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)

NOTICE OF WITHDRAWAL OF THE THREE HUNDRED SEVENTY-FOURTH

OMNIBUS OBJECTION [ECF NO. 17923] WITH RESPECT TO 

CLAIM NOS. 128602, 140498, AND 161458

To the Honorable United States District Judge Laura Taylor Swain:

1. On August 20, 2021, the Commonwealth of Puerto Rico (the “Commonwealth”), 

the Puerto Rico Sales Tax Financing Authority (“COFINA”), the Puerto Rico Highways and 

Transportation Authority (“HTA”), the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico (“ERS”), and the Puerto Rico Public Buildings Authority (“PBA,” 

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

 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 (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”) (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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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 filed the Three Hundred SeventyFourth Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico, Puerto Rico Sales 

Tax Financing Corporation, Puerto Rico Highways and Transportation Authority, Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico, and Puerto Rico 

Public Buildings Authority to Late-Filed Claims [ECF No. 17923] (the “Three Hundred SeventyFourth Omnibus Objection”).

2. In light of additional information received since the filing of the Three Hundred 

Seventy-Fourth Omnibus Objection, the Debtors respectfully withdraw, without prejudice, the 

Three Hundred Seventy-Fourth Omnibus Objection, solely with respect to Proofs of Claim Nos. 

128602, 140498, and 161458 (collectively, the “Subject Claims”).

3. The Debtors reserve their right to object to the Subject Claims on any other grounds 

whatsoever.

[Remainder of Page Intentionally Left Blank]

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

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Dated: February 2, 2022 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-Rivera

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

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico, the Puerto Rico Sales Tax 

Financing Corporation, the Puerto Rico 

Highways and Transportation Authority, the 

Employees Retirement System of the 

Government of the Commonwealth of Puerto 

Rico, and the Puerto Rico Public Buildings 

Authority

/s/ Martin J. Bienenstock

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

Co-Attorneys for the Financial Oversight 

and Management Board for Puerto Rico, as 

representative for the Commonwealth of 

Puerto Rico, the Puerto Rico Sales Tax 

Financing Corporation, the Puerto Rico 

Highways and Transportation Authority, the 

Employees Retirement System of the 

Government of the Commonwealth of Puerto 

Rico, and the Puerto Rico Public Buildings 

Authority

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