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 PREPA.

ORDER GRANTING FIVE HUNDRED THIRTY-FOURTH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE PUERTO RICO ELECTRIC POWER AUTHORITY TO 

CLAIMS THAT ARE PARTIALLY SATISFIED AND PARTIALLY ASSERT 

AMOUNTS FOR WHICH PREPA IS NOT LIABLE

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

Puerto Rico Electric Power Authority to Claims That Are Partially Satisfied and Partially Assert 

Amounts for Which PREPA Is Not Liable [ECF No. 22266] (the “Five Hundred Thirty-Fourth 

Omnibus Objection”)2 filed by the Puerto Rico Electric Power Authority (“PREPA”), dated 

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 Five Hundred Thirty-Fourth Omnibus Objection.

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September 16, 2022, for entry of an order reducing the amount of certain claims filed against 

PREPA on the basis that certain of these claims are partially satisfied and/or that PREPA has no 

liability for additional portions of the claims, as more fully set forth in the Five Hundred ThirtyFourth Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to 

consider the Five Hundred Thirty-Fourth 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-Fourth 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 Five Hundred Thirty-Fourth Omnibus Objection (collectively, the 

“Claims to Be Partially Disallowed”) having been found to be satisfied in part or to seek recovery 

of amounts for which PREPA is not liable, as applicable; and the Court having determined that the 

relief sought in the Five Hundred Thirty-Fourth Omnibus Objection is in the best interest of 

PREPA and 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 Thirty-Fourth 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-Fourth Omnibus Objection is GRANTED 

as set forth herein; and it is further

ORDERED that the Claims to Be Partially Disallowed are hereby reduced and 

disallowed to the extent they assert claims for amounts already paid and/or for which PREPA has 

no liability, such that the Claims to Be Disallowed shall now only be considered claims asserting 

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the amount set forth in the column titled “Remaining Claim” in Exhibit A to the Five Hundred 

Thirty-Fourth Omnibus Objection, respectively; and it is further

ORDERED that PREPA’s right to object to the remaining portions of these claims, 

as set forth in the column titled “Remaining Claim” in Exhibit A to the Five Hundred Thirty-Fourth 

Omnibus Objection, is reserved; and it is further

ORDERED that Kroll is authorized and directed to delete and reduce the amount 

asserted in the Claims to Be Partially Disallowed 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 Five Hundred Thirty-Fourth Omnibus Objection) from the official claims register in the 

PREPA Title III Case; and it is further

ORDERED that this Order resolves Docket Entry No. 22266 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 Five Hundred Thirty-Fourth Omnibus Objection 

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NAME

FIVE HUNDRED THIRTY-FOURTH OMNIBUS OBJECTION

	Exhibit A – Partially Satisfied / Partially No Liability Claims

ASSERTED 

DATE FILED CASE NUMBER DEBTOR CLAIM # CLAIM AMOUNT

SATISFIED 

AMOUNT

REMAINING 

CLAIM

NO LIABILITY 

AMOUNT

Reason: Liabilities associated with the claim have been paid by PREPA in part.

ENVIRONICS ENGINEERING GROUP 

CORP

P.O. BOX 29535

SAN JUAN, PR 00929

1 17-03283 PUERTO RICO 63950 $120,918.93

ELECTRIC POWER 

AUTHORITY

6/12/2018 $1,831.76 $0.00 $119,087.17

Reason: PREPA is not liable for a part of liabilities associated with this claim because the claimant's contract was invalid during the period of services provided

POLEN CAPITAL MANAGEMENT, LLC

1825 NW CORPORATE BLVD

SUITE 300

BOCA RATON, FL 33431

2 17-03283 PUERTO RICO 1184 $25,497.00

ELECTRIC POWER 

AUTHORITY

3/7/2018 $0.00 $13,031.80 $12,465.20

Reason: Liabilities associated with the claim have been paid by PREPA in part. PREPA is not liable for a part of liabilities associated with this claim because (i) a Good Friday discount was 

applied, (ii) approved invoice removed costs associated with days that services were not provided, or (iii) it was properly withheld pursuant to Puerto Rico tax law

RANGER AMERICAN ARMORED 

SERVICES INC

PO BOX 29105

SAN JUAN, PR 00929

3 17-03283 PUERTO RICO 75861 $73,340.52

ELECTRIC POWER 

AUTHORITY

6/29/2018 $16,134.00 $543.30 $56,663.22

Reason: PREPA is not liable for a part of liabilities associated with this claim because (i) a portion of such liabilities have been paid and (ii) another portion was properly withheld pursuant to 

Puerto Rico tax law

RUSSELL REYNOLDS ASSOCIATES, 

INC.

CHARLES E. BOULBOL, PC

26 BROADWAY 17TH FLOOR

NEW YORK, NY 10004

4 17-03283 PUERTO RICO 18106 $56,425.11

ELECTRIC POWER 

AUTHORITY

5/22/2018 $2,385.00 $6,000.00 $48,040.11

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* - Indicates claim contains unliquidated and/or undetermined amounts.

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