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, ERS and PBA 

NOTICE OF CORRESPONDENCE REGARDING THE FOUR HUNDRED 

FOURTEENTH OMNIBUS OBJECTION (SUBSTANTIVE) OF THE 

COMMONWEALTH OF PUERTO RICO, THE EMPLOYEES RETIREMENT SYSTEM 

OF THE GOVERNMENT OF THE COMMONWEALTH OF PUERTO RICO, AND THE 

PUERTO RICO PUBLIC BUILDINGS AUTHORITY TO LATE-FILED CLAIMS 

To the Honorable United States District Court Judge Laura Taylor Swain: 

1. On February 4, 2022, the Commonwealth of Puerto Rico (the “Commonwealth”), 

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

(“ERS”), and the Puerto Rico Public Buildings Authority (“PBA,” and together with ERS and 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-

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). 

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Commonwealth, the “Debtors”), by and through the Financial Oversight and Management Board 

for Puerto Rico (the “Oversight Board”), as the 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 Four Hundred Fourteenth Omnibus Objection (Substantive) of the 

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

Commonwealth of Puerto Rico, and the Puerto Rico Public Buildings Authority to Late-Filed 

Claims [ECF No. 20040] (the “Four Hundred Fourteenth Omnibus Objection”) to various proofs 

of claim. 

2. The Four Hundred Fourteenth Omnibus Objection seeks to disallow certain latefiled claims (the “Claims to Be Disallowed”). As set forth in the Four Hundred Fourteenth 

Omnibus Objection and supporting exhibits thereto, the Claims to Be Disallowed were filed after 

the applicable Bar Date: (i) June 29, 2018 at 4:00 p.m. (Atlantic Time), for creditors of the 

Commonwealth and ERS, or (ii) July 29, 2020 at 4:00 p.m. (Atlantic Time), for creditors of PBA.3 

Accordingly, pursuant to the terms of the Bar Date Orders, each of the holders of the Claims to Be 

Disallowed are barred from asserting a claim against the Debtors, and the Debtors are discharged 

from any and all liabilities to such claimants. 

3. Any party who disputed the Four Hundred Fourteenth Omnibus Objection was 

required to file a response by 4:00 p.m. (Atlantic Standard Time) on March 7, 2022, in accordance 

with the Court-approved notice attached to the Four Hundred Fourteenth Omnibus Objection as 

Exhibit C, which was served in English and Spanish on the individual creditors subject to the Four 

Hundred Fourteenth Omnibus Objection, the U.S. Trustee, and the Master Service List (as defined 

2

 PROMESA is codified at 48 U.S.C. §§ 2101–2241. 

3

 Capitalized terms not otherwise defined herein shall have the meanings given to such terms 

in the Four Hundred Fourteenth Omnibus Objection. 

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in the Fifteenth Amended Case Management Order [ECF No. 17127-1]). See Certificate of Service

[ECF No. 20153]. 

4. The Debtors have received the following correspondence: 

 Two responses on June 1, 2022 from Maria Ivet Feliciano Rosado (“Feliciano 

Rosado”), copies of which are attached hereto as Exhibit “A” (the “First Feliciano 

Rosado Response”) and Exhibit “B” (the “Second Feliciano Rosado Response, and 

together with the First Feliciano Rosado Response, the “Responses”), regarding 

Proof of Claim No. 179662 (the “Feliciano Rosado Claim”); 

Certified translations of the First Feliciano Rosado Response and the Second Feliciano Rosado 

Response are attached hereto as Exhibit “A-1” and Exhibit “B-1,” respectively. 

I. The Responses 

5. On October 18, 2021—over three years after the Commonwealth’s Bar Date—

Feliciano Rosado filed the Feliciano Rosado Claim, which was logged by Prime Clerk as Proof of 

Claim No. 179662. The Oversight Board seeks to disallow the Feliciano Rosado Claim as latefiled pursuant to the Four Hundred Fourteenth Omnibus Objection. 

6. The First Feliciano Rosado Response consists of a “Motion in Fulfillment of Order 

and Show Cause for Non-Dismission [sic]” addressed to the United States Court of Appeals for 

the First Circuit as well as several related documents attached as “annexes.” In the First Feliciano 

Rosado Response, Feliciano Rosado refers to proceedings related to a different claim—Proof of 

Claim No. 10547 (“Claim No. 10547”), to which the Oversight Board objected pursuant to the 

Four Hundred Thirty-Fifth Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico 

to Claims for Which the Commonwealth is Not Liable (Docket Entry No. 20490) (the “Four 

Hundred Thirty-Fifth Omnibus Objection”)4—and does not dispute the fact that the Feliciano 

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 This Court sustained the Four Hundred Thirty-Fifth Omnibus Objection with respect to the 

Feliciano Rosado Claim on June 7, 2022 in the Memorandum Order Sustaining the Four Hundred 

Thirty-Fifth Omnibus Objection (Substantive) of the Commonwealth of Puerto Rico to Claims for 

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Rosado Claim was filed after the applicable bar date, see First Feliciano Rosado Response at 9, 

18, 21. 

7. The Second Feliciano Rosado Response consists of 153 pages of scanned, largely 

Spanish-language documents pertaining to Feliciano-Rosado’s son, custody matters, and the 

treatment of child-custody payments, in addition to copies of court documents related to Claim 

No. 10547. Like the First Feliciano Rosado Response, the Second Feliciano Rosado Response 

does not dispute the fact that the Feliciano Rosado Claim was filed after the applicable bar date. 

8. Accordingly, because neither Feliciano Rosado Response disputes that the 

Feliciano Rosado Claim was not timely filed or provide any explanation for Feliciano Rosado’s 

failure to file a timely claim, the Debtors respectfully request that the Court grant the Four Hundred 

Fourteenth Omnibus Objection and disallow the Claims. 

[Remainder of Page Intentionally Left Blank] 

 

Which the Commonwealth is Not Liable With Respect to Proof of Claim No 10547 [ECF No. 

21134]. 

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Dated: April 11, 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 

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 Debtors

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