Exhibit A

Proposed Order

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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 FORTY-NINTH

OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO 

RICO TO CLAIMS FOR WHICH THE DEBTOR IS NOT LIABLE

Upon the Five Hundred Forty-Ninth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Claims for which the Debtor Is Not Liable (the “Five Hundred 

Forty-Ninth Omnibus Objection”)2 of the Commonwealth of Puerto Rico (the “Commonwealth” 

or “Objecting Debtor”), dated October 28, 2022, for entry of an order disallowing in their entirety 

1 The Debtors in the 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 Five Hundred Forty-Ninth Omnibus Objection.

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certain claims filed against the Objecting Debtor, as more fully set forth in the Five Hundred FortyNinth Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to 

consider the Five Hundred Forty-Ninth 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 Forty-Ninth 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 Five 

Hundred Forty-Ninth Omnibus Objection (collectively, the “Claims to Be Disallowed”) having 

been found to be claims for which neither the Commonwealth nor any of the other Title III Debtors 

are liable; and the Court having determined that the relief sought in the Five Hundred Forty-Ninth 

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

interest; and the Court having determined that the legal and factual bases set forth in the Five 

Hundred Forty-Ninth Omnibus Objection establish just cause for the relief granted herein; and 

after due deliberation and sufficient cause appearing therefor, it is

ORDERED that the Five Hundred Forty-Ninth 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 designate the Claims to Be 

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

ORDERED that this Order resolves Docket Entry No. 22753 in Case No. 17-3283; 

and it is further

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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 

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EXHIBIT A

Schedule of Claims Subject to the Five Hundred Forty-Ninth Omnibus Objection 

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Five Hundred Forty-Ninth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 PRADO RODRIGUEZ, BIENVENIDA 02/03/2020 17 BK 03283-LTS Commonwealth of Puerto Rico 173104-1

HC-01 BOX 4156

NAGUABO, PR 00718

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Nilda Agosto Maldonado et al. v. Commonwealth of Puerto Rico Family Department et al., Civil No. 

KPE-2005-0608 (the “Litigation”). However, based on documentation submitted by the attorney representing all claimants in the Litigation, Claimant is not a named plaintiff in that 

Litigation, and there is therefore no basis for claimant to assert liabilities associated with that Litigation against the Commonwealth, ERS, or any other Title III debtor. Further, even if 

Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim no. 115276, the master proof of claim filed on behalf of all plaintiffs associated with the 

litigation captioned Agosto Maldonado. 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.

Claim #173104-1 also contained on Exhibit A to the 548th Omnibus Claims Objection for Claims to Be Disallowed.

 2 RODRIGUEZ FARIA, MARILYN 05/18/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 14149

URB PASEO SOL Y MAR CALLE CORAL 640

JUANA DIAZ, PR 00795

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Nilda Agosto Maldonado et al. v. Commonwealth of Puerto Rico Family Department et al., Civil No. 

KPE-2005-0608 (the “Litigation”). However, based on documentation submitted by the attorney representing all claimants in the Litigation, Claimant is not a named plaintiff in that 

Litigation, and there is therefore no basis for claimant to assert liabilities associated with that Litigation against the Commonwealth, ERS, or any other Title III debtor. Further, even if 

Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim no. 115276, the master proof of claim filed on behalf of all plaintiffs associated with the 

litigation captioned Agosto Maldonado.

Claim #14149 also contained on Exhibit A to the 548th Omnibus Claims Objection for Claims to Be Disallowed.

TOTAL Undetermined*

*Indicates claim contains unliquidated and/or undetermined amounts 1

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