Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

Exhibit A Page 1 of 7
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 FOUR HUNDRED NINETY-NINTH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH 

OF PUERTO RICO TO DUPLICATE LITIGATION CLAIMS AND UNNAMED 

PLAINTIFFS

Upon the Four Hundred Ninety-Ninth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Duplicate Litigation Claims and Unnamed Plaintiffs [ECF No. 

21756] (the “Four Hundred Ninety-Ninth Omnibus Objection”)2 filed by the Commonwealth of 

Puerto Rico (the “Commonwealth” or the “Debtor”), dated August 5, 2022, for entry of an order 

1 The Debtors in the 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)

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

in the Four Hundred Ninety-Ninth Omnibus Objection.

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

Exhibit A Page 2 of 7
2

disallowing in their entirety certain claims filed against the Commonwealth, as more fully set forth 

in the Four Hundred Ninety-Ninth Omnibus Objection and supporting exhibits thereto; and the 

Court having jurisdiction to consider the Four Hundred Ninety-Ninth 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 Four Hundred NinetyNinth Omnibus Objection having been provided to those parties identified therein, and no other or 

further notice being required; and the claims identified in the column titled “Claims to be 

Disallowed” in Exhibit A to the Four Hundred Ninety-Ninth Omnibus Objection (collectively, the 

“Claims to Be Disallowed”) having been found to be duplicative of the Litigation Master Claims, 

as defined in the Four Hundred Ninety-Ninth Omnibus Objection; and the Court having 

determined that the relief sought in the Four Hundred Ninety-Ninth Omnibus Objection is in the 

best interest of the Commonwealth, its creditors, and all the parties in interest; and the Court having 

determined that the legal and factual bases set forth in the Four Hundred Ninety-Ninth Omnibus 

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

cause appearing therefor, it is

ORDERED that the Four Hundred Ninety-Ninth 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 the Commonwealth’s right to object to the Litigation Master 

Claims is reserved; and it is further

ORDERED that Kroll is authorized and directed to designate the Claims to Be 

Disallowed as expunged on the official claims register in the Title III Cases; and it is further

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

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ORDERED that this Order resolves Docket Entry No. 21756 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.

Dated: 

 Honorable Judge Laura Taylor Swain

 United States District Judge 

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

Exhibit A Page 4 of 7
EXHIBIT A

Schedule of Claims Subject to the Four Hundred Ninety-Ninth Omnibus Objection 

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

Exhibit A Page 5 of 7
Four Hundred Ninety-Ninth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 BALBIN PADILLA, CYNTHIA 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 38507

URB LOS ALMENDROS

EB 5 CALLE TILO

BAYAMON, PR 00961

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family Affairs, No. 2016-05-1340 

(“Acevedo Camacho"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, and 

there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if Claimant 

were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 32044 and 103072, the master proof of claims filed on behalf of all plaintiffs associated with the 

litigation captioned Acevedo Camacho.

 2 CANDELARIO ORTIZ, ALBA L. 06/01/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 45925

HC 01 BOX 10240

TOA BAJA, PR 00949-9795

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family Affairs, Case No. 

KAC-2009-0809 ("Beltrán Cintrón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that 

litigation, and there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, 

even if Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 179140 and 93199, the master proof of claims filed on behalf of all plaintiffs 

associated with the litigation captioned Beltrán Cintrón.

 3 CHACON RODRIGUEZ, MAYRA 05/30/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 31054

URB MONTE VERDE

M 1303 CALLE MONTE GRANDE

MANATI, PR 00674

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family Affairs, No. 2016-05-1340 

(“Acevedo Camacho"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, and 

there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if Claimant 

were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 32044 and 103072, the master proof of claims filed on behalf of all plaintiffs associated with the 

litigation captioned Acevedo Camacho.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

Exhibit A Page 6 of 7
Four Hundred Ninety-Ninth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 4 CHACON RODRIGUEZ, MAYRA 05/30/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 42306

URB MONTE VERDE

M 1303 CALLE MONTE GRANDE

MANATI, PR 00674

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family Affairs, No. 2016-05-1340 

(“Acevedo Camacho"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, and 

there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if Claimant 

were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 32044 and 103072, the master proof of claims filed on behalf of all plaintiffs associated with the 

litigation captioned Acevedo Camacho.

 5 CRUZ QUINTERO, JUAN CARLOS 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 38069

CALLE JOSE JULIAN ACOSTA

H21 BO AMELIA

CATANO, PR 00962

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Francisco Beltrán Cintrón et al. v. Puerto Rico Department of Family Affairs, Case No. 

KAC-2009-0809 ("Beltrán Cintrón"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that 

litigation, and there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, 

even if Claimant were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 179140 and 93199, the master proof of claims filed on behalf of all plaintiffs 

associated with the litigation captioned Beltrán Cintrón.

 6 TORRES, GLENDAMID 06/11/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 79250

PO BOX 689

OROCOVIS, PR 00720

Undetermined*

Reason: Claim purports to assert liabilities associated with the litigation captioned Madeline Acevedo Camacho et al. v. Puerto Rico Department of Family Affairs, No. 2016-05-1340 

(“Acevedo Camacho"). However, based on documentation submitted by the attorney representing all claimants in the litigation, Claimant is not a named plaintiff in that litigation, and 

there is therefore no basis for claimant to assert liabilities associated with that litigation against the Commonwealth, HTA, ERS, or any other Title III debtor. Further, even if Claimant 

were in fact a plaintiff in that litigation, the claim would be duplicative of Claim nos. 32044 and 103072, the master proof of claims filed on behalf of all plaintiffs associated with the 

litigation captioned Acevedo Camacho.

TOTAL Undetermined*

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23339-1 Filed:01/25/23 Entered:01/25/23 13:08:50 Desc:

Exhibit A Page 7 of 7