EXHIBIT 13

Case:17-03283-LTS Doc#:23987-13 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 13 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#:20133 Filed:02/14/22 Entered:02/15/22 11:24:41 Desc: Main

Document Page 1 of 2

RESPONSE TO OMNIBUS OBJECTION

I. CONTACT INFORMATION

Name: Marina Crispín Santiago

Mailing Address P.O. Box 987

 Luquillo, PR 00773

 

Contact Phone Home: Cell 347-514-0242

 Claim Number: 176233

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:

 Act 124 – 1973 Wage Increase

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

 Act 89 – 1979 Uniform Compensation

#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 124 – 1973 Wage Increase

Act 89 “Romerazo” – Effective July 1, 1995

 Act 89 – 1979 Uniform Compensation

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#:23987-13 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 13 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#:20133 Filed:02/14/22 Entered:02/15/22 11:24:41 Desc: Main

Document Page 2 of 2

IV. Supporting Documentation

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

Fajardo, Puerto Rico, from the 28th of October of 1971 through the 1st of May of 1992. I ended my 

career as a Supervisor

with the Puerto Rico Telephone Company, Fajardo, Puerto Rico, Commonwealth. Claim is made 

under the applicable laws that cover these years of 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.

Marina Crispín Santiago

Printed name

 [signature]

Signature

PS: The PRTC was an agency of the government until 1999, when it was sold by the 

governor in office at the time and it became a private agency.

My claim is based on money owed for wage increases under laws that were enacted 

during the years that the PRTC belonged to the Commonwealth.

I hope you will consider my claim.

Sincerely,

[signature]

Case:17-03283-LTS Doc#:23987-13 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 13 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#:20133-1 Filed:02/14/22 Entered:02/15/22 11:24:41 Desc:

Exhibit Page 1 of 1

CERTIFICATION

MARINA CRISPIN SANTIAGO

XXX-XX-1838

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

 She joined PRT/Claro effective 10/28/1971.

 She worked as a regular employee through 05/01/1992.

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

system. In Guaynabo, Puerto Rico, on Saturday, September 12, 2020.

Abigail Alejandro González

Abigail Alejandro González

Compensation Officer

Compensation and Records

Case:17-03283-LTS Doc#:23987-13 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 13 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#:20133-2 Filed:02/14/22 Entered:02/15/22 11:24:41 Desc:

Envelope Page 1 of 1

Case:17-03283-LTS Doc#:23987-13 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 13 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. 176233 DN 20133

 

Signed this 5th of June 2022 

__________________________ 

 Andreea I. Boscor

Case:17-03283-LTS Doc#:23987-13 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 13 Page 6 of 6