Exhibit A 

Proposed Order 

Case:17-03283-LTS Doc#:23900-1 Filed:03/30/23 Entered:03/30/23 15:59:46 Desc:

Exhibit A Page 1 of 10
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 SIXTIETH 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 Sixtieth 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 (the “Five 

Hundred Sixtieth Omnibus Objection”),2 filed by the Commonwealth of Puerto Rico (the 

“Commonwealth”) and the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico (“ERS,” and with the Commonwealth, “Objecting Debtors”), dated 

January 27, 2023, for entry of an order disallowing in their entirety certain claims filed against 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 (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 Sixtieth Omnibus Objection. 

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Exhibit A Page 2 of 10
2 

Objecting Debtors, as more fully set forth in the Five Hundred Sixtieth Omnibus Objection and 

supporting exhibits thereto; and the Court having jurisdiction to consider the Five Hundred Sixtieth 

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 Sixtieth 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 Sixtieth 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 

Sixtieth 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 Sixtieth 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 Sixtieth 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. 23423 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. 

 

Case:17-03283-LTS Doc#:23900-1 Filed:03/30/23 Entered:03/30/23 15:59:46 Desc:

Exhibit A Page 3 of 10
3 

SO ORDERED. 

Dated: 

 

Honorable Judge Laura Taylor Swain 

United States District Judge 

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Exhibit A Page 4 of 10
EXHIBIT A

Schedule of Claims Subject to the Five Hundred Sixtieth Omnibus Objection 

Case:17-03283-LTS Doc#:23900-1 Filed:03/30/23 Entered:03/30/23 15:59:46 Desc:

Exhibit A Page 5 of 10
Five Hundred Sixtieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 ALICEA, JENNIFER 05/23/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 19589

PO BOX 363901

SAN JUAN, PR 00936-3901

$139,968.58

Reason: Information provided states that the claim is related to case SJ2020CV06210, which was withdrawn by the creditor on 02/25/2022.

06/29/2018 17 BK 03566-LTS Employees Retirement System 126174

of the Government of the 

Commonwealth of Puerto Rico

 2 BATISTA SERRANO, ENID M.

HC-01 BOX 1070-M

ARECIBO, PR 00612

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

Claim #126174 also contained on Exhibit A to the 337th Omnibus Claims Objection for Claims to Be Reclassified.

 3 CAPPA DELGADO, NANCY 06/20/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 74612

P.O. BOX 336433

PONCE, PR 00733-6433

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

 4 COLON MALDONADO, CARMEN G 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 80160

CALLE 3 H-3 FOREST HILL

BAYAMON, PR 00959

$3,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number KAC-2003-4295, but the case has since been dismissed and there is no further basis for liability.

 5 COOPERATIVA DE SEGUROS MULTIPLES DE PUERTO 05/23/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 20364

RICO

HECTOR E. VALDES ORTIZ, ESQ.

8461 LAKE WORTH ROAD

SUITE 420

LAKE WORTH, FL 33467

$1,500.00*

Reason: Proof of claim purports to assert liability on the basis of case number ISCI-2015-1067, but the case has since been withdrawn by the claimant and there is no further basis for 

liability.

*Indicates claim contains unliquidated and/or undetermined amounts 1

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Exhibit A Page 6 of 10
Five Hundred Sixtieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 6 COOPERATIVA DE SEGUROS MULTIPLES DE PUERTO 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 24242

RICO

HECTOR E. VALDES ORTIZ, ESQ.

8461 LAKE WORTH ROAD, SUITE 420

LAKE WORTH, FL 33467

$8,038.90

Reason: Proof of claim purports to assert liability on the basis of property seized through asset forfeiture but the books and records of the Commonwealth indicate that the seized 

property has been returned and there is no further basis for liability.

 7 DAT@ACCESS COMUNICATIONS INC. 06/01/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 34656

HÉCTOR FIGUEROA-VINCENTY

310 CALLE SAN FRANCISCO

SUITE 32

SAN JUAN, PR 00901

$63,000.00

Reason: Invoice(s) totaling $15,750.00 were paid via EFT 00048329 on 08/14/2017. Additionally, proof of claim purports to assert liabilities associated with the Commonwealth of 

Puerto Rico, but liabilities totaling $47,250.00 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.

 8 GUZMAN CORTES, CARMEN 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 115088

BO MORA GUERRERO

BUZON 289 CALLE 7

ISABELA, PR 00662

$2,400.00*

Reason: Proof of claim purports to assert liability on the basis of case number KAC-2003-4295, but the case has since been dismissed and there is no further basis for liability.

 9 LOPEZ RIVERA, MARIA DEL C. 06/26/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 94315

APARTADO 957

VILLALBA, PR 00766

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

*Indicates claim contains unliquidated and/or undetermined amounts 2

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Exhibit A Page 7 of 10
Five Hundred Sixtieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 10 MENDEZ PEREZ, GEORGINA 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 150864

URB COLINAS

G 4 CALLE 6

YAUCO, PR 00698

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of case number KAC-2003-4295, but the case has since been dismissed and there is no further basis for liability.

11 ORTIZ ORTIZ, MARGARITA R 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 147932

RR 2 BOX 7104

GUAYAMA, PR 00784

$12,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

 12 PEREZ RODRIGUEZ, MARIBEL 06/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 81136

PUEBLO NUEVO C # 22

YAUCO, PR 00698

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of case number KAC-2003-4295, but the case has since been dismissed and there is no further basis for liability.

 13 PEREZ TORRES, ELIZABETH 06/26/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 93765

URB. SANTA ELEANA 2

B-16 CALLE ORIQUIDEA

GUAYANILLA, PR 00656

$10,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number KAC-2003-4295, but the case has since been dismissed and there is no further basis for liability.

 14 ROBLES RODRIGUEZ, CARLOS LUIS 09/20/2019 17 BK 03283-LTS Commonwealth of Puerto Rico 170820

BO LOS CROABAS CARR 987

HC67 BOX 21591

FAJARDO, PR 00738

$13,800.00

Reason: Proof of claim purports to assert liability on the basis of case number NSCI-2003-00282, but the case has since been dismissed and there is no further basis for liability.

*Indicates claim contains unliquidated and/or undetermined amounts 3

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Exhibit A Page 8 of 10
Five Hundred Sixtieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 15 ROBLES RODRIGUEZ, RODOLFO 09/20/2019 17 BK 03283-LTS Commonwealth of Puerto Rico 170834

HC 67 BOX 21591

BO LAS CROABAS CARR 987

FAJARDO, PR 00738-9499

$16,200.00

Reason: Proof of claim purports to assert liability on the basis of case number NSCI-2003-00282, but the case has since been dismissed and there is no further basis for liability.

 16 RODRIGUEZ LEON, RUTH I 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 73329

6602 DOREL STREET

PHILADELPHIA, PA 19142

$11,498.00*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

 17 RODRIGUEZ RAMOS, ISMAEL 06/27/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 63539

6 NOBLEZA V. ESPERANZA

CAGUAS, PR 00727

$8,594.09*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

 18 ROSADO MORALES, AYMEE DEL C. 06/05/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 46213

YADIRA ADORNO DELGADO

1605 AVE. PONCE DE LEON STE 600

SAN JUAN, PR 00909

$1,350,000.00*

Reason: Proof of claim purports to assert liability on the basis of case number FBCI-2010-01417, but the case has since been dismissed and there is no further basis for liability.

 19 TOLEDO TORRES, JULYSBETTE D. 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 65152

PO BOX 1989

HATILLO, PR 00659

$1,500.00

Reason: Proof of claim purports to assert liability on the basis of case number KAC-2003-4295, but the case has since been dismissed and there is no further basis for liability.

*Indicates claim contains unliquidated and/or undetermined amounts 4

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Exhibit A Page 9 of 10
Five Hundred Sixtieth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 20 TORRES ROSADO, JULIO 06/27/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 54400

PO BOX 100 43 CIDRA, PUERTO RICO 00739

CIDRA, PR 00739

$12,375.00*

Reason: Proof of claim purports to assert liability on the basis of case number SJ-2017-CV-00542, but a judgment has since been issued withdrawing the claimant from the case. 

Therefore, there is no further basis for liability.

 21 URBINA REYES, GLORIMAR 05/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 18424

URB L'ANTIGUA CALLE 4 VIA PARIS LH-105

TRUJILLO ALTO, PR 00976

$61,000.00*

Reason: Proof of claim purports to assert liability on the basis of an arbitration proceeding against the Commonwealth regarding accrued but unpaid wages and/or pension, but the 

administrative case is closed, and no amounts were owed as part of the resolution. Additionally, Proof of Claim asserts liability on the basis of a tax refund. The records of the 

Department of Treasury show such refund has been paid in full.

TOTAL $1,714,874.57*

*Indicates claim contains unliquidated and/or undetermined amounts 5

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Exhibit A Page 10 of 10