IN THE 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

PROMESA

Title III

CASE NO.: 17 BK 3283-LTS

(Jointly Administered)

This filing relates to the 

Commonwealth, ERS, HTA, and 

PBA.

OPOSITION TO “FIVE HUNDRED SEVENTHIETH OMNIBUS 

OBJECTION (SUBSTANTIVE) OF THE COMMONWEATLH OF 

PUERTO RICO, THE EMPLOYEES RETIREMENT SUSTEM OF 

THE GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO, 

THE PUERTO RICO HIGHWAYS AND TRANSPORTATION AUTHORITY, 

AND THE PUERTO RICO PUBLIC BUILDINGS AUTHORITY TO 

CLAIMS FOR WICH THE DEBTORS ARE NOT LIABLE (DOCKET 24050)

TO THE HONORABLE COURT: 

COMES NOW, creditor AECOM Caribe, LLP (“AECOM”), by and through its 

undersigned counsel and very respectfully states and prays:

1. On June 29, 2818, creditor AECOM Caribe LLP filed its Proof of Claim in the amount of 

$243,5556.27. See Claim Number 104150. 

2. On April 20, 2023, the Commonwealth of Puerto Rico (hereinafter, the “Commonwealth”), 

the Employees Retirement System of the Government of the Commonwealth of Puerto Rico 

(hereinafter, “ERS”), the Puerto Rico Highways and Transportation Authority (“HTA”), all 

together hereinafter referred to as the “Debtors”, by and through the Financial Oversight and 

Management Board for Puerto Rico (hereinafter, the “Oversight Board”), as sole Title III 

representative pursuant to Section 315(b) of the Puerto Rico Oversight, Management, and 

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Economic Stability Act (hereinafter, “PROMESA”), filed before this Honorable Court its Five 

Hundred Seventieth omnibus objection to claims that seek recovery claiming that Debtor is not 

liable for said claims.

3. Debtor’s legal base for its objections is the Federal Rule of Bankruptcy Procedure 3007 

(d)(1)-(7), in addition to other substantive bases set forth in the Amended Omnibus Objection 

Procedures.

4. Federal Rule 3007 (d)(1)-(7) states the following.

(d) Omnibus Objection. Subject to subdivision (e), objections to more than one 

claim may be joined in an omnibus objection if all the claims were filed by the 

same entity, or the objections are based solely on the grounds that the claims 

should be disallowed, in whole or in part, because:

(1) they duplicate other claims;

(2) they have been filed in the wrong case;

(3) they have been amended by subsequently filed proofs of claim;

(4) they were not timely filed;

(5) they have been satisfied or released during the case in accordance with the 

Code, applicable rules, or a court order;

(6) they were presented in a form that does not comply with applicable rules, and 

the objection states that the objector is unable to determine the validity of the claim 

because of the noncompliance;

(7) they are interests, rather than claims; or

5. In its motion, Debtors assert that, upon a reasonable review of the Debtors’ records, the 

invoices underlying AECOM’s claim have either been satisfied, do not provide a valid basis or 

support for asserting a claim against the Debtors, or no longer represent a valid outstanding liability 

of the Debtors. Therefore, Debtors request from this Honorable Court to disallow AECOM claim 

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because it does not represent a valid debt of the Debtor and no amounts are due under 

Commonwealth law.

6. In its proof claim filed on June 29, 2018, AECOM provided sufficient evidence of the 

existence of Debtor’s liability. Notwithstanding this, jointly with this motion AECOM provides 

further evidence of Debtor's liability.

7. In its objection, Debtor does not address AECOM’s proof of claim supporting evidence

and why it is insufficient to prove Debtor’s indebtedness toward the appearing party. Debtor’s

objection rely solely on a statement, a generical allegation, that a reasonable review on the 

agency’s books and records, there are no outstanding liabilities associated with these invoices in 

the agency system. The documentation provided by AECOM proves otherwise.

8. It is hornbook law that a party who alleges that there is no outstanding liabilities associated

with a invoice, it must produce evidence of payment. Debtor has failed to produce any evidence 

whatsoever that contest AECOM’s claim.

9. It is respectfully requested from this Honorable Court to deny Debtor’s Five Hundred 

Seventieth omnibus objection to claims that seek recovery claiming that Debtor is not liable for 

said claims Omnibus Objection

WHEREFORE, creditor AECOM prays this Court to take notice of the abovementioned 

and deny Debtor’s objection to Claim #104150.

RESPECTUFLLY SUBMITTED.

In San Juan, Puerto Rico, on this 22nd day of June 2023.

CERTIFICATE OF ELECTRONIC FILING AND SERVICE

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I HEREBY CERTIFY that on this date copy of this motion has been electronically filed 

with the Clerk of the Court using the CM/ECF system which will send notification of such filing 

to all CM/ECF participants.

ARVELO & VÁZQUEZ, P.S.C.

301 Recinto Sur

Suite 701

San Juan, Puerto Rico 00901

Tel. (787) 721-7255

s/ Pedro E. Vázquez Meléndez

PEDRO E. VÁZQUEZ MELÉNDEZ

USDC-PR. 221712

pvazquez@avlawpr.com

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