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) 

Re: ECF Nos. 23752 and 23753. 

MOTION SUBMITTING REVISED PROPOSED ORDERS GRANTING THE (I) FIVE 

HUNDRED FIFTIETH OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF 

THE PUERTO RICO ELECTRIC POWER AUTHORITY TO DUPLICATE 

BOND CLAIMS AND (II) FIVE HUNDRED FIFTY-FIRST OMNIBUS OBJECTION 

(NON-SUBSTANTIVE) OF THE PUERTO RICO ELECTRIC POWER AUTHORITY 

TO DUPLICATIVE BOND CLAIMS 

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 Puerto Rico Electric Power Authority (“PREPA”) 

pursuant to Section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability 

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); 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). 

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Act (“PROMESA”),2 respectfully submits this motion submitting revised proposed orders and 

accompanying exhibits in connection with the (1) Five Hundred Fiftieth Omnibus Objection (NonSubstantive) of the Puerto Rico Electric Power Authority to Duplicate Bond Claims [ECF No. 

22737] (the “Five Hundred Fiftieth Omnibus Objection”), and (2) Five Hundred Fifty-First 

Omnibus Objection (Non-Substantive) of the Puerto Rico Electric Power Authority to Duplicate 

Bond Claims [ECF No. 22738] (the “Five Hundred Fifty-First Omnibus Objection,” and together 

with the Five Hundred Fiftieth Omnibus Objection, the “Omnibus Objections”). 

1. On October 28, 2022, PREPA, by and through the Oversight Board, filed the 

Omnibus Objections. 

2. Thereafter, on December 9, 2022, various debtors, including PREPA, by and 

through the Oversight Board, filed a notice to withdraw, without prejudice, various omnibus 

objections as to certain claims [ECF No. 23036] (the “Notice of Withdrawal”). 

3. Specifically, pursuant to the Notice of Withdrawal, PREPA withdrew, without 

prejudice, (1) the Five Hundred Fiftieth Omnibus Objection, solely with respect to Proof of Claim 

Nos. 30888 and 22078, and (2) the Five Hundred Fifty-First Omnibus Objection, solely with 

respect to Proof of Claim No. 31087 (collectively, the “Withdrawn Claims”). 

4. On January 25, 2023, PREPA, by and through the Oversight Board, filed notices of 

presentment for the Omnibus Objections [ECF Nos. 23365 and 23366] (the “Notices of 

Presentment”). Upon further review, the Notices of Presentment did not attach revised exhibits 

reflecting the withdrawal of the Omnibus Objections as to the Withdrawn Claims. 

2

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

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5. Subsequently, on March 8, 2023, the Court granted the Omnibus Objections 

[ECF Nos. 23752 and 23753] and the Withdrawn Claims were inadvertently expunged from 

PREPA’s Title III claims register. 

6. Accordingly, to correct the record and reinstate the Withdrawn Claims on PREPA’s 

Title III claims register, attached hereto as Exhibit 1 and Exhibit 2 are amended and restated 

proposed orders and accompanying revised exhibits (the “Revised Proposed Orders”) for the 

Omnibus Objections reflecting the withdrawal of the Omnibus Objections as to the Withdrawn 

Claims. 

WHEREFORE, the Oversight Board respectfully requests that this Honorable Court take 

notice of this filing and enter the Revised Proposed Orders granting the Omnibus Objections. 

Dated: April 24, 2023 Respectfully submitted, 

 San Juan, Puerto Rico 

/s/ Ricardo Burgos Vargas 

Ricardo Burgos Vargas 

USDC núm. 218210 

A&S LEGAL STUDIO, PSC 

434 Ave. Hostos 

San Juan, PR 00918 

Tel.: (787) 751-6764 

Fax: (787) 763-8260 

/s/ Paul V. Possinger 

Martin J. Bienenstock (pro hac vice) 

Ehud Barak (pro hac vice) 

Paul V. Possinger (pro hac vice) 

PROSKAUER ROSE LLP

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative for the Puerto Rico Electric 

Power Authority

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Exhibit 1 

Amended and Restated Proposed Order Granting 

Five Hundred Fiftieth Omnibus Objection

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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. 

AMENDED AND RESTATED2 [PROPOSED] ORDER GRANTING FIVE HUNDRED 

FIFTIETH OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF THE PUERTO RICO 

ELECTRIC POWER AUTHORITY TO DUPLICATIVE BOND CLAIMS 

Upon the Five Hundred Fiftieth Omnibus Objection (Non-Substantive) of the 

Puerto Rico Electric Power Authority to Duplicative Bond Claims (the “Five Hundred Fiftieth 

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

 This Order amends and restates the Order Granting Five Hundred Fiftieth Omnibus 

Objection (Non-Substantive) of the Puerto Rico Electric Power Authority to Duplicative Bond 

Claims (Docket Entry No. 23752) to note PREPA’s withdrawal, without prejudice, of the Five 

Hundred Fiftieth Omnibus Objection to Proof of Claim Nos. 30888 and 22078. (See Docket Entry 

No. 23036.)

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Omnibus Objection”)3 of the Puerto Rico Electric Power Authority (“PREPA”), dated October 28, 

2022, for entry of an order disallowing certain claims filed against PREPA, as more fully set forth 

in the Five Hundred Fiftieth Omnibus Objection and supporting exhibits thereto; and the Court 

having jurisdiction to consider the Five Hundred Fiftieth 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 Fiftieth Omnibus 

Objection having been provided to those parties identified therein, and no other or further notice 

being required; and the claims identified in Exhibit A hereto (collectively, the “Duplicative Bond 

Claims”) asserting a duplicative claim, as set forth in Exhibit A hereto; and the Court having 

determined that the relief sought in the Five Hundred Fiftieth 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 Fiftieth 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 Fiftieth Omnibus Objection is GRANTED as set 

forth herein; and it is further 

 ORDERED that the Duplicative Bond Claims are hereby disallowed in their 

entirety; and it is further 

 ORDERED that Prime Clerk (now Kroll Restructuring Administration LLC) is 

authorized and directed to delete the Duplicative Bond Claims from the official claims register in 

the Title III Cases; and it is further 

3

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

in the Five Hundred Fiftieth Omnibus Objection.

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 ORDERED that this Order resolves Docket Entry No. 22737 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. 

Dated: 

 

 Honorable Judge Laura Taylor Swain 

 United States District Judge 

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Exhibit A 

Schedule of Claims Subject to the Five Hundred Fiftieth Omnibus Objection 

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Exhibit 2 

Amended and Restated Proposed Order Granting 

Five Hundred Fifty-First Omnibus Objection

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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. 

AMENDED AND RESTATED2 [PROPOSED] ORDER GRANTING FIVE HUNDRED 

FIFTY-FIRST OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF THE PUERTO 

RICO ELECTRIC POWER AUTHORITY TO DUPLICATIVE BOND CLAIMS 

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

Puerto Rico Electric Power Authority to Duplicative Bond Claims (the “Five Hundred Fifty-First 

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

 This Order amends and restates the Order Granting Five Hundred Fifty-First Omnibus 

Objection (Non-Substantive) of the Puerto Rico Electric Power Authority to Duplicative Bond 

Claims (Docket Entry No. 23753) to note PREPA’s withdrawal, without prejudice, of the Five 

Hundred Fifty-First Omnibus Objection to Proof of Claim No. 31087. (See Docket Entry No. 

23036.)

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Omnibus Objection”)3 of the Puerto Rico Electric Power Authority (“PREPA”), dated October 28, 

2022, for entry of an order disallowing certain claims filed against PREPA, as more fully set forth 

in the Five Hundred Fifty-First Omnibus Objection and supporting exhibits thereto; and the Court 

having jurisdiction to consider the Five Hundred Fifty-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 Fifty-First Omnibus 

Objection having been provided to those parties identified therein, and no other or further notice 

being required; and the claims identified in Exhibit A hereto (collectively, the “Duplicative Bond 

Claims”) asserting a duplicative claim, as set forth in Exhibit A hereto; and the Court having 

determined that the relief sought in the Five Hundred Fifty-First 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 Fifty-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 Fifty-First Omnibus Objection is GRANTED as 

set forth herein; and it is further 

 ORDERED that the Duplicative Bond Claims are hereby disallowed in their 

entirety; and it is further 

 ORDERED that Prime Clerk (now Kroll Restructuring Administration LLC) is 

authorized and directed to delete the Duplicative Bond Claims from the official claims register in 

the Title III Cases; and it is further 

3

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

in the Five Hundred Fifty-First Omnibus Objection.

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 ORDERED that this Order resolves Docket Entry No. 22738 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. 

Dated: 

 

 Honorable Judge Laura Taylor Swain 

 United States District Judge 

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Exhibit A 

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

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