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.,

Debtors.1

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

MOTION SUBMITTING CERTIFIED TRANSLATIONS IN CONNECTION WITH 

DOCKETED CLAIM OBJECTION RESPONSES TO BE HEARD AT THE 

APRIL 25-26, 2023 ADJOURNED OBJECTION HEARING

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 Debtors pursuant to Section 315(b) of the Puerto Rico 

Oversight, Management, and Economic Stability Act (“PROMESA”),2respectfully files this 

motion in compliance with the Court’s March 22, 2023 Order Regarding Pro Se Adjourned 

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 (“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-BK3566-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).

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

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 1 of 13
2

Omnibus Objections to Claims of Unrepresented Claimants [ECF No. 23844] (the “Adjourned 

Objection Hearing Procedures Order”) directing the Oversight Board to file (i) any responses that 

were not filed on the docket and/or (ii) certified translations of any Spanish-language responses to 

claims that the Debtors intend to prosecute at the hearing to be held on April 25-26, 2023. 

Adjourned Objection Hearing Procedures Order at 2.

1. Attached hereto as Exhibit 1 is a certified translation of the response [ECF No. 

18818] filed by claimant Jose A. Figueroa Sierra in response to the Three Hundred Eighty-Seventh 

Omnibus Objection (Substantive) of the Puerto Rico Electric Power Authority to Misclassified 

Claims [ECF No. 17926].

2. Attached hereto as Exhibit 2 is a certified translation of the response [ECF No. 

19754] filed by claimant Carmen D. Carrasquillo in response to the Three Hundred Ninety-Ninth 

Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico and the Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico to No Liability Claims 

Filed by AEELA Members [ECF No. 19548] (the “Three Hundred Ninety-Ninth Omnibus 

Objection”).

3. Attached hereto as Exhibit 3 is a certified translation of the response [ECF No. 

19725] filed by claimant Joel Negrón Guzmán in response to the Three Hundred Ninety-Ninth 

Omnibus Objection.

4. Attached hereto as Exhibit 4 is a certified translation of the response [ECF No. 

10721] filed by claimant Joel Negrón Guzmán in response to the One Hundred Fourteenth 

Omnibus Objection (Non-Substantive) to Deficient Claims Asserting Interests Based Upon 

Unspecified Puerto Rico Statutes [ECF No. 9564].

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 2 of 13
3

5. Attached hereto as Exhibit 5 is a certified translation of the response [ECF No. 

20288] filed by claimant Antonio Juan Marrero Borges in response to the Four Hundred Third 

Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico, the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico, and the Puerto Rico Sales Tax 

Financing Corporation to Employee Claims Asserting Liabilities Owed By Entities That Are Not 

Title III Debtors [ECF No. 19552] (the “Four Hundred Third Omnibus Objection”).

6. Attached hereto as Exhibit 6 is a certified translation of the response [ECF No. 

19884] filed by claimant Xilma M. Acosta Diaz in response to the Four Hundred Third Omnibus 

Objection.

7. Attached hereto as Exhibit 7 is a certified translation of the response [ECF No. 

19827] filed by claimant Keirry del Carmen Alvarez Martinez in response to the Four Hundred 

Third Omnibus Objection.

8. Attached hereto as Exhibit 8 is a certified translation of the response [ECF No. 

19888] filed by claimant José Pérez Andino in response to the Four Hundred Third Omnibus 

Objection.

9. Attached hereto as Exhibit 9 is a certified translation of the response [ECF No. 

19891] filed by claimant William Narvaez Burgos in response to the Four Hundred Third Omnibus 

Objection.

10. Attached hereto as Exhibit 10 is a certified translation of the response [ECF No. 

19832] filed by claimant Heriberto Colon Correa in response to (1) the Four Hundred Third 

Omnibus Objection and (2) the Four Hundred Fourth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Employee Claims Asserting Liabilities Owed By Entities That 

Are Not Title III Debtors [ECF No. 19553] (the “Four Hundred Fourth Omnibus Objection”).

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 3 of 13
4

11. Attached hereto as Exhibit 11 is a certified translation of the response [ECF No. 

19752] filed by claimant Irma Colon Vega in response to the Four Hundred Third Omnibus 

Objection.

12. Attached hereto as Exhibit 12 is a certified translation of the response [ECF No. 

19852] filed by claimant Marta F. Colon in response to the Four Hundred Third Omnibus 

Objection.

13. Attached hereto as Exhibit 13 is a certified translation of the response [ECF No. 

20133] filed by claimant Marina Crispin Santiago in response to the Four Hundred Third Omnibus 

Objection.

14. Attached hereto as Exhibit 14 is a certified translation of the response [ECF No. 

19883] filed by claimant Alba N. Garcia in response to the Four Hundred Third Omnibus 

Objection.

15. Attached hereto as Exhibit 15 is a certified translation of the response [ECF No. 

19825] filed by claimant Nelson Heredia Alvarez in response to the Four Hundred Third Omnibus 

Objection.

16. Attached hereto as Exhibit 16 is a certified translation of the response [ECF No. 

19977] filed by claimant Felicita Hernandez Hernandez in response to the Four Hundred Third 

Omnibus Objection.

17. Attached hereto as Exhibit 17 is a certified translation of the response [ECF No. 

20062] filed by claimant Jose A. Maysonet in response to the Four Hundred Third Omnibus 

Objection.

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 4 of 13
5

18. Attached hereto as Exhibit 18 is a certified translation of the response [ECF No. 

19800] filed by claimant Milagros Morales Hernandez in response to the Four Hundred Third 

Omnibus Objection.

19. Attached hereto as Exhibit 19 is a certified translation of the response [ECF No. 

19821] filed by claimant Fredesvinda Ortiz Otero in response to the Four Hundred Third Omnibus 

Objection.

20. Attached hereto as Exhibit 20 is a certified translation of the response [ECF No. 

19801] filed by claimant Jacqueline Rosado Colon in response to the Four Hundred Third Omnibus 

Objection.

21. Attached hereto as Exhibit 21 is a certified translation of the response [ECF No. 

20061] filed by claimant Gladys Santos Martinez in response to the Four Hundred Third Omnibus 

Objection.

22. Attached hereto as Exhibit 22 is a certified translation of the response [ECF Nos. 

19729] filed by claimant Alicia Beniquez Toro in response to the Four Hundred Third Omnibus 

Objection.

23. Attached hereto as Exhibit 23 is a certified translation of the response [ECF No. 

19826] filed by claimant Lillian I. Torres Orraca in response to the Four Hundred Third Omnibus 

Objection.

24. Attached hereto as Exhibit 24 is a certified translation of the response [ECF No. 

19878] filed by claimant Emerina Torres Torres in response to the Four Hundred Third Omnibus 

Objection.

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 5 of 13
6

25. Attached hereto as Exhibit 25 is a certified translation of the response [ECF No. 

19881] filed by claimant Carmen D. Valdez Peralta in response to the Four Hundred Third 

Omnibus Objection.

26. Attached hereto as Exhibit 26 is a certified translation of the response [ECF No. 

19802] filed by claimant Maria Isabel Velazquez in response to the Four Hundred Third Omnibus 

Objection.

27. Attached hereto as Exhibit 27 is a certified translation of the response [ECF No. 

19829] filed by claimant Leticia Velez in response to the Four Hundred Third Omnibus Objection.

28. Attached hereto as Exhibit 28 is a certified translation of the response [ECF No. 

19753] filed by claimant Maria T. Ydrach Vivoni in response to the Four Hundred Third Omnibus 

Objection.

29. Attached hereto as Exhibit 29 is a certified translation of the response [ECF No. 

20472] filed by claimant Wanda I. Perez Lopez in response to the Four Hundred Third Omnibus 

Objection.

30. Attached hereto as Exhibit 30 is a certified translation of the response [ECF No. 

19824] filed by claimant William Lopez Torres in response to the Four Hundred Fourth Omnibus 

Objection.

31. Attached hereto as Exhibit 31 is a certified translation of the response [ECF No. 

19886] filed by claimant Yazmin Martinez Cole in response to the Four Hundred Fourth Omnibus 

Objection.

32. Attached hereto as Exhibit 32 is a certified translation of the response [ECF No. 

20121] filed by claimant Olga Santiago Arce in response to the Four Hundred Fourth Omnibus 

Objection.

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 6 of 13
7

33. Attached hereto as Exhibit 33 is a certified translation of the response [ECF No. 

20270] filed by claimant Salvador S. Rivera Pena in response to the Four Hundred Fourth Omnibus 

Objection.

34. Attached hereto as Exhibit 34 is a certified translation of the response [ECF No. 

21234] filed by claimant Maria Serrano Vazquez in response to the Four Hundred Fourth Omnibus 

Objection.

35. Attached hereto as Exhibit 35 is a certified translation of the response [ECF No. 

21235] filed by claimant Sylvia Vila Solano in response to the Four Hundred Fourth Omnibus 

Objection.

36. Attached hereto as Exhibit 36 is a certified translation of the response [ECF No. 

21236] filed by claimant Regina Cruz Davila in response to the Four Hundred Fourth Omnibus 

Objection.

37. Attached hereto as Exhibit 37 is a certified translation of the response [ECF No. 

21237] filed by claimant Doris Diaz de Gonzalez in response to the Four Hundred Fourth Omnibus 

Objection.

38. Attached hereto as Exhibit 38 is a certified translation of the response [ECF No. 

21238] filed by claimant Carmen Alicia Santiago Duco in response to the Four Hundred Fourth 

Omnibus Objection.

39. Attached hereto as Exhibit 39 is a certified translation of the response [ECF No. 

22884] filed by claimant Lourdes Febre Santiago in response to the Four Hundred Fourth Omnibus 

Objection.

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 7 of 13
8

40. Attached hereto as Exhibit 40 is a certified translation of the response [ECF No. 

22358] filed by claimant Arleen J. Nieves Correa in response to the Four Hundred Fourth Omnibus 

Objection.

41. Attached hereto as Exhibit 41 is a certified translation of the response [ECF No. 

19799] filed by claimant Marilyn Cintrón Serrano in response to the Four Hundred Sixth Omnibus 

Objection (Substantive) of the Commonwealth of Puerto Rico and the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico to Duplicate Litigation Claims

[ECF No. 19555].

42. Attached hereto as Exhibit 42 is a certified translation of the response [ECF No. 

19726] filed by claimant Jorge Martinez Garcia in response to the Four Hundred Twelfth Omnibus 

Objection (Non-Substantive) of the Puerto Rico Electric Power Authority to Deficient Claims

[ECF No. 19559].

43. Attached hereto as Exhibit 43 is a certified translation of the response [ECF No. 

20641] filed by claimant Rafael Carrasquillo Nieves in response to the Four Hundred ThirtySecond Omnibus Objection (Non-Substantive) of the Commonwealth of Puerto Rico and the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico to Claims 

Asserted against the Incorrect Debtor [ECF No. 20487] (the “Four Hundred Thirty-Second 

Omnibus Objection”).

44. Attached hereto as Exhibit 44 is a certified translation of the response [ECF No. 

22896] filed by claimant Ramón A. López Alvarado in response to the Four Hundred ThirtySecond Omnibus Objection.

45. Attached hereto as Exhibit 45 is a certified translation of the response [ECF No. 

21054] filed by claimant Irma Colon Vega in response to the Four Hundred Thirty-Seventh 

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 8 of 13
9

Omnibus Objection (Non-Substantive) of the Commonwealth of Puerto Rico and the Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico to Duplicate Claims 

[ECF No. 20495] (the “Four Hundred Thirty Seventh Omnibus Objection”).

46. Attached hereto as Exhibit 46 is a certified translation of the response [ECF No. 

21010] filed by claimant Alberto Vega Zayas in response to the Four Hundred Thirty-Seventh 

Omnibus Objection.

47. Attached hereto as Exhibit 47 is a certified translation of the response [ECF No. 

20601] filed by claimant Luz M. Acevedo Mercado in response to the Four Hundred Forty-Third 

Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico and the Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico to Deficient ADR 

Claims [ECF No. 20501].

48. Attached hereto as Exhibit 48 is a certified translation of the response [ECF No. 

21595] filed by claimant Benivette Rentas in response to the Four Hundred Fifty-Third Omnibus 

Objection (Non-Substantive) of the Commonwealth of Puerto Rico, the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico, and the Puerto Rico Highways 

and Transportation Authority to Claims Asserting Liabilities Owed by Entities That Are Not Title 

III Debtors [ECF No. 20784].

49. Attached hereto as Exhibit 49 is a certified translation of the response [ECF No. 

21075] filed by claimant Miriam Sanchez Lebron in response to the Four Hundred Sixty-Fifth 

Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico, the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico, the Puerto Rico Highways and 

Transportation Authority, and the Puerto Rico Public Buildings Authority to Claims for Which 

The Debtors Are Not Liable [ECF No. 20796].

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 9 of 13
10

50. Attached hereto as Exhibit 50 is a certified translation of the response [ECF No. 

21799] filed by claimant Aurelio Moreno Soto in response to the Four Hundred Seventy-Sixth 

Omnibus Objection (Non-Substantive) of the Commonwealth of Puerto Rico and Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico to Duplicate Claims

[ECF No. 20791].

51. Attached hereto as Exhibit 51 is a certified translation of the response [ECF No. 

22600] filed by claimant Alicea Rodriguez Heliodora in response to the Four Hundred EightyFourth Omnibus Objection (Non-Substantive) of the Commonwealth of Puerto Rico and the 

Employees Retirement System of the Government of the Commonwealth of Puerto Rico to 

Subsequently Amended and Superseded Claims [ECF No. 21733].

52. Attached hereto as Exhibit 52 is a certified translation of the response [ECF No. 

22651] filed by claimant Nelson I. Maysonet Martinez in response to the Five Hundred Fourteenth 

Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico, the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico, and the Puerto Rico Highways 

and Transportation Authority to Claims for Which The Debtors Are Not Liable [ECF No. 22251] 

(the “Five Hundred Fourteenth Omnibus Objection”).

53. Attached hereto as Exhibit 53 is a certified translation of the response [ECF No. 

22652] filed by claimant Asunción Colón Ramos in response to the Five Hundred Fourteenth 

Omnibus Objection.

54. Attached hereto as Exhibit 54 is a certified translation of the response [ECF No. 

22653] filed by claimant Myrtelina Torres Berríos in response to the Five Hundred Fourteenth 

Omnibus Objection.

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 10 of 13
11

55. Attached hereto as Exhibit 55 is a certified translation of the response [ECF No. 

22654] filed by claimant Juan L. Dávila Pérez in response to the Five Hundred Fourteenth 

Omnibus Objection.

56. Attached hereto as Exhibit 56 is a certified translation of the response [ECF No. 

22655] filed by claimant Arnold Rodriguez Sanchez in response to the Five Hundred Fourteenth 

Omnibus Objection.

57. Attached hereto as Exhibit 57 is a certified translation of the response [ECF No. 

22656] filed by claimant Gerardo J. Ramos Velázquez in response to the Five Hundred Fourteenth 

Omnibus Objection.

58. Attached hereto as Exhibit 58 is a certified translation of the response [ECF No. 

22657] filed by claimant Raul Santini-Rivera in response to the Five Hundred Fourteenth Omnibus 

Objection.

59. Attached hereto as Exhibit 59 is a certified translation of the response [ECF No. 

23299] filed by claimant Luz Esther Rivera Cuevas in response to the Five Hundred TwentySecond Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico and the Puerto 

Rico Highways and Transportation Authority to Unliquidated Claims [ECF No. 22257].

60. Attached hereto as Exhibit 60 is a certified translation of the response [ECF No. 

22852] filed by claimant Efran Márquez Guzmán in response to the Thirty-Seventh Omnibus 

Objection (Substantive) of the Commonwealth of Puerto Rico and the Puerto Rico Highways and 

Transportation Authority to Duplicate and No Liability Bond Claims [ECF No. 22740].

61. Attached hereto as Exhibit 61 is a certified translation of the response [ECF No. 

22853] filed by claimant María V. Peréz Rodríguez in response to the Five Hundred Thirty-Eighth 

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 11 of 13
12

Omnibus Objection (Non-Substantive) of the Commonwealth of Puerto Ric to Incorrect Debtor 

Claims [ECF No. 20501].

62. Attached hereto as Exhibit 62 is a certified translation of the response [ECF No. 

20646] filed by claimant Miriam Sanchez Lebron in response to the Four Hundred Forty-Eighth 

Omnibus Objection (Substantive) of the Puerto Rico Electric Power Authority to Claims for Which 

It Is Not Liable [ECF No. 20504].

Additional responses that were not filed on the docket, as well as certified translations 

thereof, are being submitted via notices of correspondence submitted contemporaneously 

herewith.

Courtesy copies of these certified translations will also be submitted to chambers in the 

electronic hearing binders the Oversight Board intends to submit on or before April 18, 2023 at 

12:00 p.m. (Atlantic Standard Time) in compliance with the Adjourned Objection Hearing 

Procedures Order.

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

notice of the filing of these responses and certified translations in compliance with the Court’s 

orders.

[Remainder of Page Intentionally Left Blank]

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 12 of 13
13

Dated: April 11, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Brian S. Rosen

Martin J. Bienenstock

Brian S. Rosen

(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

USDC No. 215205

Carla Carcía-Benítez

USDC No. 203708

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

Case:17-03283-LTS Doc#:23987 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc: Main

Document Page 13 of 13