EXHIBIT 38

Case:17-03283-LTS Doc#:23987-38 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 38 Page 1 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

13/JULY/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:21238 Filed:06/13/22 Entered:06/14/22 12:23:20 Desc: Main

Document Page 1 of 2

[handwritten:] # 177513

RESPONSE TO OMNIBUS OBJECTION

I. CONTACT INFORMATION

Name: Carmen Alicia Santiago Duco

[stamp:] RECEIVED 2022 JUN 13 [illegible]

Mailing Address Urb. Parque del Rio Calle Yahueca

 Casa A-16 Caguas, PR 00725

 

Contact Home Phone: 787-743-0192 Cell 

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 129 – 1973 Pay raise

Act 89 – 1979 - Uniform Compensation

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

#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 129 – 1973 Pay raise

Act 89 – 1979 - Uniform Compensation

Act 89 “Romerazo” – Effective July 1, 1995

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#:23987-38 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 38 Page 2 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

13/JULY/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:21238 Filed:06/13/22 Entered:06/14/22 12:23:20 Desc: Main

Document Page 2 of 2

IV. Supporting Documentation

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

Ponce, Puerto Rico, from the 24th of August of 1971 through the 1

st

 of March of 1999 . I 

ended my career as a Regular PRTC Employee with the Puerto Rico 

Telephone Company, Ponce Caguas, Puerto Rico, Commonwealth. Claim is made under the 

applicable laws that cover these years of educational 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.

Carmen A. Santiago Duco

Printed name

 [signature]

Signature

PS

To whom it may concern:

I will tell you a bit more, I am Carmen Alicia Santiago Duco, I began working August 24, 1971 CCPR of 

the Commonwealth of Puerto Rico, and I ended my career on March 1, 1999 at the PRTC of the 

Commonwealth of Puerto Rico. I am making this claim because I know that it is unfair for them to say 

that I am not in said claim for laws that were passed during the period I worked for the Commonwealth of 

Puerto Rico. When I began at the agency that at the time was called the Communication Authority of the 

Commonwealth of Puerto Rico, later its name was changed to the communication corporation of the 

Commonwealth of Puerto Rico in 1974, when I began at the agency, later the name was changed to the 

PRTC of the Commonwealth of Puerto Rico. I worked for the PRTC for 28 years, during that time I 

qualified for three of the Laws. Act 124-1973 pay raise, Act 89-1979 Uniform compensation,

Act 89-1995 The Romerazo,

said laws were enacted while I was working for the PRTC of the Commonwealth of Puerto Rico.

For these reasons, I do not agree with my claim being cancelled, because the basis or reasons for my 

claims relate to money owed under certain laws that were enacted during the period that the PRTC of the 

Commonwealth of Puerto Rico was an agency that belonged to the Commonwealth of Puerto Rico.

Thank you for your attention.

Sincerely,

Case:17-03283-LTS Doc#:23987-38 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 38 Page 3 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

13/JULY/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:21238-1 Filed:06/13/22 Entered:06/14/22 12:23:20 Desc:

Exhibit Page 1 of 1

CERTIFICATION

CARMEN ALICIA SANTIAGO DUCOS

XXX-XX-2102

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

➢ She joined CCPR effective 08/24/1971.

➢ She joined PRT/Claro effective 05/05/1994.

➢ She worked as a regular employee through 03/01/1999.

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

system. In Guaynabo, Puerto Rico, on 6/2/2022.

Abigail Alejandro

González

Abigail Alejandro González

Compensation Officer

Compensation and Records

Case:17-03283-LTS Doc#:23987-38 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 38 Page 4 of 6
Certified to be a correct and true translation from the source text in Spanish to the target language English.

13/JULY/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

Case:17-03283-LTS Doc#:21238-2 Filed:06/13/22 Entered:06/14/22 12:23:20 Desc:

Envelope Page 1 of 1

Case:17-03283-LTS Doc#:23987-38 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 38 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. 177513 DN 21238

Signed this 13

th of July 2022

__________________________

Andreea I. Boscor

Case:17-03283-LTS Doc#:23987-38 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 38 Page 6 of 6