Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23361-1 Filed:01/25/23 Entered:01/25/23 17:14:14 Desc:

Exhibit A Proposed Order Page 1 of 6
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 TWENTY-FIRST OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO TO PARTIALLY 

SATISFIED AND PARTIALLY NO LIABILITY CLAIMS

Upon the Five Hundred Twenty-First Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Partially Satisfied and Partially No Liability Claims (the “Five 

Hundred Twenty-First Omnibus Objection”)2 of the Commonwealth of Puerto Rico (the 

“Commonwealth”), dated September 16, 2022, for entry of an order modifying certain claims filed 

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 Twenty-First Omnibus Objection.

Case:17-03283-LTS Doc#:23361-1 Filed:01/25/23 Entered:01/25/23 17:14:14 Desc:

Exhibit A Proposed Order Page 2 of 6
2

against the Debtors, as more fully set forth in the Five Hundred Twenty-First Omnibus Objection 

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

Twenty-First 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 Twenty-First 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 the column titled “Claims to Be Reduced and Allowed” in Exhibit A to the Five Hundred 

Twenty-First Omnibus Objection (collectively, the “Claims to Be Reduced”) having been partially 

satisfied and/or not giving rise to any liability of the Commonwealth; and the Court having 

determined that the relief sought in the Five Hundred Twenty-First Omnibus Objection is in the 

best interest of the Debtors, their creditors, and all the parties in interest; and the Court having 

determined that the legal and factual bases set forth in the Five Hundred Twenty-First 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 Twenty-First Omnibus Objection is GRANTED 

as set forth herein; and it is further

ORDERED that the Claims to Be Reduced are hereby modified as set forth in 

Exhibit A to the Five Hundred Twenty-First Omnibus Objection; and it is further 

ORDERED that Kroll is authorized and directed to modify the amounts of the 

Claims to Be Reduced set forth on the official claims register in the Title III Cases; 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.

Case:17-03283-LTS Doc#:23361-1 Filed:01/25/23 Entered:01/25/23 17:14:14 Desc:

Exhibit A Proposed Order Page 3 of 6
3

Dated: 

Honorable Judge Laura Taylor Swain

United States District Judge 

Case:17-03283-LTS Doc#:23361-1 Filed:01/25/23 Entered:01/25/23 17:14:14 Desc:

Exhibit A Proposed Order Page 4 of 6
EXHIBIT A

Schedule of Claims Subject to the Five Hundred Twenty-First Omnibus Objection 

Case:17-03283-LTS Doc#:23361-1 Filed:01/25/23 Entered:01/25/23 17:14:14 Desc:

Exhibit A Proposed Order Page 5 of 6
PRIORITY 

STATUS

Five Hundred Twenty-First Omnibus Objection

Exhibit A - Claims to Be Reduced and Allowed

ASSERTED MODIFIED AND ALLOWED

NAME DEBTOR

PRIORITY 

CLAIM # STATUS AMOUNT DEBTOR AMOUNT

 1 CONSOLIDATED WASTE 23922 Commonwealth of Puerto Rico Unsecured $2,773.75 Commonwealth of Puerto Rico Unsecured $85.05

SERVICES

PO BOX 1322

GURABO, PR 00778

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $1,105.00 in the agency's system. Additionally, invoices totaling $1,583.70 were paid via EFTs 3648, 4304, and 

4364 on 01/26/2018, 05/03/2018, and 05/10/2018. The Claimant shall retain the non-modified portion of the claim.

 2 CRESPO & RODRIGUEZ 21515 Commonwealth of Puerto Rico Unsecured $14,297.56 Commonwealth of Puerto Rico Unsecured $8,341.85

INC.

PO BOX 270029

SAN JUAN, PR 00928

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $1,233.50 in the agency's system. Invoices totaling $4,255.46 fail 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 Health Insurance Administration (ASES), Medical Services 

Administration, Municipality of San Lorenzo, and Puerto Rico Ports Authority, which are not part of the Title III proceedings. The Claimant shall retain the non-modified portion of the 

claim. Claim #21515 also contained on Exhibit A to the 372nd Omnibus Claims Objection for Modified Claims.

 3 ESTUDIOS TÉCNICOS, INC. 27512 Commonwealth of Puerto Rico Unsecured $98,650.00 Commonwealth of Puerto Rico Unsecured $68,412.50

PO BOX 12144

SAN JUAN, PR 00914-0144

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $24,237.50 in the agency's system. The Claimant shall retain the non-modified portion of the claim. Claim #27512 

also contained on Exhibit A to the 391st Omnibus Claims Objection for Modified Claims.

 4 PR STORAGE FORKLIFT 45353 Commonwealth of Puerto Rico Unsecured Undetermined* Commonwealth of Puerto Rico Unsecured $116.55

DIVISION

PO BOX 250060

AGUADILLA, PR 00604

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice totaling $3,200.00 in the agency's system. Additionally, invoices totaling $5,797.38 were paid via checks/ EFTs 00000958, 

00002185, 00002975, 00003481, 00003979, and 00004691 on 10/24/2016, 05/10/2017, 09/18/2017, 12/29/2017, 03/09/2018, and 06/28/2018. Also, the claim was fully unliquidated, 

modified amount fully liquidates the claim.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23361-1 Filed:01/25/23 Entered:01/25/23 17:14:14 Desc:

Exhibit A Proposed Order Page 6 of 6