Exhibit A

Proposed Order

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 1 of 11
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.

ORDER GRANTING FIVE HUNDRED SIXTEENTH OMNIBUS OBJECTION 

(SUBSTANTIVE) OF THE COMMONWEALTH OF PUERTO RICO TO CLAIMS FOR 

WHICH THE COMMONWEALTH IS NOT LIABLE

Upon the Five Hundred Sixteenth Omnibus Objection (Substantive) of the 

Commonwealth of Puerto Rico to Claims for which the Commonwealth is Not Liable [ECF No. 

22253] (the “Five Hundred Sixteenth Omnibus Objection”),2 filed by the Commonwealth of Puerto 

Rico (the “Commonwealth”), dated September 16, 2022, for entry of an order disallowing in their 

entirety certain claims filed against the Commonwealth, as more fully set forth in the Five Hundred 

Sixteenth Omnibus Objection and supporting exhibits thereto; and the Court having jurisdiction to 

consider the Five Hundred Sixteenth Omnibus Objection and to grant the relief requested therein 

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 Sixteenth Omnibus Objection.

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 2 of 11
2

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 Sixteenth 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 

Sixteenth Omnibus Objection (collectively, the “Claims to Be Disallowed”) having been found to 

be claims for which the Commonwealth is not liable; and the Court having determined that the 

relief sought in the Five Hundred Sixteenth Omnibus Objection is in the best interest of the 

Commonwealth, its creditors, and all the parties in interest; and the Court having determined that 

the legal and factual bases set forth in the Five Hundred Sixteenth 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 Sixteenth 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. 22253 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.

Dated: 

Honorable Judge Laura Taylor Swain

United States District Judge

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 3 of 11
EXHIBIT A 

Schedule of Claims Subject to the Five Hundred Sixteenth Omnibus Objection 

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Exhibit A Proposed Order Page 4 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 1 BIOIMAGENES MEDICAS 05/28/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 24807

BIOPLAZA BUILDING

2638 HOSTOS AVE., SUITE 101

CARR #2 KM. 150.3

BO. ALGARROBO

MAYAGÜEZ, PR 00682

$47,230.91

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 2 CAMERA MUNDI INC 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 18172

PO BOX 6840

CAGUAS, PR 00726-6840

$15,601.90

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 3 CAMERA MUNDI INC 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 23226

PO BOX 6840

CAGUAS, PR 00726-6840

$25.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

 4 CARLOS FLORES CE & L FIRE EXTINGUISHERS 05/07/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 11075

PO BOX 3092

BAYAMON, PR 00960

Undetermined*

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

*Indicates claim contains unliquidated and/or undetermined amounts 1

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 5 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 5 CONSOLIDATED WASTE SERVICES 05/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 22556

PO BOX 1322

GURABO, PR 00778

$24,965.97

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 6 CONSOLIDATED WASTE SERVICES 05/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 30912

PO BOX 1322

GURABO, PR 00778

$446.16

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $246.16 in the agency's system. Additionally, invoice totaling $200.00 was paid via EFT 00089334 on 07/05/2018.

 7 CONSOLIDATED WASTE SERVICES 05/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 50208

PO BOX 1322

GURABO, PR 00778

$2,876.95

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with invoices 0000165861, 0000165863, 0000165864, 0000165865, 0000165866, 0000165867, 0000326958, 0000334693, 0000334694, 

0000335713, and 0000340206 in the agency's system. Claim #50208 also contained on Exhibit A to the 391st Omnibus Claims Objection for Modified Claims.

 8 DAT@ACCESS 05/07/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 10764

HÉCTOR FIGUEROA-VINCENTY, ESQ.

310 CALLE SAN FRANCISCO

SUITE 32

SAN JUAN, PR 00901

$2,032.80

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

*Indicates claim contains unliquidated and/or undetermined amounts 2

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 6 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 9 DAT@ACCESS 05/07/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 10765

HÉCTOR FIGUEROA-VINCENTY, ESQ.

310 CALLE SAN FRANCISCO

SUITE 32

SAN JUAN, PR 00901

$14,009.18

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 10 DAT@ACCESS COMMUNICATIONS, INC 05/04/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 9442

HECTOR FIGUEROA-VINCENTY ESQ.

310 CALLE SAN FRANCISCO

SUITE 32

SAN JUAN, PR 00901

$51,559.26

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $35,114.26 in the agency's system. Additionally, invoice totaling $16,445.00 was paid via check 2473 on 

06/26/2018.

11 DJ AIR GROUP CORP 05/30/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 29793

PO BOX 10403

SAN JUAN, PR 00922

$51,946.50

Reason: Proof of claim purports to assert liability on the basis of submitted invoices and purchase orders. Based on a declaration attesting to a reasonable review of the agency's books 

and records, there are no outstanding liabilities associated with the invoice or purchase order totaling $1,132.50 in the agency's system. Additionally, invoices totaling $26,730.00 were 

paid via check 83309 on 05/24/2018. The remaining liabilities totaling $24,084.00 are duplicative to claim 173934.

 12 DUST CONTROL SERVICES OF P.R. INC. 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 111557

PO BOX 362048

SAN JUAN, PR 00936-2048

$2,556.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $1,470.00 in the agency's system. Additionally, invoices totaling $1,086.00 were paid via checks 00186556, 

00187609, 00194543, 00195798, 00197876, 00198824, 00202196, 00202872, 00204175, 00204979, and 00238607 on 03/19/2009, 04/17/2009, 07/23/2009, 08/20/2009, 10/09/2009, 

10/29/2009, 01/22/2010, 01/28/2010, 02/12/2010, 02/25/2010, and 11/03/2011.

*Indicates claim contains unliquidated and/or undetermined amounts 3

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 7 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 13 DUST CONTROL SERVICES OF P.R., INC. 06/29/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 137438

P. O. BOX 362048

SAN JUAN, PR 00936-2048

$25.25

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

 14 GREATAMERICA FINANCIAL SERVICES 02/19/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 501

CORPORATION

ATTN: PEGGY UPTON

PO BOX 609

CEDAR RAPIDS, IA 52406

$29,800.30*

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

 15 LANDFILL TECHNOLOGIES OF FAJARDO 05/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 27807

PO BOX 1322

GURABO, PR 00778

$2,168.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices totaling $1,628.00 in the agency's system. Additionally, invoice totaling $540.00 was paid via check 00135659 on 

04/06/2017.

 16 MILLER & CHEVALIER CHARTERED 05/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 22059

900 16TH ST NW

WASHINGTON, DC 20006-2901

$154,508.75

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system. Claim #22059 also contained on Exhibit A to the 391st Omnibus Claims Objection for Modified 

Claims.

*Indicates claim contains unliquidated and/or undetermined amounts 4

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Exhibit A Proposed Order Page 8 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 17 NATIONAL ASSOCIATION OF STATE BUDGET 05/10/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 11506

OFFICERS

444 N. CAPITOL ST. NW

WASHINGTON, DC 20001

$5,600.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

 18 NETWAVE EQUIPMENT CO. 05/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 17379

HÉCTOR FIGUEROA-VINCENTY, ESQ.

310 CALLE SAN FRANCISCO

SUITE 32

SAN JUAN, PR 00901

$6,000.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

 19 NETWAVE EQUIPMENT CO. 05/03/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 9021

HÉCTOR FIGUEROA-VINCENTY, ESQ.

310 CALLE SAN FRANCISCO

SUITE 32

SAN JUAN, PR 00901

$16,200.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 20 QUEST DIAGNOSTICS OF PUERTO RICO, INC. 06/25/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 86557

CAPARRA GALLERY CALLE ORTEGON #107 LOCAL 

105

GAUYNABO, PR 00966

$63.20

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

*Indicates claim contains unliquidated and/or undetermined amounts 5

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Exhibit A Proposed Order Page 9 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 21 RAMOS PIZARRO, ERIEL E 05/24/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 20539

URB LA ALAMEDA

800 ESMERALDA STREET

SAN JUAN, PR 00926-5818

$7,980.00

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 22 RODRIGUEZ RODRIGUEZ, FELIX 07/03/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 152644

CITY OFFICE SUPPLIES

PO BOX 1669

BAYAMON, PR 00960

$1,782.30

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

 23 RODRIGUEZ RODRIGUEZ, FELIX 07/03/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 154213

CITY OFFICE SUPPLIES

PO BOX 1669

BAYAMON, PR 00960

$1,120.80

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 24 RODRIGUEZ RODRIGUEZ, FELIX 07/03/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 154522

CITY OFFICE SUPPLIES

PO BOX 1669

BAYAMON, PR 00960

$8,699.45

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

*Indicates claim contains unliquidated and/or undetermined amounts 6

Case:17-03283-LTS Doc#:23358-1 Filed:01/25/23 Entered:01/25/23 17:05:25 Desc:

Exhibit A Proposed Order Page 10 of 11
Five Hundred Sixteenth Omnibus Objection

Exhibit A - Claims to Be Disallowed

NAME DATE FILED DEBTOR CLAIM #

ASSERTED CLAIM 

CASE NUMBER AMOUNT

 25 RODRIGUEZ RODRIGUEZ, FELIX 07/03/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 154950

CITY OFFICE SUPPLIES

PO BOX 1669

BAYAMON, PR 00960

$3,181.08

Reason: Proof of claim purports to assert liability on the basis of submitted invoices. Based on a declaration attesting to a reasonable review of the agency's books and records, there 

are no outstanding liabilities associated with these invoices in the agency's system.

 26 TRAFON GROUP, INC. 06/22/2018 17 BK 03283-LTS Commonwealth of Puerto Rico 49492

JUAN R. RIVERA FONT

27 GONZALEZ GIUSTI

SUITE 602

GUAYNABO, PR 00968

$949.24

Reason: Proof of claim purports to assert liability on the basis of submitted invoice. Based on a declaration attesting to a reasonable review of the agency's books and records, there are 

no outstanding liabilities associated with this invoice in the agency's system.

TOTAL $451,329.00*

*Indicates claim contains unliquidated and/or undetermined amounts 7

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Exhibit A Proposed Order Page 11 of 11