Exhibit A

Proposed Order

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Proposed Order Page 1 of 12
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 and ERS.

ORDER GRANTING FIVE HUNDRED FORTY-FIRST OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO AND THE 

EMPLOYEES RETIREMENT SYSTEM OF THE GOVERNMENT OF THE 

COMMONWEALTH OF PUERTO RICO TO CLAIMS FOR WHICH THE OBJECTING 

DEBTORS ARE NOT LIABLE

Upon the Five Hundred Forty-First Omnibus Objection (Substantive) of the 

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

Puerto Rico to Claims for which the Objecting Debtors are Not Liable (the “Five Hundred FortyFirst Omnibus Objection”),2 filed by the Commonwealth of Puerto Rico (the “Commonwealth”), 

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

(“ERS,” and with the Commonwealth, the “Objecting Debtors”), dated October 28, 2022, for entry 

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-BK5523-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 used but not defined herein shall have the meanings ascribed to them in 

the Five Hundred Forty-First Omnibus Objection.

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2

of an order disallowing in their entirety certain claims filed against the Objecting Debtors, as more 

fully set forth in the Five Hundred Forty-First Omnibus Objection and supporting exhibits thereto; 

and the Court having jurisdiction to consider the Five Hundred Forty-First 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 Five Hundred Forty-First 

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 Five Hundred Forty-First Omnibus Objection (collectively, the “Claims to Be 

Disallowed”) having been found to be claims for which the Commonwealth and/or ERS are not 

liable; and the Court having determined that the relief sought in the Five Hundred Forty-First 

Omnibus Objection is in the best interest of the Objecting Debtors, their creditors, and all the parties 

in interest; and the Court having determined that the legal and factual bases set forth in the Five 

Hundred Forty-First Omnibus Objection establish just cause for the relief granted herein; and after 

due deliberation and sufficient cause appearing therefor, it is

ORDERED that the Five Hundred Forty-First 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 Kroll is authorized and directed to designate the Claims to Be 

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

ORDERED that this Order resolves Docket Entry No. 22745 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.

SO ORDERED.

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3

Dated: 

Honorable Judge Laura Taylor Swain

United States District Judge

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EXHIBIT A 

Schedule of Claims Subject to the Five Hundred Forty-First Omnibus Objection 

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 ANDRES VELEZ MUNIZ AND CONCEPCION PARADIS 06/27/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 164525

RIVERA

1702 CALLE SAN MATEO

SANTURCE

SAN JUAN, PR 00912

$9,794.10

Reason: The claimant was awarded $18,000 according to the stipulation agreement presented on 06/27/2014 in relation to case KDP-2012-1489. According to the Cosignment Motion 

dated 11/01/2016, $976.80 of the awarded amount was used to offset debts owed to the Department of Treasury. An additional 8,817.30 was offset against debts owed to the Municipal 

Revenue Collections Center (CRIM), which leaves a remaining amount of $8,205.90 owed to the claimant. The payment in this amount was issued to the claimant with check number 

0085654 on 11/1/2016. As such, there remains no existing liability to the Commonwealth of Puerto Rico.

 2 ANNA MARIA FINETTO BOLTZI, HERMINIO 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 41389

MARTINEZ TIVEDE

P.O. BOX 50198

TOA BAJA, PR 00950

$16,666.66*

Reason: Proof of claim purports to assert liability based on case number KDP-2009-1505, but the case has since been dismissed as it relates to the Commonwealth of Puerto Rico and 

the Puerto Rico Highways and Transportation Authority. As such, there is no further basis for liability.

 3 CARRIÓN LOZANO, DAPHNE I 05/23/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 18890

PO BOX 1589

CAROLINA, PR 00984

$100,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number FDP-2010-1066 but the case has since been dismissed and there is no further basis for liability.

*Indicates claim contains unliquidated and/or undetermined amounts 1

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 4 COMMUNICATION LEASING LEASING 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 30353

CORPORATION

ATTN: ANA ALBERTORIO

PO BOX 362526

SAN JUAN, PR 00936-2565

$28,214.00

Reason: Invoice(s) totaling $9,628.48 were paid via checks 00248972, 00285039, 00292432, 00296082, 00296289, 00296893, 00297294, 00004079, 00009588, 00010143, 00010234, 

00011682, 00012162, 00012197, 00013237, 00013340, 00013454, 00013765, 00014035, 00014886, 00015014, 00015391, 00015400, 00015621, 00015638, 00015778, 00015792, 

00015927, 00016213, 00016437, 00016618, 00017143, 00017287, 00017724, 00018036, 00018280, 00019242, 00019693, 00019772, 00019910, 00020141, 00020299, 00020438, 

00020938, 00021170, 00021250, 00021290, 00021929, and 00028034 on 05/04/2012, 04/14/2014, 08/26/2014, 11/18/2014, 12/01/2014, 12/29/2014, 01/26/2015, 08/04/2016, 

01/30/2017, 02/10/2017, 02/14/2017, 04/03/2017, 04/17/2017, 04/18/2017, 05/19/2017, 05/23/2017, 05/25/2017, 06/05/2017, 06/12/2017, 07/ 11/2017, 07/13/2017, 07/21/2017, 

07/21/2017, 07/31/2017, 07/31/2017, 08/08/2017, 08/08/2017, 08/16/2017, 08/22/2017, 08/30/2017, 09/14/2017, 10/25/2017, 10/30/2017, 11/16/2017, 12/08/2017, 12/19/2017, 

01/30/2018, 02/21/2018, 02/22/2018, 03/01/2018, 03/12/2018, 03/16/2018, 03/20/2018, 04/09/2018, 04/12/2018, 04/13/2018, 04/16/2018, 05/04/2018, and 11/09/2018. Additionally, 

invoice(s) totaling $1,773.00 fail to provide a basis for asserting a claim against Commonwealth of Puerto Rico. Proof of Claim and supporting documentation only show liability 

between Claimant and Municipality of Bayamon, which is not part of the Title III proceedings. Further, Proof of Claim purports to assert liabilities associated with the Commonwealth 

of Puerto Rico, but liabilities totaling $18,585.52 fail to provide sufficient supporting documentation for asserting the liabilities against the Commonwealth of Puerto Rico , such that the 

Debtors are unable to determine whether claimant has valid liabilities against the Commonwealth of Puerto Rico or any of the other Title III debtors. 

Claim #30353 also contained on Exhibit A to the 372nd Omnibus Claims Objection for Claims to Be Modified.

05/24/2018 17 BK 03566-LTS Employees Retirement System 26257

of the Government of the 

Commonwealth of Puerto Rico

 5 CORRES SOTO, MORAYMA

CONDO. PARQUE JULIANA APTO. 103

EDIF. 100

CAROLINA, PR 00987

$145,008.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #26257 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclasified, the 347th Omnibus Claims Objection for Claims to Be Reclassified, 

and the 547th Omnibus Claims Objection for Claims to Be Disallowed.

 6 CORRES SOTO, MORAYMA 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 44328

CONDO. PARQUE JULIANA

EDIF 100 APTO 103

CAROLINA, PR 00987

$475,200.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #44328 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclasified and the 547th Omnibus Claims Objection for Claims to Be Disallowed.

*Indicates claim contains unliquidated and/or undetermined amounts 2

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 7 CRUZ CARLO, JOSE M 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 28527

HC 66 BOX 10317

FAJARDO, PR 00738

$381,600.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #28527 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclasified, the 351st Omnibus Claims Objection for Claims to Be Partially 

Disallowed, and the 548th Omnibus Claims Objection for Claims to Be Disallowed.

05/24/2018 17 BK 03566-LTS Employees Retirement System 31462

of the Government of the 

Commonwealth of Puerto Rico

 8 CRUZ CARLO, JOSE M.

HC 66 BOX 10317

FAJARDO, PR 00738

$160,014.96*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #31462 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclasified, the 347th Omnibus Claims Objection for Claims to Be Reclassified, 

and the 351st Omnibus Claims Objection for Claims to Be Partially Disallowed.

 9 HERNANDEZ RIVERA, RAMON 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 29547

CALLE LAS FLORES #42

VISTA ALEGRE

BAYAMON, PR 00959

$641.31*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #29547 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclassified.

 10 JOHNSON ROSARIO, EVELYN 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 27751

VILLA CADIZ

424 CALLE OLOT

SAN JUAN, PR 00923

$400,248.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #27751 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclasified, the 547th Omnibus Claims Objection for Claims to Be Disallowed, and 

the 548th Omnibus Claims Objection for Claims to Be Disallowed.

*Indicates claim contains unliquidated and/or undetermined amounts 3

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

05/24/2018 17 BK 03566-LTS Employees Retirement System 28524

of the Government of the 

Commonwealth of Puerto Rico

11 JOHSON ROSARIO, EVELYN J

424 CALLE OLOT VILLA CADIZ

SAN JUAN, PR 00923

$126,578.88*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #28524 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclasified, the 347th Omnibus Claims Objection for Claims to Be Reclassified, 

and the 547th Omnibus Claims Objection for Claims to Be Disallowed.

05/24/2018 17 BK 03566-LTS Employees Retirement System 25267

of the Government of the 

Commonwealth of Puerto Rico

 12 LIMERY DONES, ABRAHAM

C/ LEILA U-20

URB. LEVITOWN

TOA BAJA, PR 00949

$122,319.72*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #25267 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclasified, the 347th Omnibus Claims Objection for Claims to Be Reclassified, 

and the 351st Omnibus Claims Objection for Claims to Be Partially Disallowed.

 13 LIMERY DONES, ABRAHAM 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 28721

URB LEVITTOWN

U20 CALLE LEILA

TOA BAJA, PR 00949

$316,800.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #28721 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclasified, the 351st Omnibus Claims Objection for Claims to Be Partially 

Disallowed, and the 547th Omnibus Claims Objection for Claims to Be Disallowed.

 14 MELENDEZ, SANTIAGO NUNEZ 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 31418

RR-37 BOX 5140 CALLE ROMANY

SAN JUAN, PR 00926

$491,400.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #31418 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclassified and the 351st Omnibus Claims Objection for Claims to Be Partially 

Disallowed.

*Indicates claim contains unliquidated and/or undetermined amounts 4

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 15 MONTANEZ JOHNSON, GLENDA J 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 29525

URBOPEN LAND

424 CALLE OLOT

SAN JUAN, PR 00923

$108,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #29525 also contained on Exhibit A to the 345th Omnibus Claims Objection for Claims to Be Reclasified, the 547th Omnibus Claims Objection for Claims to Be Disallowed, and 

the 548th Omnibus Claims Objection for Claims to Be Disallowed.

 16 ORTIZ PEREZ, DIANA M. 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 30739

URB RIO HONDO I

D 39 CALLE RIO CAONILLAS

BAYAMON, PR 00961

$12,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2018-02-0453, but the case has since been voluntarily withdrawn by the claimant and there is no further 

basis for liability.

05/24/2018 17 BK 03566-LTS Employees Retirement System 45764

of the Government of the 

Commonwealth of Puerto Rico

 17 PEREZ PENALOZA, ZHADYA P

RR 2 BOX 252

CAROLINA, PR 00987

$60,179.76*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #45764 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclasified, the 347th Omnibus Claims Objection for Claims to Be Reclassified, 

and the 351st Omnibus Claims Objection for Claims to Be Partially Disallowed.

 18 PEREZ PENALOZA, ZHADYA P 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 25578

RR 2 BOX 252

CAROLINA, PR 00987

$151,200.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #25578 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclassified and the 351st Omnibus Claims Objection for Claims to Be Partially 

Disallowed.

*Indicates claim contains unliquidated and/or undetermined amounts 5

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 19 RIVERA HERNANDEZ, ZAIDA 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 31346

4U 17 ALTOS CALLE LAGRUMO

LOMAS VERDES

BAYAMON, PR 00956

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #31346 also contained on Exhibit A to the 547th Omnibus Claims Objection for Claims to Be Disallowed.

 20 RIVERA LOPEZ, FRANCISCO J 05/21/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 13118

27 CALLE CORREO

CAMUY, PR 00627-2342

$14,300.00

Reason: Invoice totaling $13,200.00 was paid via EFTs 198301, 198304, 210614, 210618, 210619, 210620, 210621, 272633, 272634, 272635, 272636, and 272637 on 07/20/2020, 

07/20/2020, 09/04/2020, 09/04/2020, 09/04/2020, 09/04/2020, 09/04/2020, 05/17/2021, 05/17/2021, 05/17/2021, 05/17/2021, and 05/17/2021. Per the books and records of the 

Commonwealth, invoice totaling $1,100.00 was associated with amounts that were outside of the approved contract, where no contract was in place or where the invoices were never 

received and therefore are not due and owed by the Commonwealth agency asserted.

05/24/2018 17 BK 03566-LTS Employees Retirement System 27607

of the Government of the 

Commonwealth of Puerto Rico

 21 RODRIGUEZ CARDI, ENEROLIZA

CALLE RAFAEL ALONZO TORRES #1765

SAN JUAN, PR 00921

$161,191.44*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #27607 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclasified, the 347th Omnibus Claims Objection for Claims to Be Reclassified, 

and the 351st Omnibus Claims Objection for Claims to Be Partially Disallowed.

 22 RODRIGUEZ CARDI, ENEROLIZA 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 31424

CALLE RAFAEL ALONZO TORRES #1765

SAN JUAN, PR 00921

$691,200.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #31424 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclassified and the 351st Omnibus Claims Objection for Claims to Be Partially 

Disallowed.

*Indicates claim contains unliquidated and/or undetermined amounts 6

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Five Hundred Forty-First Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 23 TRUJILLO PLUMEY, ROSAMAR 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 29473

COND. TIERRA DEL SOL APT 122

HUMACAO, PR 00791

$453,600.00*

Reason: Proof of claim purports to assert liability on the basis of case number 2016-10-0546, but the claimant does not appear as a named plaintiff in that litigation.

Claim #29473 also contained on Exhibit A to the 347th Omnibus Claims Objection for Claims to Be Reclasified and the 548th Omnibus Claims Objection for Claims to Be Disallowed.

TOTAL $4,426,156.83*

*Indicates claim contains unliquidated and/or undetermined amounts 7

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