UNITED STATES DISTRICT COURT 

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.,

Debtor.1

PROMESA Title III

Case No. 17 BK 3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY 

(“PREPA”),

Debtor.

PROMESA Title III

Case No. 17 BK 4780-LTS

SEVENTH INFORMATIVE MOTION OF THE FINANCIAL 

OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO 

RICO WITH RESPECT TO RESOLUTION OF PROOFS OF CLAIM

PURSUANT TO ALTERNATIVE DISPUTE RESOLUTION PROCEDURES

 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); 

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).

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To the Honorable United States District Judge Laura Taylor Swain:

The Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), 

as the sole Title III representative of the Commonwealth of Puerto Rico (the “Commonwealth”), 

the Puerto Rico Highways and Transportation Authority (“HTA”), the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico (“ERS”), the Puerto Rico Electric 

Power Authority (“PREPA”), and the Puerto Rico Public Buildings Authority (“PBA,” and 

together with the Commonwealth, HTA, ERS, and PREPA, the “Debtors”) pursuant to section 

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

respectfully submits this Seventh Informative Motion of the Financial Oversight and Management 

Board For Puerto Rico With Respect to Resolution of Proofs of Claim Pursuant to Alternative 

Dispute Resolution Procedures (the “Seventh Informative Motion”) pursuant to the Order (A) 

Authorizing Alternative Dispute Resolution Procedures, (B) Approving Additional Form of Notice, 

and (C) Granting Related Relief [ECF No. 12576] (the “ADR Order”), as amended by the Order 

Amending Alternative Dispute Resolution Procedures [ECF No. 15505], and in support of the 

Seventh Informative Motion, the Oversight Board respectfully states as follows:

1. On April 1, 2020, this Court entered the ADR Order, which authorized the Debtors

to resolve the amount of general unsecured claims utilizing the ADR Procedures (as defined in the 

ADR Order).

2. Pursuant to the ADR Order, the Debtors have filed twenty-six notices transferring 

claims into the ADR Procedures.

3

 2 PROMESA is codified at 48 U.S.C. §§ 2101–2241.

3 See First Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 13609];

Second Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 14090]; Third 

Notice of Transfer of Claims to Alternative Dispute Resolution [ECF No. 14521]; Fourth Notice 

of Transfer of Claims to Alternative Dispute Resolution [ECF No. 14786]; Fifth Notice of Transfer 

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3. Through the Offer-Exchange (as defined in the ADR Order) phase of the ADR 

Procedures, the Debtors have resolved the validity and the amount of the proofs of claim (the 

“Resolved Claims”) listed on the schedule attached as Exhibit 1 to the proposed order submitted 

herewith. The applicable Debtor and claimant for each Resolved Claim, as identified in Exhibit 

1 to the proposed order submitted herewith, have agreed to and executed a stipulation (collectively, 

the “Stipulations”) regarding the Resolved Claims. 

4. The Stipulations shall not become effective unless and until the proposed order 

attached hereto as Exhibit A is approved by the Court.

WHEREFORE the Debtors respectfully request the Court (1) approve the Stipulations; 

and (2) grant such other and further relief as is just.

[Remainder of Page Intentionally Left Blank]

 

of Claims to Alternative Dispute Resolution [ECF No. 15085]; Sixth Notice of Transfer of Claims 

to Alternative Dispute Resolution [ECF No. 15113]; Seventh Notice of Transfer of Claims to 

Alternative Dispute Resolution [ECF No. 15217]; Eighth Notice of Transfer of Claims to 

Alternative Dispute Resolution [ECF No. 15533]; Ninth Notice of Transfer of Claims to Alternative 

Dispute Resolution [ECF No. 15720]; Tenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 15861]; Amended Eleventh Notice of Transfer of Claims to Alternative 

Dispute Resolution [ECF No. 16540]; Twelfth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 16517]; Thirteenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 16767]; Fourteenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 17208]; Fifteenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 17832]; Sixteenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 18259]; Seventeenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 19169]; Eighteenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 19594]; Nineteenth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 19671]; Twentieth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 20012]; Twenty-First Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 20241]; Twenty-Second Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 20688]; Twenty-Third Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 20779]; Twenty-Fourth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 21685]; Twenty-Fifth Notice of Transfer of Claims to Alternative Dispute 

Resolution [ECF No. 21913]; and Twenty-Sixth Notice of Transfer of Claimsto Alternative Dispute 

Resolution [ECF No. 22364].

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Dated: October 21, 2022

San Juan, Puerto Rico

Respectfully submitted,

/s/ Brian S. Rosen

Martin J. Bienenstock

Brian S. Rosen

Ehud Barak

Paul V. Possinger

(Admitted Pro Hac Vice)

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

Email: mbienenstock@proskauer.com

 brosen@proskauer.com

 ebarak@proskauer.com

 ppossinger@proskauer.com

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

/s/ Hermann D. Bauer

Hermann D. Bauer

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Email: Hermann.bauer@oneillborges.com

Co-Attorneys for the Financial Oversight and 

Management Board as representative for the 

Debtors

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EXHIBIT A

[Proposed] Order

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UNITED STATES DISTRICT COURT 

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.,

Debtor.1

PROMESA Title III

Case No. 17-BK-3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

PUERTO RICO ELECTRIC POWER AUTHORITY 

(“PREPA”),

Debtor.

PROMESA Title III

Case No.17-BK-4780-LTS

[PROPOSED] ORDER REGARDING SEVENTH INFORMATIVE MOTION OF THE 

FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO WITH 

RESPECT TO RESOLUTION OF PROOFS OF CLAIM PURSUANT TO 

ALTERNATIVE DISPUTE RESOLUTION PROCEDURES

 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); 

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).

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Upon consideration of the Seventh Informative Motion of the Financial Oversight and 

Management Board For Puerto Rico With Respect to Resolution of Proofs of Claim Pursuant to 

Alternative Dispute Resolution Procedures (the “Seventh Informative Motion”) filed by the 

Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), as the sole 

Title III representative of the Commonwealth of Puerto Rico (the “Commonwealth”), the Puerto

Rico Highways and Transportation Authority (“HTA”), the Employees Retirement System of the

Government of the Commonwealth of Puerto Rico (“ERS”), the Puerto Rico Electric Power

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

the Commonwealth, HTA, ERS, and PREPA, the “Debtors”), pursuant to section 315(b) of the

Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”), requesting the 

Court approve the stipulations attached hereto as Exhibits 1-A, 1-B, 1-C, and 1-D (the 

“Stipulations”) on the basis that the parties have agreed to settle the validity and amount of the 

proofs of claim identified in the column titled “Claim Number” in Exhibit 1 attached hereto, that 

is the subject of said Stipulations; and it appearing that (i) the Court has subject matter jurisdiction 

over the Seventh Informative Motion pursuant to PROMESA section 306(a); and (ii) venue is 

proper pursuant to PROMESA section 307(a); and after due deliberation and sufficient cause 

appearing therefor:

1. The Seventh Informative Motion is GRANTED as set forth herein; 

2. The Stipulations are hereby approved;

3. The Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the implementation, interpretation, or enforcement of this Order;

4. This Order resolves Docket Entry No. in Case No. 17-3283.

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United States District Court Judge

Laura Taylor Swain

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Exhibit 1 – Schedule of Resolved Claims 

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Exhibit 1 – Schedule of Resolved Claims

Claimant Claim Number Debtor(s) Asserted Claim 

Amount

Settled Amount Stipulation Ex. 

No.

Mercado Guzmán, 

Carlos Miguel

73421 Puerto Rico 

Electric Power 

Authority

$250,000.00 $16,000.00 1-A

N.L.M., UN 

MENOR 

(BARBARA 

MALDONADO, 

MADRE, HCO2 

BOX 5023, PR 

00669)

9516 Puerto Rico 

Electric Power 

Authority

$118,750.00 $59,375.00. 1-B

Y.L.M., in menor 

(Barbara 

Maldonado, madre)

8864 Puerto Rico 

Electric Power 

Authority

$118,750.00 $59,375.00 1-C

GUTIERREZ 

ARROYO, JEAN 

CARLOS

167862 Puerto Rico 

Electric Power 

Authority

$700,000.00 $40,000.00 1-D

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