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)

NOTICE OF WITHDRAWAL OF OBJECTION TO PROOF OF CLAIM NO. 74306 

SUBJECT TO THE THREE HUNDRED NINETY-FIRST OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO TO PARTIALLY 

SATISFIED AND PARTIALLY NO LIABILLITY CLAIMS [ECF NO. 17974]

To The Honorable United States District Judge Laura Taylor Swain: 

1. On August 25, 2021, the Commonwealth of Puerto Rico (the “Commonwealth” or 

“Debtor”), by and through the Financial Oversight and Management Board for Puerto Rico (the 

“Oversight Board”), as sole Title III representative of the Debtors pursuant to section 315(b) of 

the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”),2 filed the 

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 (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”) (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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Three Hundred Ninety-First Omnibus Objection (Substantive) of the Commonwealth of Puerto 

Rico to Partially Satisfied and Partially No Liability Claims[ECF No. 17974] (the “Three Hundred 

Ninety-First Omnibus Objection”).

2. In light of additional information received since the filing of the Three Hundred 

Ninety-First Omnibus Objection, the Commonwealth respectfully withdraws, without prejudice, 

the Three Hundred Ninety-First Omnibus Objection, solely with respect to Proof of Claim No. 

74306 (the “Subject Claim”).

3. The Commonwealth reserves the right to object to the Subject Claim on any other 

grounds whatsoever.

[Remainder of Page Intentional Left Blank] 

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Dated: July 14, 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-Rivera

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 for the Commonwealth of 

Puerto Rico

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