Exhibit A 

Proposed Order 

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

Exhibit A Page 1 of 7
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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 SIXTY-SECOND 

OMNIBUS OBJECTION (NON-SUBSTANTIVE) OF THE COMMONWEALTH OF 

PUERTO RICO TO DEFICIENT ADR CLAIMS 

Upon the Five Hundred Sixty-Second Omnibus Objection (Non-Substantive) of 

Commonwealth of Puerto Rico to Deficient ADR Claims (the “Five Hundred Sixty-Second 

Omnibus Objection”),2 filed by the Commonwealth of Puerto Rico (the “Commonwealth” or the 

“Objecting Debtor”), dated January 27, 2023, for entry of an order disallowing in their entirety 

certain claims filed against the Objecting Debtor, as more fully set forth in the Five Hundred SixtySecond Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to 

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-BK3283-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). 

2

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

in the Five Hundred Sixty-Second Omnibus Objection. 

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

Exhibit A Page 2 of 7
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consider the Five Hundred Sixty-Second 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 Sixty-Second Omnibus Objection 

having been provided to those parties identified therein, and no other or further notice being 

required; and each the claims identified in Exhibit A to the Five Hundred Sixty-Second Omnibus 

Objection (the “Claims to Be Disallowed”) having been found to be deficient; and the Court having 

determined that the relief sought in the Five Hundred Sixty-Second Omnibus Objection is in the 

best interests of the Objecting Debtor, its creditors, and all parties in interest; and the Court having 

determined that the legal and factual bases set forth in the Five Hundred Sixty-Second Omnibus 

Objection establish just cause for the relief granted herein; and after due deliberation and sufficient 

cause appearing therefor, it is hereby 

 ORDERED that the Five Hundred Sixty-Second 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 registry in the Title III Cases; and it is further 

ORDERED that this Order resolves Docket Entry No. 23424 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. 

 SO ORDERED. 

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

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Dated: 

 

 Honorable Judge Laura Taylor Swain 

 United States District Judge 

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

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EXHIBIT A

Schedule of Claims Subject to the Five Hundred Sixty-Second Omnibus Objection 

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

Exhibit A Page 5 of 7
Five Hundred Sixty-Second Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 ANDUJAR NIEVES, VIVIAN E 06/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 105256

P.O. BOX 330-306 ATOCHA STATION

PONCE, PR 00733-0306

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

 2 DELGADO RODRIGUEZ, LUZ 05/31/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 42272

HC 01 BOX 6558

LAS PIEDRAS, PR 00771

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

 3 PAGAN, EAST J. 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 82761

URB. ISLAZUL

3323 CALLE BELIZE

ISABELA, PR 00662

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

 4 RAMOS SOTO, DAVID 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 68979

16 ARISTIDES MAISONAVE

MOCA, PR 00676

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

Exhibit A Page 6 of 7
Five Hundred Sixty-Second Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 5 RIVERA CRUZ, JOHANNA 06/07/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 49599

URB. PATIOS DE REXUILLE

PC 4 CALLE 21 A

BAYAMON, PR 00957

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

 6 RIVERA QUINONES, EILEEN JANET 05/10/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 13733

PO BOX 560244

GUAYANILLA, PR 00656

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

 7 SANTIAGO CINTRON, IRMA 06/08/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 49364

HC 1 BOX 5280

JUANA DIAZ, PR 00795

Undetermined*

Reason: Proof of Claim purports to assert liabilities associated with outstanding litigations; however, neither the proof of claim nor supporting documentation provided enough 

information for the Debtors to understand whether any liabilities are owed by the Debtors. The Debtors have made multiple attempts to contact claimant by email, mail, and/or 

telephone, but claimant either has not responded to Debtors’ requests, or claimant’s response still does not provide enough information to enable the Debtors to understand whether any 

liabilities are owed.

TOTAL Undetermined*

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23901-1 Filed:03/30/23 Entered:03/30/23 16:03:50 Desc:

Exhibit A Page 7 of 7