UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

FINANCIAL OVERSIGHT AND 

ADMINISTRATION BOARD FOR 

PUERTO RICO,

 As a representative of the

COMMONWEALTH OF PUERTO RICO et 

al.,

Debtors.

PROMESA

Title III

Number 17BK 3283-LTS

(Jointly administered)

RESPONSE TO THE FIVE HUNDRED SEVENTY-SEVENTH OMNIBUS OBJECTION

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO, THE

EMPLOYEES RETIREMENT SYSTEM OF THE GOVERNMENT OF THE

COMMONWEALTH OF PUERTO RICO, AND THE PUERTO RICO HIGHWAYS

AND TRANSPORTATION AUTHORITY TO CLAIMS FOR WHICH THE DEBTORS

ARE NOT LIABLE

To the Honorable United States Court Judge Laura Taylor Swain:

The group of plaintiffs under the case Maggie Acevedo Sepúlveda et al. V. Department of 

Health of Puerto Rico, before the Public Service Appellate Commission (CASP), under number 

2000-06-1639, Case before the Supreme Court of Puerto Rico CC-2012-1050, file this reply to 

the forty-seventieth global objection and respectfully state the following:

1. Mrs. Daisy Charon Santiago, claim # 27404, member of the group of Plaintiff under the 

case Maggie Acevedo Sepúlveda et al. V. Department of Health of Puerto Rico, before 

the Public Service Appellate Commission (CASP), under number 2000-06-1639, Case 

before the Supreme Court of Puerto Rico CC-2012-1050, contacted us about the 

OMNIBUS OBJECTION we’re responding on this Motion, in which this Honorable 

Court asks her to response before May 22, 2023 if they have a claim in the case at hand.

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2. Upon analysis of our records, Mrs. Charon Santiago is part of our group, although she

wasn’t included on our exhibit when we presented RESPONSE TO THE FOUR 

HUNDRED SEVENTY-SEVENTH OMNIBUS OBJECTION (SUBSTANTIVE) OF 

THE COMMONWEALTH OF PUERTO RICO AND THE EMPLOYEES 

RETIREMENT SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO TO ACEVEDO SEPÚLVEDA 

LITIGATION CLAIMS.

3. This was a typographical error on our part and, therefore, Mrs. Daisy Charon Santiago, 

must be included as member of our group of plaintiffs.

WHEREFORE, the group of plaintiffs under the Maggie Acevedo Sepúlveda et al. V. 

Department of Health of Puerto Rico respectfully requests that this honorable court deny the 

FIVE HUNDRED SEVENTY-SEVENTH OMNIBUS OBJECTION (SUBSTANTIVE) OF 

THE COMMONWEALTH OF PUERTO RICO, THE EMPLOYEES RETIREMENT SYSTEM 

OF THE GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO, AND THE 

PUERTO RICO HIGHWAYS AND TRANSPORTATION AUTHORITY TO CLAIMS FOR 

WHICH THE DEBTORS ARE NOT LIABLE on all parts related to Mrs. Daisy Charon 

Santiago, update record so that she is included on the group of plaintiffs under the case Maggie 

Acevedo Sepúlveda et al. V. Department of Health of Puerto Rico, before the Public Service 

Appellate Commission (CASP), under number 2000-06-1639, Case before the Supreme Court of 

Puerto Rico CC-2012-1050 grand grant any other remedy deemed just.

RESPECTFULLY SUBMITTED.

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I HEREBY CERTIFY that on this date I electronically filed the foregoing with the Clerk of the 

Court using the CM/ECF system which will send notification of such filing to all participants of 

the CM/ECF system including the Trustee and Debtors’ counsel.

Dated: May 8, 2023

Ponce, Puerto Rico /s/ Santiago A. Iturregui Del Toro

Santiago A. Iturregui Del Toro

USDC No.225006

P.O. Box 7341

Ponce, Puerto Rico 00732-7341

saiturregui@gmail.com

(787) 298-8155

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