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. 24157, 24154, 

24103, 23621, 23612, and 21326.

This filing relates only to HTA

MOTION SUBMITTING CERTIFIED TRANSLATION IN CONNECTION WITH THE 

PUERTO RICO HIGHWAYS AND TRANSPORTATION AUTHORITY’S 

(1) OPPOSITION TO (A) MOTION REQUESTING PAYMENT OF SEVERANCE 

DAMAGES [ECF NO. 23612], AND (B) AMENDED PETITION REQUESTING 

PAYMENT OF SEVERANCE DAMAGES [ECF NO. 24103], AND (2) REPLY TO 

RESPONSE FILED BY CLAIMANT ADRIÁN MERCADO JIMÉNEZ [ECF NO. 21326] 

IN CONNECTION WITH THE FOUR HUNDRED FIFTY-FOURTH OMNIBUS 

OBJECTION (NON-SUBSTANTIVE) TO SATISFIED CLAIMS

To the Honorable United States District Judge Laura Taylor Swain:

The Puerto Rico Highways and Transportation Authority (“HTA”), by and through the 

Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”), as sole 

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).

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representative of HTA pursuant to section 315(b) of the Puerto Rico Oversight, Management, and 

Economic Stability Act (“PROMESA”)2, hereby respectfully states as follows: 

1. On May 5, 2023, HTA filed The Puerto Rico Highways and Transportation 

Authority’s (1) Opposition to (A) Motion Requesting Payment of Severance Damages [ECF No. 

23612], and (B) Amended Petition Requesting Payment of Severance Damages [ECF No. 24103], 

and (2) Reply to Response Filed by Claimant Adrían Mercado Jiménez [ECF No. 21326] in 

Connection with the Four Hundred Fifty-Fourth Omnibus Objection (Non-Substantive) to 

Satisfied Claims [ECF No. 24153] (the “Objection”). In support of the arguments in the Objection, 

HTA attached as Exhibit 2 thereto the Judgment dated May 31, 2019, issued by the Commonwealth 

Court of Appeals in connection with Case K EF2011-0240, in its original Spanish language (the 

“Judgment”).

2. On that same day, HTA filed a motion requesting leave to file the Judgment in the 

Spanish language and three business days, until May 10, 2023, to provide the Court with a certified 

translation of the Judgment. See [ECF No. 24154].

3. On May 8, 2023, the Court entered an order granting HTA until May 10, 2023 to 

file a certified translations of the Judgment to the English language. See [ECF No. 24157].

4. Attached hereto as Exhibit A is a certified translation to the English language of 

the Judgment.

[Remainder of Page Intentionally Left Blank]

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

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WHEREFORE, HTA respectfully requests the Court take notice of the filing of this 

certified translation in compliance with the Court’s orders. 

Dated: May 10, 2023 Respectfully submitted,

San Juan, Puerto Rico

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla García-Benítez

USDC No. 203708

Gabriel A. Miranda

USDC No. 306704

O’NEILL & BORGES LLC

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice)

Brian S. Rosen (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 of 

the Puerto Rico Highways and 

Transportation Authority 

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CERTIFICATE OF SERVICE

I hereby certify that, on this same date, I electronically filed the foregoing with the Clerk 

of the Court using the CM/ECF system, which will send notifications of such filing to all CM/ECF 

participants in this case.

/s/ Hermann D. Bauer

Hermann D. Bauer

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