EXHIBIT 31

Case:17-03283-LTS Doc#:23987-31 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 31 Page 1 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

5/JUNE/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:19886 Filed:01/21/22 Entered:01/25/22 14:57:45 Desc: Main

Document Page 1 of 2

RESPONSE TO OMNIBUS OBJECTION

Page 1 of 2

I. CONTACT INFORMATION

Name: Yazmín Martínez Cole

Mailing Address: #30 C/ Juan C. Borbón Apt. 311

Guaynabo P.R. 00969-5320

Contact Phone Home: Cell (787) 390-1439

Claim #: 177243

II. Caption

A. Clerk’s Office

United States District Court

Room 150 Federal Building

San Juan Puerto Rico 00918-1767

B. Commonwealth of Puerto Rico et al. (Debtors)

C. Case Number: 17 BK 3283 – LTS

D. Omnibus Objection regarding amounts not paid by the Commonwealth of Puerto Rico:

Evidence by proof of claim numbers:

#49762 – Act 89 – Romerazo – Effective July 1, 1995

Act 89 – Uniform Compensation – Effective 1979

#94057 –June 6, 2008 Pay Scale Act – Step Increases

#96621 – Act 96 (2002) of Dr. Pedro Rosello – effective July 2002

 Act 164 (2004) of Ms. Sila Calderón – effective January 2004

III. The court should not grant the Omnibus Objection, because these amounts are owed based on 

the following laws passed by the government of the Commonwealth of Puerto Rico:

Act 89 “Romerazo” – Effective July 1, 1995

Act 89 – Uniform Compensation – Effective 1979

June 6, 2008 Pay Scale Act – Step Increases

Act 96 (2002) of Dr. Pedro Rosello – effective July 2002

Act 164 (2004) of Ms. Sila M. Calderón, effective January 2004

Case:17-03283-LTS Doc#:23987-31 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 31 Page 2 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

5/JUNE/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:19886 Filed:01/21/22 Entered:01/25/22 14:57:45 Desc: Main

Document Page 2 of 2

Page 2 of 2

IV. Supporting Documentation

Enclosed are documents evidencing the years of service with the Puerto Rico Telephone Company,

S.J., Puerto Rico, from the 16th of May of 1988 through the 14th of January of 2002. I ended my 

career as a Wireless Service Sales Consultant II with

Puerto Rico Telephone Company, S.J., Puerto Rico, Commonwealth. Claim is made under the 

applicable laws that cover these years of educational service.

Enclosed are documents in support of this claim.

Due to the recent emergency situation in Puerto Rico brought on by earthquakes and COVID-19, the 

responses are being sent on today’s date. Please contact me should any additional information or 

documents be needed.

Yazmín Martínez Cole

Printed name

 [signature] 01/17/22

Signature

P.S.

In 1988 I became a regular employee of the Communications Corporation of P.R. (CCPR). This 

agency belonged to the Commonwealth of P.R. (i.e., the government) and was merged in 1994 with 

the Puerto Rico Telephone Company (PRTC), also an agency that belonged to the Commonwealth 

of P.R. It was not until 1999 that the governor in office at the time, Dr. Pedro Roselló, sold it and it 

became private.

The basis of my claim is that under the laws mentioned above on the first page of this document, I 

am owed money according to the dates when these were created and while I worked for the (CCPR) 

and (PRTC), as mentioned here.

This is money owed based on wage increases. For this reason, I do not agree with my petition being 

dismissed.

I thank you for your consideration of this matter. Sincerely,

[signature]

YMC

YMC

Case:17-03283-LTS Doc#:23987-31 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 31 Page 3 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

5/JUNE/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:19886-1 Filed:01/21/22 Entered:01/25/22 14:57:45 Desc:

Exhibit Page 1 of 1

CERTIFICATION

YAZMIN MARTINEZ COLE

XXX-XX-4018

For the former employee referenced above, we certify the following:

 She joined CCPR effective 05/16/1988.

 She joined PRT/Claro effective 05/05/1994.

 She worked as a regular employee through 01/14/2002.

This certification confirms that the information was obtained from our personnel information 

system. In Guaynabo, Puerto Rico, on Wednesday, October 7, 2020.

[signature]

Abigail Alejandro González

Abigail Alejandro González

Compensation Officer

Compensation and Records

Case:17-03283-LTS Doc#:23987-31 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 31 Page 4 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

5/JUNE/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:19886-2 Filed:01/21/22 Entered:01/25/22 14:57:45 Desc:

Envelope Page 1 of 1

Case:17-03283-LTS Doc#:23987-31 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 31 Page 5 of 6
TRANSLATOR’S CERTIFICATE OF TRANSLATION

Translation from: Spanish (Puerto Rico) into English (US)

TARGEM Translations Inc.

I, Andreea I. Boscor, ATA-certified Spanish-English #525556, acting as translator at TARGEM Translations Inc., a NEW 

YORK City corporation, with its principal office at 185 Clymer Street, Brooklyn, NY, 11211, USA, certify that:

the English translated document is a true and accurate translation of the original Spanish and has been translated to 

the best of my knowledge.

Original Document Name: Claim No. 177243 DN 19886

 

Signed this 5th of June 2022 

__________________________ 

 Andreea I. Boscor

Case:17-03283-LTS Doc#:23987-31 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 31 Page 6 of 6