Notice of modified submission deadline for special education claims.

In re:  
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO  PROMESA  
reject the Settlement Offer will forgo their ability to share pro rata in the distribution in connection  with the Settlement Offer, and instead, will retain their right to pursue their claim in connection with  
THE FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO,   as representative of 
THE COMMONWEALTH OF PUERTO RICO, et al.,  
 Debtors.1 
Title III  
No. 17 BK 3283-LTS  (Jointly Administered) 
the Commonwealths claims reconciliation process. 
Modification of the Submission Deadline 
Pursuant to the Order Granting Motion of the Commonwealth of Puerto Rico for an Order, Pursuant  to Bankruptcy Code Section 105 and Federal Rule of Bankruptcy Procedure Rule 2002, (A) Modifying  
NOTICE OF ENTRY OF ORDER GRANTING MOTION OF THE COMMONWEALTH OF PUERTO RICO  FOR AN ORDER, PURSUANT TO BANKRUPTCY CODE SECTION 105 AND FEDERAL RULE OF  BANKRUPTCY PROCEDURE RULE 2002, (A) MODIFYING CERTAIN DEADLINES PERTAINING  
TO THE SPECIAL EDUCATION OFFER, AND (B) ESTABLISHING NOTICE PROCEDURES IN  CONNECTION WITH PROPOSED SPECIAL EDUCATION INFORMATION REQUESTS 
This notice relates TO (I) EACH MEMBER OF A FAMILY UNIT (EACH INDIVIDUALLY A CLAIMANT AND TOGETHER CLAIMANTS), WHICH, FOR PURPOSES OF THE SPECIAL EDUCATION  CLAIM PROCEDURES, SHALL INCLUDE (A) CHILDREN WHO WERE STUDENTS ENTITLED TO RECEIVE  SPECIAL EDUCATION SERVICES FROM THE DEPARTMENT OF EDUCATION (THE DOE), BUT  CONTEND THEY DID NOT RECEIVE SUCH ADEQUATE SPECIAL EDUCATION SERVICES DURING THE  PERIOD UP TO AND INCLUDING OCTOBER 31, 2016 (CHILDREN) AND (B) LEGAL GUARDIANS,  INCLUDING, BUT NOT LIMITED TO, MOTHERS, FATHERS AND CARETAKERS OF SUCH STUDENTS  WHO WERE ENTITLED TO RECEIVE SPECIAL EDUCATION SERVICES FROM THE DOE DURING THE  PERIOD UP TO AND INCLUDING OCTOBER 31, 2016 (LEGAL GUARDIANS AND TOGETHER WITH  CHILDREN, A FAMILY), WHO TIMELY AND APPROPRIATELY FILED PROOFS OF CLAIM IN THE TITLE  III CASE OF THE COMMONWEALTH (THE COMMONWEALTHS TITLE III CASE), EITHER THROUGH  CLAIMS FILED ON THEIR OWN BEHALF, OR THROUGH CLAIMS FILED BY THEIR RESPECTIVE  COUNSEL, WHICH REMAIN PENDING FOR RESOLUTION BEFORE THE TITLE III COURT, AND (II) ARE  A PARTY TO THE CIVIL LITIGATION CAPTIONED ROSA LYDIA VLEZ AND OTHERS V. DEPARTMENT OF  EDUCATION, CIVIL CASE NO. KPE-1980-1738 (THE SPECIAL EDUCATION LITIGATION), PENDING  BEFORE THE SUPERIOR COURT OF FIRST INSTANCE OF SAN JUAN (THE COMMONWEALTH  COURT), OR TO ONE OF SEVERAL LITIGATIONS THAT WERE CONSOLIDATED WITH THE SPECIAL EDUCATION LITIGATION (THE CONSOLIDATED SPECIAL EDUCATION LITIGATIONS).  
THIS NOTICE DOES NOT APPLY TO ANY CLAIMANT WHO HAS PREVIOUSLY RECEIVED AND  ACCEPTED THIS SETTLEMENT OFFER PURSUANT TO THE SPECIAL EDUCATION CLAIM PROCEDURES. THE DEADLINE TO RESPOND (RESPONSE) TO THIS NOTICE IS APRIL 15, 2026 (THE MODIFIED  SUBMISSION DEADLINE.)
Starting on February 13, 2025, a Settlement Offer of $25,000.00 was proposed to each Family, collectively. Responses to the proposed Settlement Offer were due by June 3, 2025. The June 3, 2025 deadline to respond to the Settlement Offer proposed in accordance with the  Special Education Claim Procedures disseminated by the Commonwealth of Puerto Rico has been  extended to April 15, 2026 at 11:59 p.m. (Atlantic Standard Time) for certain parties, as further  detailed below. Please review this notice carefully. 
IF YOU FILED A PROOF OF CLAIM IN CONNECTION WITH THE SPECIAL EDUCATION LITIGATION  AS DESCRIBED ABOVE, YOU SHOULD READ THIS NOTICE CAREFULLY AND DISCUSS IT WITH YOUR  ATTORNEY. IF YOU DO NOT HAVE AN ATTORNEY, YOU MAY WISH TO CONSULT ONE. 
If you have any questions, please contact Kroll by emailing puertoricoinfo@ra.kroll.com or by  phone at (844) 822-9231 (toll free for U.S. and Puerto Rico) or (646) 486-7944 (for international callers),  available 10:00 a.m. to 7:00 p.m. (Atlantic Standard Time) (Spanish available).

Background
On November 14, 1980, Ms. Rosa Lydia Vlez and eight other plaintiffs (the Original Plaintiffs),  initiated litigation against the Puerto Rico Department of Education (the DOE) on behalf of a class  of minors and parents of minors who participated in the DOEs Special Education Program. Following  decades of litigation and a multitude of procedural events, the Supreme Court of Puerto Rico (the  Supreme Court) determined that parents, guardians and caregivers of children enrolled in the Special  Education Program in Puerto Rico, along with children, could present claims for damages in the Special  Education Litigation. The Supreme Court issued a public edict explaining how to present claims and  instructing any party who was seeking to prove his or her damages pursuant to the Special Education  Litigation to do so on or before October 31, 2016. 
On May 3, 2017, the Financial Oversight and Management Board for the Commonwealth of Puerto  Rico (the Oversight Board) issued a restructuring certificate pursuant to PROMESA Sections 104(j)  and 206, and filed a voluntary petition for relief for the Commonwealth pursuant to PROMESA Section  304(a), commencing a case under Title III, therefore. Shortly thereafter, the Commonwealth Court  issued a judgment declaring the damages phase of the Special Education Litigation2 stayed pursuant  to the Commonwealths Title III case.  
Pursuant to an order, dated January 18, 2022 [ECF No. 19813] (the Confirmation Order), the  Modified Eighth Amended Title III Plan of Adjustment for the Commonwealth or Puerto Rico, et al., dated January 14, 2022 [ECF No. 19784] (as amended, supplemented, or modified, the Plan), was  confirmed by the United States District Court for the District of Puerto Rico (the Court).  
The Effective Date of the Plan occurred on March 15, 2022, and the Notice of (A) Entry of Order  Confirming Modified Eighth Amended Title III Plan of Adjustment of the Commonwealth of Puerto Rico,  et al. Pursuant to Title III of PROMESA and (B) Occurrence of the Effective Date [ECF No. 20349] (the  Effective Date Notice) was filed and served in connection therewith.3 
On May 24, 2018, a master proof of claim, Proof of Claim No. 29477, was filed on behalf of all  plaintiffs in the Special Education Litigation who agreed to be represented by Lead Counsel, Mr.  Jos E. Torres Valentn (Torres Valentn) of Torres Valentn Estudio Legal, LLC (the Vlez Master  Claim), asserting liabilities arising from the complaint filed in the Special Education Litigation. In  addition, approximately, 1,345 proofs of claim (the Other Special Education Claims, and together  with the Vlez Master Claim, the Special Education Claims), were filed in the Commonwealth Title  III Case by claimants who are parties to either the Special Education Litigation or the Consolidated  Special Education Litigations, but who had opted not to be represented by Lead Counsel. In total,  approximately 1,346 proofs of claim were filed by or on behalf of approximately 18,667 Claimants in  the Special Education Litigation. 
On February 10, 2025, the Commonwealth Court entered the Order Granting Motion of the  Commonwealth of Puerto Rico for An Order, Pursuant to Bankruptcy Code Section 105 and Federal  Rule of Bankruptcy Procedure Rule 2002, Regarding Notice Procedures in Connection with Proposed  Special Education Settlement [ECF No. 28846] (the Special Education Procedures Order), approving  the dissemination and form of a Settlement Offer (the Settlement Offer) to (i) each Family who timely  and appropriately filed a proof of claim in the Commonwealths Title III Case, either through claims  filed on their own behalf, or through claims filed by their respective counsel, which remain pending  for resolution before the Title III Court and (ii) are a party to the Special Education Litigation or the  Consolidated Special Education Litigations. 
Settlement Offer 
The Settlement Offer proposes each Family who properly and timely filed a proof of claim in the  Commonwealth Title III Case on their own behalf, or through claims filed by their respective counsel,  asserting liabilities in connection with the Special Education Litigation shall be granted an allowed  claim collectively against the Commonwealth in the amount of $25,000.00, which such allowed claim  will be treated in accordance with the terms and provisions of the Plan. Each Family will be granted  an allowed claim in the amount of $25,000.00 collectively, with such amount to be distributed pro  rata amongst the members of the Family associated with the relevant Special Education Claim and  who accept the Settlement Offer. The Settlement Offer amount is not proposed on an individual basis  to each member in the Family associated with the relevant Special Education Claim. Pursuant to the  Plan, each Family will be treated as a holder of an allowed general unsecured claim, held against the  Commonwealth, in Class 58 (CW General Unsecured Claims) and be entitled to recover its pro rata  share of the CW GUC Recovery up to the GUC Recovery Cap. See Plan  1.181, 1.261, 1.285, 62.1.  Thus, the amount each Family will actually receive may NOT equal $25,000.00. 
By agreeing to accept the $25,000.00 allowed claim, Claimants agree to release the Commonwealth,  including its agencies, related entities constituting the central government, as listed at ECF No. 2828,  and its covered territorial instrumentalities, approved by the Oversight Board at its September 30,  2016 meeting (ECF No. 1299-15 in Case No. 17-3567), together with their respective current or former  board members, directors, principals, agents, officers, employees, advisors and professionals, from  any claim or cause of action, whether known, unknown, asserted or assertable directly or derivatively,  fixed, contingent, matured, unmatured, disputed, undisputed, in law, equity or otherwise, and whether  asserted or unasserted, that arose, in whole or in part, prior to the Plan Effective Date, including, without  limitation, claims arising from or relating to the Special Education Litigation. By choosing to reject the  $25,000.00 allowed claim, Claimants forego the right to share pro rata in the recovery for a Familys  allowed general unsecured claim of $25,000.00 against the Commonwealth, and instead, will retain  the right to pursue the claim in connection with the Commonwealths claims reconciliation process.  
Unanimous acceptance of the Settlement Offer by all Claimants in a Family is not required. Each  Claimant in a Family who chooses to accept the Settlement Offer will receive their pro rata share of  the distribution in connection with the Settlement Offer. Any Claimant in a Family who chooses to  
Certain Deadlines Pertaining to the Special Education Offer, and (B) Establishing Notice Procedures In  Connection with Proposed Special Education Information Requests [ECF No. 30518] (the Modification  Order), the deadline for submitting a response to the Settlement Offer has been extended to 11:59  p.m. (Atlantic Standard Time) on April 15, 2026 (the Modified Submission Deadline). 
IF YOU FILED A PROOF OF CLAIM IN CONNECTION WITH THE SPECIAL EDUCATION LITIGATION AS DESCRIBED ABOVE, YOU SHOULD READ THIS NOTICE CAREFULLY AND DISCUSS IT WITH YOUR  ATTORNEY. IF YOU DO NOT HAVE AN ATTORNEY, YOU MAY WISH TO CONSULT ONE. 
If you have any questions, please contact Kroll by emailing puertoricoinfo@ra.kroll.com or by  phone at (844) 822-9231 (toll free for U.S. and Puerto Rico) or (646) 486-7944 (for international callers),  available 10:00 a.m. to 7:00 p.m. (Atlantic Standard Time) (Spanish available).

When You Should Submit A Response
1. You did not previously submit any Response to the Settlement Offer. 
2. You previously submitted a rejection to the Settlement Offer but now wish to submit an  acceptance to the Settlement Offer. 
When You Should NOT Submit a Response 
1. You should not submit a Response if you have previously accepted the Settlement Offer.  All prior acceptances are final and a Response will not be considered if you have previously  submitted an acceptance to the Settlement Offer.  
2. You should not submit a Response if your claim is deemed resolved and allowed against  the Commonwealth. 
3. The following Responses will not be counted: 
a. Any Response that does not contain an election to accept or reject the Settlement Offer. b. Any Response by the same family member that contains elections to accept and reject the  Settlement Offer. 
c. Any Response that is unsigned. 
d. Any Response that is illegible or contains insufficient information to permit the identification  of the Claimant. 
e. Any Response that fails to include both the Claimants name and contact information  requested in the Response. 
f. Any Response that is received by Kroll after the Modified Submission Deadline. g. Any Response submitted by a party that does not hold a Special Education Claim. h. Any Response submitted by facsimile, email, or other means of electronic transmission other  than Krolls dedicated online portal. 
The Modified Submission Deadline is intended only to allow those Claimants who have not already  accepted the Settlement Offer additional time to do so. For the avoidance of doubt, Claimants who have  previously submitted a Response accepting the Settlement Offer will be deemed to have accepted the  Settlement Offer and their Response accepting the Settlement Offer shall supersede any subsequent  submission or revocation. For the avoidance of doubt, Claimants who have previously responded as  rejecting the Settlement Offer are permitted to supersede and revoke any prior Response with an  acceptance on or before the Modified Submission Deadline.  
Where and How to Respond to the Settlement Offer 
Upon completion of the below Settlement Offer form, every Response to the Settlement Offer  should be submitted to Kroll. There are two methods that you can use to submit your Response to  the Settlement Offer to Kroll: 
1. Online Portal. To submit your Response electronically, you must complete and submit your  Response to the Settlement Offer through Krolls dedicated, online portal (the Online Portal).  To submit your Response through the Online Portal, access the Commonwealths restructuring  website at https://cases.ra.kroll.com/puertorico, click on the Settlement Offer section of the  website on the left-hand navigation panel and follow the instructions to submit your Response.  IMPORTANT NOTE: You will need your Unique ID# provided to you in your individualized Notice  of Settlement Offer.  
To the extent you have not received a Unique ID# from Kroll, please contact Kroll by emailing  puertoricoinfo@ra.kroll.com or by phone at (844) 822-9231 (toll free for U.S. and Puerto  Rico) or (646) 486-7944 (for international callers), available 10:00 a.m. to 7:00 p.m. (Atlantic  Standard Time) (Spanish available) to retrieve your Unique ID#. 
2. By Mail. To submit your Response by mail, you must complete and mail your Response to the  Settlement Offer to Kroll in the return envelope provided or otherwise by regular mail, overnight  courier, or hand delivery to the following address:  
PUERTO RICO SETTLEMENT OFFER PROCESSING 
C/O KROLL RESTRUCTURING ADMINISTRATION LLC 
(F/K/A PRIME CLERK LLC) 
850 THIRD AVENUE, SUITE 412 
BROOKLYN, NY 11232 
To arrange for hand delivery of this Response, please send an email to  puertoricoinfo@ra.kroll.com (with Puerto Rico Response to Settlement Offer in the subject  line) at least 24 hours before your arrival at the address above and provide the expected date  and time of your delivery. 
You must deliver your Response to the Settlement Offer in the manner described above. If  you are submitting the Response using the Online Portal you should NOT also submit a paper  copy of the Response. 
The Online Portal is the sole manner in which Responses will be accepted by electronic or  online transmission. Responses submitted by facsimile, email, or other means of electronic  transmission will not be counted. Further, as provided for in the Special Education Claims  Procedures, counsel representing one hundred (100) or more Claimants have the option to  submit a Master Response in lieu of submitting Responses through Krolls Online Portal or via  mail or hand-delivery in accordance with the Special Education Claims Procedures. 
The Response must actually be received by Kroll by no later than the Modified Submission  Deadline, April 15, 2026. 
IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE OR IF YOUR FAMILY REJECTS  THE SETTLEMENT OFFER, THE DEBTOR MAY OBJECT TO YOUR PROOF OF CLAIM PURSUANT TO  THE PROCEDURES ESTABLISHED FOR THE COMMONWEALTH TITLE III CLAIMS RECONCILIATION  PROCESS. 
If you have any questions, please contact Kroll by emailing puertoricoinfo@ra.kroll.com or by  phone at (844) 822-9231 (toll free for U.S. and Puerto Rico) or (646) 486-7944 (for international callers),  available 10:00 a.m. to 7:00 p.m. (Atlantic Standard Time) (Spanish available).  1 The Debtors in these Title III cases, along with each Debtors respective Title III case number  listed as a bankruptcy case number due to software limitations and the last four (4) digits of each  Debtors federal tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (the  Commonwealth) (Bankruptcy Case No. 17-BK3283 (LTS)) (Last Four Digits of Federal Tax ID: 3481),  (ii) 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), (iii) Puerto Rico  Highways and Transportation Authority (HTA) (Bankruptcy Case No. 17-BK-3567 (LTS)) (Last Four  Digits of Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (COFINA) (Bankruptcy  Case No. 17-BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474), (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). On October 30, 2024, the Title III case for the Puerto Rico Sales  Tax Financing Corporation (COFINA) (Bankruptcy Case No. 17-BK-3284- LTS) was closed. 2 Unless otherwise defined in this Notice or the Motion, capitalized terms used herein shall have the  meanings ascribed to them in the Special Education Claim Procedures. 
3 Any party in interest wishing to obtain copies of the Confirmation Order, the Plan, and related  documents should contact Kroll Restructuring Administration LLC (Kroll), by telephone at (844) 822- 9231 (toll free for U.S. and Puerto Rico) or (646) 486-7944 (for international callers), available 10:00  a.m. to 7:00 p.m. (Atlantic Standard Time) (Spanish available), or by email at puertoricoballots@ra.kroll. com, or may view such documents by accessing either https://cases.ra.kroll.com/puertorico/ or the  Courts website, https://www.prd.uscourts.gov/. Please note that a Public Access to Court Electronic  Records (PACER) (http://www.pacer.psc.uscourts.gov) password and login are needed to access  documents on the Courts website.