Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 1 of 18
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 and ERS.

ORDER GRANTING FOUR HUNDRED NINETY-EIGHTH 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

Upon the Four Hundred Ninety-Eighth 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. 21755] (the “Four 

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)

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 2 of 18
2

Hundred Ninety-Eighth Omnibus Objection”)2 filed by the Commonwealth of Puerto Rico (the 

“Commonwealth”) and the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico (“ERS,” and together with the Commonwealth, the “Debtors”), 

dated August 5, 2022, for entry of an order disallowing in their entirety certain claims filed against 

the Debtors, as more fully set forth in the Four Hundred Ninety-Eighth Omnibus Objection and 

supporting exhibits thereto; and the Court having jurisdiction to consider the Four Hundred NinetyEighth 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 Four Hundred Ninety-Eighth 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 Four Hundred Ninety-Eighth Omnibus 

Objection (collectively, the “Claims to Be Disallowed”) having been found to be duplicative of 

the Litigation Master Claims, as defined in the Four Hundred Ninety-Eighth Omnibus Objection; 

and the Court having determined that the relief sought in the Four Hundred Ninety-Eighth 

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 Four 

Hundred Ninety-Eighth Omnibus Objection establish just cause for the relief granted herein; and 

after due deliberation and sufficient cause appearing therefor, it is

ORDERED that the Four Hundred Ninety-Eighth Omnibus Objection is 

GRANTED as set forth herein; and it is further

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

in the Four Hundred Ninety-Eighth Omnibus Objection.

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 3 of 18
3

ORDERED that the Claims to Be Disallowed are hereby disallowed in their 

entirety; and it is further 

 ORDERED that the Debtors’ right to object to the Litigation Master Claims is 

reserved; 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. 21755 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 

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 4 of 18
EXHIBIT A

Schedule of Claims Subject to the Four Hundred Ninety-Eighth Omnibus Objection 

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 5 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 1 05/30/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

APONTE CALDERON, 25052 Undetermined*

ISABEL M

URB EL ROSARIO T13 

CALLE G

VEGA BAJA, PR 00693

MADELINE ACEVEDO 

CAMACHO ET AL. 

(2,818 PLANTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLANTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

103072 $8,990,000.00*

MADELINE ACEVEDO 

CAMANCHO ET AL. 

(2818 PLAINTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLAINTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

LCDA. IVONNE 

GONZALEZ MORALES

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/04/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

32044 $50,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 32044 and 103072, which were filed on behalf of all plaintiffs in the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of 

Family Affairs, No. 2016-05-1340 (the “Acevedo Camacho Master Claims”), by the attorney representing plaintiffs in that litigation. The Acevedo Camacho Master Claims are filed on behalf of the DOFA 

employees who alleged that DOFA illegally sequestered wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that 

litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 6 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 2 06/28/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

BENIQUEZ RIOS, 162130 Undetermined*

MARIA DEL C

HC 67 BOX 126

BAYAMON, PR 00956

MADELINE ACEVEDO 

CAMACHO ET AL. 

(2,818 PLANTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLANTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

103072 $8,990,000.00*

MADELINE ACEVEDO 

CAMANCHO ET AL. 

(2818 PLAINTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLAINTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

LCDA. IVONNE 

GONZALEZ MORALES

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/04/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

32044 $50,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 32044 and 103072, which were filed on behalf of all plaintiffs in the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of 

Family Affairs, No. 2016-05-1340 (the “Acevedo Camacho Master Claims”), by the attorney representing plaintiffs in that litigation. The Acevedo Camacho Master Claims are filed on behalf of the DOFA 

employees who alleged that DOFA illegally sequestered wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that 

litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 7 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 3 04/30/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

CLEMENTE TAPIA, 9837 $32,000.00*

MARGARITA

HC 3 BOX 22922

RIO GRANDE, PR 

00745-8868

JEANNETTE 

ABRAMS-DIAZ ET AL 

(1084 PLAINTIFFS) 

COLLECTIVELY (THE 

"ABRAMS-DIAZ 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2005-5021

ABRAMS-DIAZ 

PLAINTIFF GROUP 

(1,084 PLAINTIFFS) 

LCDA IVONNE 

GONZALEZ-MORALES

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

104127 $6,829,644.40*

JEANETTE ABRAHAM 

DIAZ ET AL (1,084 

PLAINTIFFS) 

COLLECTIVELY (THE 

"ABRAHAM DIAZ 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2005-5021

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/14/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

50221 $43,400,081.58*

Reason: This claim is duplicative of Master Claim nos. 50221 and 104127, which were filed on behalf of all plaintiffs in the litigation captioned Jeannete Abrams Diaz et al. v. Department of Transportation & 

Public Works, No. KAC2005-5021 (the “Abrams Diaz Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Transportation and Public 

Works (“DOTP”) employees who alleged that DOTP improperly withheld a proportion of their wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 

5-86.” Claimant is a plaintiff in that litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 3

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 8 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 4 05/30/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

CRUZ ACEVEDO, 39412 Undetermined*

MARIBEL

URB MONTEMAR #13

AGUADA, PR 00602

FRANCISCO BELTRAN 

ET AL (4,593 

PLAINTIFFS) 

COLLECTIVELLY (THE 

"BELTRAN CINTRON 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2009-0805/TSPR AC 

2016-0120

C/O IVONNE 

GONZALEZ-MORALES

ATTORNEY FOR 

BELTRAN CINTRON 

PLAINTIFF GROUP

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

93199 $15,283,000.00*

FRANCISCO BELTRAN 

ET ALL (4,493 

PLAINTIFFS) 

COLLECTIVELY (THE 

BELTRAN CINTRON 

PLAINTIFF GROUP")...

ATTN: IVONNE 

GONZALEZ-MORALES

PO BOX 9021828

SAN JUAN, PR 00902

03/05/21 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

179140 $105,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 179140 and 93199, which were filed on behalf of all plaintiffs in the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family 

Affairs, No. KAC2009-0809 (the “Beltrán Cintrón Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Family Affairs (“DOFA”) 

employees who alleged that DOFA withheld wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that litigation, and 

his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 4

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 9 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 5 05/29/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

ESQUILIN CINTRON, 43713 Undetermined*

ROSA

URB VALLE ARRIBA 

HEIGHTS

BC5 CALLE 

YAGRUMO

CAROLINA, PR 00983

FRANCISCO BELTRAN 

ET AL (4,593 

PLAINTIFFS) 

COLLECTIVELLY (THE 

"BELTRAN CINTRON 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2009-0805/TSPR AC 

2016-0120

C/O IVONNE 

GONZALEZ-MORALES

ATTORNEY FOR 

BELTRAN CINTRON 

PLAINTIFF GROUP

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

93199 $15,283,000.00*

FRANCISCO BELTRAN 

ET ALL (4,493 

PLAINTIFFS) 

COLLECTIVELY (THE 

BELTRAN CINTRON 

PLAINTIFF GROUP")...

ATTN: IVONNE 

GONZALEZ-MORALES

PO BOX 9021828

SAN JUAN, PR 00902

03/05/21 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

179140 $105,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 179140 and 93199, which were filed on behalf of all plaintiffs in the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family 

Affairs, No. KAC2009-0809 (the “Beltrán Cintrón Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Family Affairs (“DOFA”) 

employees who alleged that DOFA withheld wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that litigation, and 

his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 5

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 10 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 6 06/07/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

MALDONADO 80639 Undetermined*

FONTANEZ, 

MARITZA

PO BOX 965

COROZAL, PR 00783

MADELINE ACEVEDO 

CAMACHO ET AL. 

(2,818 PLANTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLANTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

103072 $8,990,000.00*

MADELINE ACEVEDO 

CAMANCHO ET AL. 

(2818 PLAINTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLAINTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

LCDA. IVONNE 

GONZALEZ MORALES

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/04/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

32044 $50,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 32044 and 103072, which were filed on behalf of all plaintiffs in the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of 

Family Affairs, No. 2016-05-1340 (the “Acevedo Camacho Master Claims”), by the attorney representing plaintiffs in that litigation. The Acevedo Camacho Master Claims are filed on behalf of the DOFA 

employees who alleged that DOFA illegally sequestered wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that 

litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 6

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 11 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 7 05/21/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

ORTIZ RIVERA, 28763 $230,400.00*

WILMA

P.O. BOX 5026

CAGUAS, PR 

00726-5026

FRANCISCO BELTRAN 

ET AL (4,593 

PLAINTIFFS) 

COLLECTIVELLY (THE 

"BELTRAN CINTRON 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2009-0805/TSPR AC 

2016-0120

C/O IVONNE 

GONZALEZ-MORALES

ATTORNEY FOR 

BELTRAN CINTRON 

PLAINTIFF GROUP

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

93199 $15,283,000.00*

MADELINE ACEVEDO 

CAMACHO ET AL. 

(2,818 PLANTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLANTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

103072 $8,990,000.00*

*Indicates claim contains unliquidated and/or undetermined amounts 7

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 12 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

MADELINE ACEVEDO 

CAMANCHO ET AL. 

(2818 PLAINTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLAINTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

LCDA. IVONNE 

GONZALEZ MORALES

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/04/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

32044 $50,000,000.00*

FRANCISCO BELTRAN 

ET ALL (4,493 

PLAINTIFFS) 

COLLECTIVELY (THE 

BELTRAN CINTRON 

PLAINTIFF GROUP")...

ATTN: IVONNE 

GONZALEZ-MORALES

PO BOX 9021828

SAN JUAN, PR 00902

03/05/21 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

179140 $105,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 179140 and 93199, which were filed on behalf of all plaintiffs in the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family 

Affairs, No. KAC2009-0809 (the “Beltrán Cintrón Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Family Affairs (“DOFA”) 

employees who alleged that DOFA withheld wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that litigation, and 

his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

This claim is duplicative of Master Claim nos. 32044 and 103072, which were filed on behalf of all plaintiffs in the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family 

Affairs, No. 2016-05-1340 (the “Acevedo Camacho Master Claims”), by the attorney representing plaintiffs in that litigation. The Acevedo Camacho Master Claims are filed on behalf of the DOFA employees who 

alleged that DOFA illegally sequestered wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that litigation, and his/her 

claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 8

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 13 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 8 05/25/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

REYES ORTIZ, SONIA 32116 Undetermined*

I

TURABO GARDENS 

2DA SECCION

K 56 CALLE 28

CAGUAS, PR 00727

FRANCISCO BELTRAN 

ET AL (4,593 

PLAINTIFFS) 

COLLECTIVELLY (THE 

"BELTRAN CINTRON 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2009-0805/TSPR AC 

2016-0120

C/O IVONNE 

GONZALEZ-MORALES

ATTORNEY FOR 

BELTRAN CINTRON 

PLAINTIFF GROUP

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

93199 $15,283,000.00*

FRANCISCO BELTRAN 

ET ALL (4,493 

PLAINTIFFS) 

COLLECTIVELY (THE 

BELTRAN CINTRON 

PLAINTIFF GROUP")...

ATTN: IVONNE 

GONZALEZ-MORALES

PO BOX 9021828

SAN JUAN, PR 00902

03/05/21 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

179140 $105,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 179140 and 93199, which were filed on behalf of all plaintiffs in the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family 

Affairs, No. KAC2009-0809 (the “Beltrán Cintrón Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Family Affairs (“DOFA”) 

employees who alleged that DOFA withheld wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that litigation, and 

his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 9

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 14 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 9 05/17/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

RODRIGUEZ 26432 $21,888.86*

MERCADO, IVETTE

NUM 5288 CALLE 

IGENIO

URBANIZACION 

HACIENDA LA 

MATILDE

PONCE, PR 

00728-2430

JEANNETTE 

ABRAMS-DIAZ ET AL 

(1084 PLAINTIFFS) 

COLLECTIVELY (THE 

"ABRAMS-DIAZ 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2005-5021

ABRAMS-DIAZ 

PLAINTIFF GROUP 

(1,084 PLAINTIFFS) 

LCDA IVONNE 

GONZALEZ-MORALES

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

104127 $6,829,644.40*

JEANETTE ABRAHAM 

DIAZ ET AL (1,084 

PLAINTIFFS) 

COLLECTIVELY (THE 

"ABRAHAM DIAZ 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2005-5021

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/14/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

50221 $43,400,081.58*

Reason: This claim is duplicative of Master Claim nos. 50221 and 104127, which were filed on behalf of all plaintiffs in the litigation captioned Jeannete Abrams Diaz et al. v. Department of Transportation & 

Public Works, No. KAC2005-5021 (the “Abrams Diaz Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Transportation and Public 

Works (“DOTP”) employees who alleged that DOTP improperly withheld a proportion of their wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 

5-86.” Claimant is a plaintiff in that litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 10

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 15 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 10 05/24/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

SALVA RODRIGUEZ 26248 Undetermined*

(FALLECIDO), 

CANDIDO A

DOS PINOS 

TOWNHOUSES

B 12 CALLE 2

SAN JUAN, PR 00923

MADELINE ACEVEDO 

CAMACHO ET AL. 

(2,818 PLANTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLANTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

103072 $8,990,000.00*

MADELINE ACEVEDO 

CAMANCHO ET AL. 

(2818 PLAINTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLAINTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

LCDA. IVONNE 

GONZALEZ MORALES

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/04/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

32044 $50,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 32044 and 103072, which were filed on behalf of all plaintiffs in the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of 

Family Affairs, No. 2016-05-1340 (the “Acevedo Camacho Master Claims”), by the attorney representing plaintiffs in that litigation. The Acevedo Camacho Master Claims are filed on behalf of the DOFA 

employees who alleged that DOFA illegally sequestered wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that 

litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 11

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 16 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

11 06/28/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

SANTIAGO CONDE, 61367 Undetermined*

BLANCA

PO BOX 370038

CAYEY, PR 

00737-0038

MADELINE ACEVEDO 

CAMACHO ET AL. 

(2,818 PLANTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLANTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

103072 $8,990,000.00*

MADELINE ACEVEDO 

CAMANCHO ET AL. 

(2818 PLAINTIFFS) 

(COLLECTIVELY THE 

"ACEVEDO CAMACHO 

PLAINTIFF GROUP"); 

CASP CASE NUM. 

2016-05-1340

LCDA. IVONNE 

GONZALEZ MORALES

PO BOX 9021828

SAN JUAN, PR 

00902-1828

06/04/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

32044 $50,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 32044 and 103072, which were filed on behalf of all plaintiffs in the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of 

Family Affairs, No. 2016-05-1340 (the “Acevedo Camacho Master Claims”), by the attorney representing plaintiffs in that litigation. The Acevedo Camacho Master Claims are filed on behalf of the DOFA 

employees who alleged that DOFA illegally sequestered wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that 

litigation, and his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 12

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 17 of 18
CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

CLAIMS TO BE DISALLOWED REMAINING CLAIMS

Four Hundred Ninety-Eighth Omnibus Objection

Exhibit A - Claims to Be Disallowed

CLAIM 

CLAIM # AMOUNT

CASE NUMBER / 

DEBTOR

DATE 

NAME FILED

 12 04/16/18 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

VAZQUEZ REYES, 7401 Undetermined*

KARIAM S

URB. ALTAGRACIA

CALLE RUISENOR 

1N-3

TOA BAJA, PR 00949

FRANCISCO BELTRAN 

ET AL (4,593 

PLAINTIFFS) 

COLLECTIVELLY (THE 

"BELTRAN CINTRON 

PLAINTIFF GROUP") 

CIVIL CASE NUM. K 

AC2009-0805/TSPR AC 

2016-0120

C/O IVONNE 

GONZALEZ-MORALES

ATTORNEY FOR 

BELTRAN CINTRON 

PLAINTIFF GROUP

P.O. BOX 9021828

SAN JUAN, PR 

00902-1828

06/29/18 17 BK 03566-LTS

Employees Retirement 

System of the Government 

of the Commonwealth of 

Puerto Rico

93199 $15,283,000.00*

FRANCISCO BELTRAN 

ET ALL (4,493 

PLAINTIFFS) 

COLLECTIVELY (THE 

BELTRAN CINTRON 

PLAINTIFF GROUP")...

ATTN: IVONNE 

GONZALEZ-MORALES

PO BOX 9021828

SAN JUAN, PR 00902

03/05/21 17 BK 03283-LTS

Commonwealth of Puerto 

Rico

179140 $105,000,000.00*

Reason: This claim is duplicative of Master Claim nos. 179140 and 93199, which were filed on behalf of all plaintiffs in the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family 

Affairs, No. KAC2009-0809 (the “Beltrán Cintrón Master Claims”), by the attorney representing plaintiffs in that litigation. The plaintiffs in the litigation are former Department of Family Affairs (“DOFA”) 

employees who alleged that DOFA withheld wages and pension payments as a result of the Office of Public Service Personnel’s “General Memorandum No. 5-86.” Claimant is a plaintiff in that litigation, and 

his/her claim asserts the above-referenced litigation and/or liabilities associated with this litigation as its basis.

*Indicates claim contains unliquidated and/or undetermined amounts 13

Case:17-03283-LTS Doc#:23338-1 Filed:01/25/23 Entered:01/25/23 13:05:23 Desc:

Exhibit A Page 18 of 18