EXHIBIT 10

Case:17-03283-LTS Doc#:19998-10 Filed:02/02/22 Entered:02/02/22 18:09:44 Desc:

Exhibit Exhibit 10 Page 1 of 5
Case:17-03283-LTS Doc#:18327 Filed:09/30/21 Entered:09/30/21 15:18:24 Desc:

Main

Document Page 1 of 3

Certified to be a correct and true translation from the source text in Spanish to the target language English.

15/DECEMBER/2021 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

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, COFINA, HTA, 

ERS, and PBA.

Response

Acting on my own behalf and in consult with counsel, I wish to respond the information that has 

been given, to the effect that my claim was not submitted within the stipulated deadlines and that 

it was made after the deadline set by the ruling In response, this assertion is incorrect, since our 

legal representative sent a document dated May 24, 2018, as well as evidence that the procedure 

was done on said date. If you need additional information, you may request it via email addressed 

to our legal representative ealvaradofrias@torresvalentin.com. 

A. Vargas Noriega, Iván L., Judith Vargas García,

Janitza Noriega Vargas. Tel (787)-619-8287

J-2 C-1 Jardines de Caparra, Bayamón PR

00959

E-mail: Gaviotaesnumero1@yahoo.com

Eva Alvarado Frias – Attorney and Legal Representative

Tel (787)-733-7575

B. Omnibus Objection

Reasons Not [sic] to Object to the Omnibus Objection

The court should not grant the omnibus objection in relation to my claim for the following reasons:

It is not true that my claim was not submitted within the stipulated deadlines and that the claim was 

made after the applicable deadline set by the ruling on deadlines. My claim was sent by our legal 

representative on May 24, 2018, along with proof of claim. Our attorney is Mrs. Eva Alvarado 

Frias, and her phone number is (787)-753-7575. 

Case:17-03283-LTS Doc#:19998-10 Filed:02/02/22 Entered:02/02/22 18:09:44 Desc:

Exhibit Exhibit 10 Page 2 of 5
Case:17-03283-LTS Doc#:18327 Filed:09/30/21 Entered:09/30/21 15:18:24 Desc:

Main

Document Page 2 of 3

Certified to be a correct and true translation from the source text in Spanish to the target language English.

15/DECEMBER/2021 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

1. My name is Judith Vargas García. I am the mother of two special education children: 

Iván, a young man with autism, and Janitza, who has Attention Deficit Hyperactivity 

Disorder. I am a retired teacher with 25 years of service in education, currently disabled 

due to an accident in my home. I fought with all my might so that my children could 

have an effective education, which did not happen. The education in my country, 

Puerto Rico, is not good. There are two books currently in the hands of our legal 

counsel, with evidence of complaints about institutional abuse, school transportation 

issues, lack of teachers for years, bullying, teacher absenteeism, lack of therapy, lack 

of transportation to therapy sessions, lack of therapists, lack of academic staff, etc. I 

hereby authorize anyone who may be interested to ask our legal representative for 

information so that they may verify that this information is accurate, and how difficult 

it has been for me and my children not having an effective and fair education which, 

according to the law and our Constitution, everyone is entitled to a dignified, good, 

effective, and fair education.

2. We plead that this honorable court to do us justice, not to let them get away with it, no 

to let lies prevail, and to let the truth triumph. This claim was made on time and there 

is evidence of that.

3. My name is Judith Vargas. I am not a lawyer, but a mother, a teacher, a tireless fighter 

for my children, whose rights have been violated, and who have been humiliated and 

have suffered. They have not been provided with a decent education despite being 

entitled to receiving it. We are representing all special education children who have 

been denied the nurturing of schooling, and whose rights to receive an education has 

been violated.

4. We apologize to our honorable court for any unethical words.

C. Supporting Documentation

Justification

There is a large book for Iván L. Noriega and another one for Janitza Noriega, which include ample 

evidence of complaints related to bullying, psychological abuse, and all the other issues expressed 

above. You may request this information from our legal representative via email in order to 

complete this procedure. I do not have the books in my possession and therefore I cannot personally 

send you the information requested.

Case:17-03283-LTS Doc#:19998-10 Filed:02/02/22 Entered:02/02/22 18:09:44 Desc:

Exhibit Exhibit 10 Page 3 of 5
Case:17-03283-LTS Doc#:18327 Filed:09/30/21 Entered:09/30/21 15:18:24 Desc:

Main

Document Page 3 of 3

Certified to be a correct and true translation from the source text in Spanish to the target language English.

15/DECEMBER/2021 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

I, Judith Vargas Garcia, pursuant to Title 28 USC, 1746, hereby declare, under penalty of 

perjury, that the following [sic] is true and accurate to the best of my knowledge.

Signature: Date: September 17, 2021

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).

Case:17-03283-LTS Doc#:19998-10 Filed:02/02/22 Entered:02/02/22 18:09:44 Desc:

Exhibit Exhibit 10 Page 4 of 5
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. 158363 DN 18327

 

Signed this 15th day of December, 2021 

__________________________ 

 Andreea I. Boscor

Case:17-03283-LTS Doc#:19998-10 Filed:02/02/22 Entered:02/02/22 18:09:44 Desc:

Exhibit Exhibit 10 Page 5 of 5