Presentment Date: February 6, 2023 

Objection Deadline: February 3, 2023 at 4:00 p.m. (AST) 

UNITED STATES DISTRICT COURT 

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 HTA, 

ERS and PBA.

NOTICE OF PRESENTMENT OF PROPOSED ORDER GRANTING THE FIVE 

HUNDRED TENTH OMNIBUS OBJECTION (SUBSTANTIVE) OF THE PUERTO 

RICO HIGHWAYS AND TRANSPORTATION AUTHORITY, EMPLOYEES 

RETIREMENT SYSTEM OF THE GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO, AND PUERTO RICO PUBLIC BUILDINGS AUTHORITY TO 

UNRESPONSIVE ACR CLAIMS (ECF NO. 21766)

PLEASE TAKE NOTICE that, on January 27, 2023, the Puerto Rico Highways and 

Transportation Authority (“HTA”), 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 HTA and ERS, the “Debtors”), by and through the Financial Oversight and 

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 (“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-BK3566-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). 

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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 hereby submit this Notice of Presentment of Proposed Order 

Granting the Five Hundred Tenth Omnibus Objection (Substantive) of the Puerto Rico Highways 

and Transportation Authority, Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico, and Puerto Rico Public Buildings Authority to Unresponsive ACR 

Claims (this “Notice”). 

PLEASE TAKE FURTHER NOTICE that, on August 5, 2022, the Debtors, by and 

through the Oversight Board, filed the Five Hundred Tenth Omnibus Objection (Substantive) of 

the Puerto Rico Highways and Transportation Authority, Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico, and Puerto Rico Public Buildings Authority to 

Unresponsive ACR Claims [ECF No. 21766] (the “Five Hundred Tenth Omnibus Objection”) to 

the proofs of claim listed on Exhibit A thereto. 

PLEASE TAKE FURTHER NOTICE that, the Five Hundred Tenth Omnibus Objection 

was scheduled for hearing on September 21, 2022. 

PLEASE TAKE FURTHER NOTICE that, any party against whom the Five Hundred 

Tenth Omnibus Objection was served, or any other party to the Debtors’ Title III cases who 

objected to the relief sought therein, was required to file and serve a response to the Five Hundred 

Tenth Omnibus Objection with the clerk’s office of the United States District Court for the District 

of Puerto Rico (the “Court”) by 4:00 p.m. (Atlantic Standard Time) on September 5, 2022 (the 

“Response Deadline”). 

2

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

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PLEASE TAKE FURTHER NOTICE that, as set forth in Exhibit C to the Five Hundred 

Tenth Omnibus Objection, if no responses were filed by the Response Deadline, the Five Hundred 

Tenth Omnibus Objection “will be deemed unopposed and may be granted unless: (1) the 

requested relief is forbidden by law; (2) the requested relief is against public policy; or (3) in the 

opinion of the court, the interest of justice requires otherwise.” Ex. C to the Five Hundred Tenth 

Omnibus Objection, [ECF No. 21766-4, at 3]. 

PLEASE TAKE FURTHER NOTICE that, according to this Court’s Sixteenth Amended 

Case Management Procedures [ECF No. 20190-1] (the “Case Management Procedures”), the 

Court may enter an order granting request for relief without a hearing upon receipt of a certificate 

of no objection (“CNO”, as defined by the Case Management Procedures). See Case Management 

Procedures, Section III, paragraph P. 

PLEASE TAKE FURTHER NOTICE that, in accordance with the Case Management 

Procedures, the undersigned hereby certifies that this Notice is filed not less than forty-eight (48) 

hours after the expiration of the Response Deadline. 

PLEASE TAKE FURTHER NOTICE that, pursuant to notices of withdrawal, the 

Commonwealth withdrew the Five Hundred Tenth Omnibus Objection solely as to Proof of Claim 

Nos. 106241; 80302; 107206; 121135; 133137; 179153; 58340; 104018; 74848; 89833; 77944; 

119134; 91814; 106103; 75438; 119134; and 83696 (collectively, the “Withdrawn Claims”). See

ECF Nos. 22242; 22418; and 23036. 

PLEASE TAKE FURTHER NOTICE that, the undersigned hereby certifies that counsel 

for the Oversight Board has reviewed, not less than forty-eight (48) hours after expiration of the 

Response Deadline, (i) the docket in the above-captioned case, (ii) mailings received by Kroll 

Restructuring Administration, LLC (“Kroll”), (iii) mailings received by the Oversight Board, and 

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(iv) mailings received by counsel for the Official Committee of Unsecured Creditors of the 

Commonwealth of Puerto Rico and forwarded to counsel for the Oversight Board and, to the best 

of the undersigned’s knowledge, no applicable objection, responsive pleading, or request for a 

hearing with respect to the Five Hundred Tenth Omnibus Objection, except as it may relate to the 

Withdrawn Claims, has been submitted. 

PLEASE TAKE FURTHER NOTICE that, attached hereto as Exhibit A, the 

Commonwealth hereby submits a revised Exhibit A to the Five Hundred Tenth Omnibus Objection 

removing the Withdrawn Claims. 

PLEASE TAKE FURTHER NOTICE that, attached hereto as Exhibit B is a proposed 

order (the “Proposed Order”) granting the relief requested in the Five Hundred Tenth Omnibus 

Objection. 

PLEASE TAKE FURTHER NOTICE that, pursuant to Paragraph III.H of the Case 

Management Procedures, “the presentment of a proposed order for administrative relief must be 

filed and served at least seven (7) calendar days before the presentment date, and Objections 

thereto must be filed and served at least one (1) calendar day before the presentment date,” and 

accordingly, unless a written objection to the Proposed Order is filed with the Court by 4:00 p.m. 

(Atlantic Standard Time) on February 3, 2023, the relief requested in the Five Hundred Tenth 

Omnibus Objection shall be deemed unopposed, and the Proposed Order may be entered without 

a further hearing. 

PLEASE TAKE FURTHER NOTICE that, copies of all documents filed in these Title 

III cases are available (a) free of charge by visiting https://cases.ra.kroll.com/puertorico or by 

calling +1 (844) 822-9231, and (b) on the Court’s website at http://www.prd.uscourts.gov, subject 

to the procedures and fees set forth therein. 

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Dated: January 27, 2023 

 San Juan, Puerto Rico 

Respectfully submitted, 

/s/ Brian S. Rosen 

Martin J. Bienenstock 

Brian S. Rosen 

(Admitted Pro Hac Vice) 

PROSKAUER ROSE LLP

Eleven Times Square 

New York, NY 10036 

Tel: (212) 969-3000 

Fax: (212) 969-2900 

Email: mbienenstock@proskauer.com 

 brosen@proskauer.com 

 

/s/ Hermann D. Bauer 

Hermann D. Bauer 

USDC No. 215205 

Carla García Benítez 

USDC No. 203708 

O’NEILL & BORGES LLC 

250 Muñoz Rivera Ave., Suite 800 

San Juan, PR 00918-1813 

Tel: (787) 764-8181 

Fax: (787) 753-8944 

Email: Hermann.bauer@oneillborges.com 

Attorneys for the Financial Oversight and 

Management Board for Puerto Rico, as 

representative for the Puerto Rico Highways 

and Transportation Authority, the Employees 

Retirement System of the Government of the 

Commonwealth of Puerto Rico, and the Puerto 

Rico Public Buildings Authority 

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