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, ERS, HTA, and 

PBA. 

REPLY 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 THE 

RESPONSE FILED BY MIRIAM SANCHEZ LEBRON [ECF NO. 21075] TO THE FOUR 

HUNDRED SIXTY-FIFTH OMNIBUS OBJECTION (SUBSTANTIVE) TO CLAIMS 

FOR WHICH THE DEBTORS ARE NOT LIABLE 

To the Honorable United States District Court Judge Laura Taylor Swain: 

The Commonwealth of Puerto Rico (the “Commonwealth”), the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico (“ERS”), the Puerto Rico 

Highways and Transportation Authority (“HTA”), and the Puerto Rico Public Buildings Authority 

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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(“PBA,” and together with the Commonwealth, ERS, and HTA, the “Debtors”), by and through 

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

Title III representative of the Debtors pursuant to Section 315(b) of the Puerto Rico Oversight, 

Management, and Economic Stability Act (“PROMESA”),2 file this reply (the “Reply”) to the 

response [Case No. 17-BK-3283-LTS, ECF No. 21075]3 (the “Response”) filed by claimant 

Miriam Sanchez Lebron (“Sanchez Lebron”) 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] (the “Four Hundred Sixty-Fifth Omnibus Objection”). In support of 

this Reply, the Objecting Debtors respectfully represent as follows: 

1. On May 18, 2018, Sanchez Lebron filed a proof of claim against the 

Commonwealth in an undetermined amount, and it was logged by Kroll Restructuring 

Administration LLC as Proof of Claim No. 17230 (the “Commonwealth Claim”). The 

Commonwealth Claim asserts liabilities purportedly arising out of Sanchez Lebron’s alleged 

ownership of land held by the Commonwealth and various municipalities. 

2. On May 5, 2020, Sanchez Lebron filed a proof of claim against the PBA in an 

undetermined amount, logged by Kroll Restructuring Administration LLC as Proof of Claim No. 

173831 (the “PBA Claim,” and together with the Commonwealth Claim, the “Sanchez Lebron 

Claims”). The PBA Claim also asserts liabilities purportedly arising out of Sanchez Lebron’s 

alleged ownership of land held by the PBA and various municipalities. 

2

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

3

 Unless otherwise stated herein, ECF citations refer to documents filed in Bankruptcy Case 

No. 17-BK-3283-LTS. 

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3. The Four Hundred Sixty-Fifth Omnibus Objection sought to disallow, among other 

claims, the Sanchez Lebron Claims because they seek recovery of amounts for which the Debtors 

are not liable. Sanchez Lebron contends she owns certain land held by the Commonwealth, PBA, 

and various municipalities, but the supporting documentation provided with the Sanchez Lebron 

Claims fails to provide a valid basis for asserting liability against the Commonwealth, PBA, or any 

other Title III debtor. 

4. Any party who disputed the Four Hundred Sixty-Fifth Omnibus Objection was 

required to file a response by 4:00 p.m. (Atlantic Standard Time) on June 13, 2022 in accordance 

with the Court-approved notice attached to the Four Hundred Sixty-Fifth Omnibus Objection as 

Exhibit C, which was served in English and Spanish on the individual creditors subject to the Four 

Hundred Sixty-Fifth Omnibus Objection, the U.S. Trustee, and the Master Service List (as defined 

in the Sixteenth Amended Notice, Case Management and Administrative Procedures [ECF No. 

20190-1]). See Certificate of Service [ECF No. 21011]. 

5. On May 27, 2022, Sanchez Lebron filed the Response. The Response asserts that 

the “Court of General Justice of Puerto Rico” has not disclosed certain resolutions that would 

establish Sanchez Lebron’s rightful ownership of land held by the Commonwealth, PBA, and 

various municipalities, and requests the Oversight Board obtain the allegedly withheld 

resolutions.4 The Response attaches (1) an “Estate Partition and Adjudication Deed,” and (2) a 

Declaration of Heirs of Eladio Lebrón, filed in Puerto Rico Superior Court, Humacao Division, 

On June 24, 1955 (the “Resolution”), see id. at 10–11. The Resolution, which Sanchez Lebron 

asserts to be one of three such resolutions (the other two being allegedly withheld), declares, 

4

 To the extent the Response asks this court for an order requiring the Oversight Board to obtain 

the allegedly withheld resolutions, it fails to provide any basis for such relief, and on that basis 

the Court should deny the request. 

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among others, Juana Lebron Perez as Eladio Lebron’s heir. Neither the Estate Partition and 

Adjudication Deed nor the Resolution demonstrate, however, that Sanchez Lebron is the lawful 

owner of the land she claims. 

6. Sanchez Lebron further asserts her “civil and constitutional rights” have been 

violated, id. at 2, but, she has not identified any specific actions taken by the Debtors giving rise 

to such a claim, and accordingly, she has not established a basis for any recovery in respect of 

these violations. Accordingly, to the extent the Sanchez Lebron Claims assert liabilities arising 

out of purported violations of Sanchez Lebron’s “civil and constitutional rights,” they should be 

disallowed. 

7. For the foregoing reasons, the Debtors respectfully request the Court grant the Four 

Hundred Sixty-Fifth Omnibus Objection and disallow the Sanchez Lebron Claims. 

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Dated: April 11, 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 for 

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

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