Exhibit A 

Proposed Order 

Case:17-03283-LTS Doc#:23896-1 Filed:03/30/23 Entered:03/30/23 15:42:40 Desc:

Exhibit A Page 1 of 11
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. 

ORDER GRANTING FIVE HUNDRED FIFTY-FIFTH 

OMNIBUS OBJECTION (SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO 

RICO TO CLAIMS FOR WHICH THE DEBTOR IS NOT LIABLE 

Upon the Five Hundred Fifty-Fifth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Claims for which the Debtor Is Not Liable (the “Five Hundred 

Fifty-Fifth Omnibus Objection”)2 of the Commonwealth of Puerto Rico (the “Commonwealth” or 

“Objecting Debtor”), dated December 16, 2022, for entry of an order disallowing in their entirety 

certain claims filed against the Commonwealth, as more fully set forth in the Five Hundred Fifty1

 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-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,” 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) 

2

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

in the Five Hundred Fifty-Fifth Omnibus Objection. 

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Exhibit A Page 2 of 11
2

Fifth Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to 

consider the Five Hundred Fifty-Fifth 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 Five Hundred Fifty-Fifth 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 Five Hundred 

Fifty-Fifth Omnibus Objection (collectively, the “Claims to Be Disallowed”) having been found 

to be claims for which neither the Commonwealth nor any of the other Title III Debtors are liable; 

and the Court having determined that the relief sought in the Five Hundred Fifty-Fifth Omnibus 

Objection is in the best interest of the Commonwealth, its creditors, and all the parties in interest; 

and the Court having determined that the legal and factual bases set forth in the Five Hundred 

Fifty-Fifth Omnibus Objection establish just cause for the relief granted herein; and after due 

deliberation and sufficient cause appearing therefor, it is 

 ORDERED that the Five Hundred Fifty-Fifth Omnibus Objection is GRANTED as 

set forth herein; and it is further 

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

entirety; 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. 23090 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. 

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Exhibit A Page 3 of 11
3

Dated: 

 

 Honorable Judge Laura Taylor Swain 

 United States District Judge 

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Exhibit A Page 4 of 11
EXHIBIT A

Schedule of Claims Subject to the Five Hundred Fifty-Fifth Omnibus Objection 

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Exhibit A Page 5 of 11
Five Hundred Fifty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 COTTO CASTRO, PABLO J. 05/30/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 114498

HC 2 BOX 6281

GUAYANILLA, PR 00656-9708

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

 2 CRUZ LAFONTAINE, JUAN M. 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 30885

15 FIGERAS

JAYUYA, PR 00664

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

 3 CRUZ NUNEZ, FRANCISCO 03/14/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 2872

PO BOX 526

BAJADERO, PR 00616-0526

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

*Indicates claim contains unliquidated and/or undetermined amounts 1

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Exhibit A Page 6 of 11
Five Hundred Fifty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 4 CRUZ SANCHEZ, RUBEN D. 06/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 71402

PO BOX 346

ARROYO, PR 00714

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

 5 FAS RAMIREZ, JOSUE 06/05/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 46281

URB. MARTY BUZON #3

CABO ROJO, PR 00623

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigations captioned Juan Pérez Colón et al. v. Puerto Rico Department of Transportation & Public Works, Case No. 

KAC1990-0487 ("Pérez Colón”) and Jeannette Abrams Diaz et al. v. Department of Transportation & Public Works, Case No. KAC-2005-5021 (“Abrams Diaz"). However, based on 

documentation submitted by the attorneys representing all plaintiffs in those litigations, the claimant is not a named plaintiff in either litigation, and there is therefore no basis for the 

claimant to assert liabilities associated with either litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if the claimant were in fact a plaintiff in 

either litigation, the claim would be duplicative of the master proofs of claim filed on behalf of all plaintiffs associated with the Pérez Colón and Abrams Diaz litigations.

 6 FIGUEROA ORTIZ, MARIA D 05/16/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 16121

P O BOX 826

YABUCOA, PR 00767

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family Affairs, Case No. 

KAC-2009-0809 ("Beltrán Cintrón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that 

litigation, and there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, 

even if Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 179140 and 93199, the master proof of claims filed on behalf of all plaintiffs 

associated with the litigation captioned Beltrán Cintrón.

*Indicates claim contains unliquidated and/or undetermined amounts 2

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Exhibit A Page 7 of 11
Five Hundred Fifty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 7 GONZALEZ ZAYAL, RAFAEL 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 165332

URB. ESTANCIA DEL MAYORAL

CALLE COUBERAL BUZON 12106

VILLALBA, PR 00766

$17,000.00*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

 8 MONTALVO CASTRO, FERNANDO 05/15/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 15477

1542 AVE MIRAMAR

ARECIBO, PR 00612

$40,000.00*

Reason: Claim purports to assert liabilities associated with the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family Affairs, Case No. 

KAC-2009-0809 ("Beltrán Cintrón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that 

litigation, and there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, 

even if Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 179140 and 93199, the master proof of claims filed on behalf of all plaintiffs 

associated with the litigation captioned Beltrán Cintrón.

 9 ORTIZ SANTIAGO, SAMUEL 04/09/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 5390

HC 1 BOX 4336

AIBONITO, PR 00705

$1,072.00*

Reason: Claim purports to assert liabilities associated with the litigations captioned Juan Pérez Colón et al. v. Puerto Rico Department of Transportation & Public Works, Case No. 

KAC1990-0487 ("Pérez Colón”) and Jeannette Abrams Diaz et al. v. Department of Transportation & Public Works, Case No. KAC-2005-5021 (“Abrams Diaz"). However, based on 

documentation submitted by the attorneys representing all plaintiffs in those litigations, the claimant is not a named plaintiff in either litigation, and there is therefore no basis for the 

claimant to assert liabilities associated with either litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if the claimant were in fact a plaintiff in 

either litigation, the claim would be duplicative of the master proofs of claim filed on behalf of all plaintiffs associated with the Pérez Colón and Abrams Diaz litigations.

*Indicates claim contains unliquidated and/or undetermined amounts 3

Case:17-03283-LTS Doc#:23896-1 Filed:03/30/23 Entered:03/30/23 15:42:40 Desc:

Exhibit A Page 8 of 11
Five Hundred Fifty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 10 OTANO HERNANDEZ, ANGEL 05/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 24439

HC 01 BOX 4146

LARES, PR 00669

$30,000.00*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

11 PINTO GONZALEZ, ALFREDO 06/28/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 140364

303 CALLE VEREDA DEL PRADO

URB. LOS ARBOLES

CAROLINA, PR 00987

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family Affairs, No. 2016-05-1340 

(“Acevedo Camacho"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, and 

there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if Claimant 

were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 32044 and 103072, the master proof of claims filed on behalf of all plaintiffs associated with the 

litigation captioned Acevedo Camacho.

 12 QUINONES PINTO, ANGEL G 04/02/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 5731

BO LAS DOLORES

263 CALLE COLOMBIA

RIO GRANDE, PR 00745

$85,813.91*

Reason: Claim purports to assert liabilities associated with the litigation captioned Frente Unido de Policías Organizados et al. v. Puerto Rico Police Department, Case No. 

KAC-2007-4170 (“FUPO"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, 

and there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if 

Claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 161091, the master proof of claim filed on behalf of all plaintiffs associated 

with the litigation captioned "FUPO".

*Indicates claim contains unliquidated and/or undetermined amounts 4

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Exhibit A Page 9 of 11
Five Hundred Fifty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 13 RIVERA MARRERO, JOSE R 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 41805

URB COUNTRY CLUB

877 CALLE HYPOLIAS

SAN JUAN, PR 00924

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family Affairs, Case No. 

KAC-2009-0809 ("Beltrán Cintrón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that 

litigation, and there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, 

even if Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 179140 and 93199, the master proof of claims filed on behalf of all plaintiffs 

associated with the litigation captioned Beltrán Cintrón.

Claim #41805 also contained on Exhibit A to the 351st Omnibus Claims Objection for Claims to Be Partially Disallowed.

 14 ROSARIO COLLAZO, SILVERIO J. 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 33388

RES. FERNANDO LUIS GARCIA

EDI. 27 APT. 195

UTUADO, PR 00641

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Alfredo Maldonado Colón et al. v. Puerto Rico Department of Corrections & Rehabilitation, Case 

No. KAC-1996-1381 (“Maldonado Colón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, the claimant is not a named 

plaintiff in that litigation, and there is therefore no basis for the claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III 

debtor. Further, even if the claimant were in fact a plaintiff in that litigation, that portion of the claim would be duplicative of Claim no. 152372, the master proof of claim filed on 

behalf of all plaintiffs associated with the litigation captioned Maldonado Colón.

 15 VALENTIN TORRES, JULIO ANGEL 05/15/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 15400

URB. RIO CRISTAL C/ ROBERTO COLE 520

MAYAGUEZ, PR 00680

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigations captioned Juan Pérez Colón et al. v. Puerto Rico Department of Transportation & Public Works, Case No. 

KAC1990-0487 ("Pérez Colón”) and Jeannette Abrams Diaz et al. v. Department of Transportation & Public Works, Case No. KAC-2005-5021 (“Abrams Diaz"). However, based on 

documentation submitted by the attorneys representing all plaintiffs in those litigations, the claimant is not a named plaintiff in either litigation, and there is therefore no basis for the 

claimant to assert liabilities associated with either litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if the claimant were in fact a plaintiff in 

either litigation, the claim would be duplicative of the master proofs of claim filed on behalf of all plaintiffs associated with the Pérez Colón and Abrams Diaz litigations.

*Indicates claim contains unliquidated and/or undetermined amounts 5

Case:17-03283-LTS Doc#:23896-1 Filed:03/30/23 Entered:03/30/23 15:42:40 Desc:

Exhibit A Page 10 of 11
Five Hundred Fifty-Fifth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 16 VAZQUEZ MARTINEZ, MITCHELL 06/05/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 35228

CANA

DD-1 CALLE 29

BAYAMON, PR 00957

$223,200.00*

Reason: Claim purports to assert liabilities associated with the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family Affairs, No. 2016-05-1340 

(“Acevedo Camacho"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, and 

there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if Claimant 

were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 32044 and 103072, the master proof of claims filed on behalf of all plaintiffs associated with the 

litigation captioned Acevedo Camacho.

TOTAL $397,085.91*

*Indicates claim contains unliquidated and/or undetermined amounts 6

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Exhibit A Page 11 of 11