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)

Re: ECF Nos. 24191 and 24186.

This filing relates to the 

Commonwealth.

MOTION SUBMITTING CERTIFIED TRANSLATION IN CONNECTION WITH THE 

OBJECTION OF THE COMMONWEALTH OF PUERTO RICO TO PROOF OF 

CLAIM (CLAIM NO. 70324) OF EMPRESAS OMAJEDE, INC. AND TO MOTION FOR 

ALLOWANCE AND PAYMENT OF ADMINISTRATIVE EXPENSE CLAIM 

PURSUANT TO 11 U.S.C. § 503

To the Honorable United States District Judge Laura Taylor Swain:

The Commonwealth of Puerto Rico (the “Commonwealth”), by and through the Financial 

Oversight and Management Board for Puerto Rico (the “Oversight Board”), as sole representative 

of the Commonwealth pursuant to section 315(b) of the Puerto Rico Oversight, Management, and 

Economic Stability Act (“PROMESA”)2, hereby respectfully states as follows: 

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).

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

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1. On May 10, 2023, the Commonwealth filed the Objection of the Commonwealth of 

Puerto Rico to Proof of Claim (Claim No. 70324) of Empresas Omajede, Inc. and to Motion for 

Allowance and Payment of Administrative Expense Claim Pursuant to 11 U.S.C. § 503 [ECF No. 

24186] (the “Objection”). In support of the arguments in the Objection, the Commonwealth 

attached as Exhibits F and G thereto an opinion dated November 15, 2021, issued by the Court of 

Appeals of Puerto Rico in connection with Case No. KLCE202101045, which is in an uncertified 

translation into English and in its original Spanish language (the “Opinion”), respectively. 

2. On that same day, the Commonwealth filed a motion requesting leave to file the 

Opinion in the Spanish language and three business days, until May 16, 2023, to provide the Court 

with a certified English-language translation of the Opinion. See ECF No. 24187.

3. On May 11, 2023, the Court entered an order granting the Commonwealth until 

May 16, 2023, to file a certified translation of the Opinion to the English language. See ECF No. 

24191.

4. In compliance with the Court’s May 11, 2023 order, attached hereto as Exhibit A

is a certified translation to the English language of the Opinion.

[Remainder of Page Intentionally Left Blank]

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WHEREFORE, the Commonwealth respectfully requests the Court take notice of the filing 

of this certified translation in compliance with the Court’s orders. 

Dated: May 15, 2023 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

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

/s/ Brian S. Rosen

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

Attorneys for the Financial 

Oversight and Management Board 

for Puerto Rico, as representative of 

the Commonwealth of Puerto Rico

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