and it is further

ORDERED that Kroll is authorized and directed to designate as expunged and 

reduce the amount asserted in the Partially Satisfied and Partially No Liability Claims by the 

disallowed portions (i.e., reducing the amount of the claims to the amounts set forth in the column 

titled “Remaining Claim” in Exhibit A to the Four Hundred Ninety-Sixth Omnibus Objection)

from the official claims register in the Title III Case; and it is further

ORDERED that this Order resolves Docket Entry No. 21749 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: 

Honorable Judge Laura Taylor Swain

United States District Judge 

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EXHIBIT A

Schedule of Claims Subject to the Four Hundred Ninety-Sixth Omnibus Objection 

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PRIORITY 

STATUS

Four Hundred Ninety-Sixth Omnibus Objection

Exhibit A - Modified Claims

ASSERTED MODIFIED

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 1 AKM MFG INC. 44619 Commonwealth of Puerto Rico Unsecured $41,061.62* Commonwealth of Puerto Rico Unsecured $8,790.03*

418 CALLE ASTE 1

SAN JUAN, PR 00920-2005

Reason: Proof of claim purports to assert liabilities associated with the Commonwealth of Puerto Rico, but liabilities totaling $32,271.59 fail to provide sufficient supporting 

documentation for asserting the liabilities against the Commonwealth of Puerto Rico, such that the Debtors are unable to determine whether claimant has valid liabilities against the 

Commonwealth of Puerto Rico or any of the other Title III debtors. The Claimant shall retain the non-modified portion of the claim. Additionally, Claim was filed as partially 

unliquidated, modified amount fully liquidates the Claim.

 2 BPA OFFICE SUPPLIES INC 25556 Commonwealth of Puerto Rico Unsecured $302,042.54 Commonwealth of Puerto Rico Unsecured $240,131.43

PO BOX 10611

PONCE, PR 00732

Reason: Invoices totaling $61,911.11 were paid via ACH/checks 00113418, 00116939, 00116940, 00116941, 00116942, 00116943, 00116944, 00116945, 00116946, 00116947, 

00116948, 00121027, 00121903, 00123067, 00124076, 00128810, 00129709, 00147400, 00150275, 00150902, 00151282, 00154403, 00202796, 00007604, and 00253854 on 

04/19/2017, 05/01/2017, 05/16/2017, 05/18/2017, 05/31/2017, 06/05/2017, 06/20/2017, 06/28/2017, 07/18/2017, 08/10/2017, 08/24/2017, 08/30/2017, 11/13/2017, 09/12/2018, 

09/14/2018, and 10/01/2019. The Claimant shall retain the non-modified portion of the claim.

 3 C E & L FIRE 11882 Commonwealth of Puerto Rico Unsecured Undetermined* Commonwealth of Puerto Rico Unsecured $54.60*

EXTINGUISHERS

PO BOX 3092

BAYAMON, PR 00960

Reason: Claim does not assert a stated value, however the support provided in the POC totals $1,596.00 of which the Debtors show all but $54.60 was paid on 05/29/2018 via checks 

00212714, 00212715, 00212716, 00212717, 00212718, 00212719, and 00212720. The Claimant shall retain the non-modified portion of the claim. Additionally, Claim was filed as 

partially unliquidated, modified amount fully liquidates the Claim.

 4 CAMERA MUNDI INC 168163 Commonwealth of Puerto Rico Unsecured $1,738,496.35 Commonwealth of Puerto Rico Unsecured $1,638,612.96

PO BOX 6840

CAGUAS, PR 00726-6840

Reason: Invoices totaling $99,883.39 were paid via ACHs/checks 00237726, 00230957, 00460881, 00241166, 00484947, 00482887, 00007954, 00010826, 00122751, 00120387, 

00521136, 00529651, 00524391, 00012293, 00107201, 00583320, 00537986, 00052271, 00666018, 00426667, 00648387, 00202218, 00011059, 00046303, 00126745, 00116882, 

00117607, 00117614, 00361175, 00001118, 00173947, 00002641, 00442995, 00202721, 00010316, 00451242, 00514221, 00497756, 00009870, 00011930, 00258365, 00638341, 

00026646, 00076762, 00070627, and 00360705 between 2007 and 2019. The Claimant shall retain the non-modified portion of the claim.

*Indicates claim contains unliquidated and/or undetermined amounts 1

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PRIORITY 

STATUS

Four Hundred Ninety-Sixth Omnibus Objection

Exhibit A - Modified Claims

ASSERTED MODIFIED

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 5 CONSOLIDATED WASTE 27647 Commonwealth of Puerto Rico Unsecured $1,033.10 Commonwealth of Puerto Rico Unsecured $883.10

SERVICES

PO BOX 1322

GURABO, PR 00778

Reason: Invoices totaling $150.00 were paid via checks 00046891 and 00046893 on 07/30/2018. The Claimant shall retain the non-modified portion of the claim.

 6 CONSOLIDATED WASTE 28070 Commonwealth of Puerto Rico Unsecured $1,678.11 Commonwealth of Puerto Rico Unsecured $1,223.11

SERVICES

PO BOX 1322

GURABO, PR 00778

Reason: Invoices totaling $455.00 were paid via EFTs 70087, 74410, 78384, 79813, and 79814 on 03/27/2018, 04/23/2018, 05/16/2018, and 05/23/2018. The Claimant shall retain the 

non-modified portion of the claim.

 7 CONSOLIDATED WASTE 28096 Commonwealth of Puerto Rico Unsecured $15,881.26 Commonwealth of Puerto Rico Unsecured $14,658.91

SERVICES

PO BOX 1322

GURABO, PR 00778

Reason: Invoices totaling $1,222.35 were paid via checks 00040185, 00040186, 00040187, 00040188, 00041215, and 00042896 on 04/18/2018, 04/30/2018, and 05/31/2018. The 

Claimant shall retain the non-modified portion of the claim.

 8 CONSOLIDATED WASTE 28103 Commonwealth of Puerto Rico Unsecured $3,838.13 Commonwealth of Puerto Rico Unsecured $2,515.00

SERVICES

P.O. BOX 1322

GURABO, PR 00778

Reason: Invoices totaling $1,323.13 were paid via EFTs 00080103, 00080272, 00080273, 00080274, 00080275, 00080276, and 00080277 on 05/23/2018. The Claimant shall retain 

the non-modified portion of the claim.

*Indicates claim contains unliquidated and/or undetermined amounts 2

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PRIORITY 

STATUS

Four Hundred Ninety-Sixth Omnibus Objection

Exhibit A - Modified Claims

ASSERTED MODIFIED

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 9 CONSOLIDATED WASTE 28115 Commonwealth of Puerto Rico Unsecured $2,332.70 Commonwealth of Puerto Rico Unsecured $1,152.72

SERVICES

PO BOX 1322

GURABO, PR 00778

Reason: Invoices totaling $1,179.98 were paid via EFTs 39993, 42906, 46896, 49511, 52302, 56951, 59283, 59286, 64074, 68802, 69793, 69994, 71734, 72055, 72057, 74695, 87142, 

87143, 87144, 87145, 87146, and 98175 on 03/26/2018, 06/20/2017, 07/10/2017, 08/02/2017, 08/24/2017, 10/ 11/2017, 12/07/2017, 12/27/2017, 02/07/2018, 03/19/2018, 03/26/2018, 

04/09/2018, 04/24/2018, 06/27/2018, and 09/06/2018. The Claimant shall retain the non-modified portion of the claim.

 10 GARCIA DAVILA, 138933 Commonwealth of Puerto Rico Unsecured $2,462.50 Commonwealth of Puerto Rico Unsecured $1,150.00

HUMBERTO

PO BOX 361716

SAN JUAN, PR 00936

Reason: Invoices totaling $1,312.50 were paid via checks 188738 and 222990 on 01/25/2018 and 07/05/2018. The Claimant shall retain the non-modified portion of the claim.

11 GERMAN TORRES 48747 Commonwealth of Puerto Rico 503(b)(9) $15,178.00 Commonwealth of Puerto Rico Unsecured $3,900.00

BERRIOS & ASSOCIADOS

HC 04 BOX 5775

BARRANQUITAS, PR 

00794-9609

Reason: Invoices totaling $11,278.00 were paid via EFTs 11100112, 11100044, 11100064, and 11100152 on 07/18/2016, 02/28/2017, 04/20/2017, and 09/19/2017. The Claimant shall 

retain the non-modified portion of the claim.

 12 GONZALEZ DIAZ, WILLIAN 3077 Commonwealth of Puerto Rico Unsecured $21,600.00* Commonwealth of Puerto Rico Unsecured $8,100.00*

PO BOX 534

SALINAS, PR 00751

Reason: Proof of claim purports to assert liabilities associated with the Commonwealth of Puerto Rico, but liabilities totaling $13,500.00 fail to provide sufficient supporting 

documentation for asserting the liabilities against the Commonwealth of Puerto Rico, such that the Debtors are unable to determine whether claimant has valid liabilities against the 

Commonwealth of Puerto Rico or any of the other Title III debtors. The Claimant shall retain the non-modified portion of the claim. Additionally, Claim was filed as partially 

unliquidated, modified amount fully liquidates the Claim.

*Indicates claim contains unliquidated and/or undetermined amounts 3

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PRIORITY 

STATUS

Four Hundred Ninety-Sixth Omnibus Objection

Exhibit A - Modified Claims

ASSERTED MODIFIED

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 13 LIBERTY CABLEVISION OF 17316 Commonwealth of Puerto Rico Unsecured $1,767.37 Commonwealth of Puerto Rico Unsecured $535.90

PUERTO RICO LLC

C/O ORLANDO 

FERNANDEZ, ESQ.

#27 CALLE GONZALEZ 

GIUSTI STE 300

GUAYNABO, PR 00968-3076

Reason: Invoice totaling $1,231.47 was paid via EFT 33640 on 05/17/2017. The Claimant shall retain the non-modified portion of the claim.

 14 PONCE MEDICAL SCHOOL 19257 Commonwealth of Puerto Rico Unsecured $9,182.76 Commonwealth of Puerto Rico Unsecured $98.44

FOUNDATION INC

PO BOX 7004

PONCE, PR 00732-7004

Reason: Invoices totaling $4,145.67 were paid via checks 51477, 51479, 112412, 116436, 120162, and 124103 on 06/20/2017, 02/21/2019, 03/21/2019, 04/30/2019, and 05/30/2019. 

For liabilities totaling $4,938.65, the claimant 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 University of Puerto Rico which is not part of the Title III proceedings. The Claimant shall retain the non-modified portion of the claim.

 15 QUEST DIAGNOSTICS OF 94933 Commonwealth of Puerto Rico Unsecured $2,349.14 Commonwealth of Puerto Rico Unsecured $706.87

PUERTO RICO, INC.

CAPARRA GALLERY 

CALLE ORTEGON #107

LOCAL 105

GUAYNABO, PR 00966

Reason: Invoices totaling $1,642.27 were paid via checks 75978, 75979, 75980, 75987, 82274, 96372, 96374, and 96382 on 03/26/2018, 05/18/2018, and 09/18/2018. The Claimant 

shall retain the non-modified portion of the claim.

*Indicates claim contains unliquidated and/or undetermined amounts 4

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PRIORITY 

STATUS

Four Hundred Ninety-Sixth Omnibus Objection

Exhibit A - Modified Claims

ASSERTED MODIFIED

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 16 RIVERA SIACA, LUIS A. 48953 Commonwealth of Puerto Rico Unsecured $483,109.37 Commonwealth of Puerto Rico Unsecured $55,531.24

CHARLES A CUPRILL P.S.C. 

LAW OFFICES

356 FORALEZA STREET 2 

FLOOR

SAN JUAN, PR 00901

Reason: Invoices totaling $427,578.13 were paid via ACHs/checks 00033392, 00259654, 00035704, 00261257, and 00036001 on 12/23/2019, 02/06/2020, and 02/10/2020. The 

Claimant shall retain the non-modified portion of the claim.

 17 SUR MED MEDICAL 41863 Commonwealth of Puerto Rico Unsecured $97,016.06 Commonwealth of Puerto Rico Unsecured $6,573.00

CENTER CORP

PO BOX 1162

8 CALLE COLON PACHECO

SALINAS, PR 00751

Reason: Invoices totaling $90,443.06 were paid via EFTs 00096628, 00096660, 00096661, 00096662, 00096663, 00096664, 00096665, and 00096666 on 08/29/2018. The Claimant 

shall retain the non-modified portion of the claim.

 18 YABUCOA DEVELOPMENT, 25519 Commonwealth of Puerto Rico Unsecured $74,097.42 Commonwealth of Puerto Rico Unsecured $47,945.49

S.E

PO BOX 190858

SAN JUAN, PR 00919-0858

Reason: Invoices totaling $26,151.93 were paid via EFT 00095237 on 09/14/2018. The Claimant shall retain the non-modified portion of the claim.

*Indicates claim contains unliquidated and/or undetermined amounts 5

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