EXHIBIT 47

Case:17-03283-LTS Doc#:23987-47 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 47 Page 1 of 5
Certified to be a correct and true translation from the source text in Spanish to the target language English.

18 / OCTOBER / 2022 – PHILLIP BERRYMAN ATA-certified Spanish-English #432118 

By Targem Translations Inc.

19 April, 2022 

Martin J. Bienenstock 

Brian S. Rosen 

Oversight Board Attorneys 

Proskauer Rose LLP 

Eleven Times Squares 

New York, NY, 10036-8299 

RE: ATTACHMENT TO DEFICIENT CLAIM [handwritten] 104914 

My name is Luz M. Acevedo Mercado with social security number xxx-xx-6506, date of birth xx/xx/1962 and I confirm 

that I was working under the Department of Education from 1990-2020 with 30 years of service as a permanent 

teaching employee. 

In the following points I show the reason why Attachment A of case 17-03283-LTS was deficient: 

1. 1. Act 96-2002 meets the requirements of years offered while I was working for the Department of 

Education uninterruptedly until 2020. The following is what the Puerto Rico legislature decreed: 

Article l. The raises granted under this Law shall be as follows: 

a. One hundred (100) dollars per month salary increase to public employees in active service as of 

June 30, 2002, without distinction of status or category. When a position provides part-time 

services, the increase to be granted shall be proportional to the workday. Those employees linked 

to the service who are not in active service as of July 1, 2002, shall be entitled to receive the 

increase effective on the date they return to service. 

b. The salary increase shall be granted even if the employee is earning a salary equal to or greater 

than the maximum rate of the scale or if the increase exceeds the maximum rate of the scale. Said 

increase shall not affect the salary margin enjoyed by the employees for salary improvement, nor 

shall it be adjusted to scale. It is hereby ordered that the personnel actions to be taken after the 

effective date of this increase shall be processed in accordance with the rules issued by the Central 

Office of Labor Counseling and Human Resources Administration, in harmony with Act No. 89 of 

July 12, 1979, as amended, known as the "Uniform Compensation Act" and the Uniform 

Compensation Regulations. 

Case:17-03283-LTS Doc#:23987-47 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 47 Page 2 of 5
Certified to be a correct and true translation from the source text in Spanish to the target language English.

18 / OCTOBER / 2022 – PHILLIP BERRYMAN ATA-certified Spanish-English #432118 

By Targem Translations Inc.

c. One hundred (100) dollars to employees organized in unions under Act No. 45 of February 25, 

1998, as amended, included in appropriate units whose result of the formula under Section 7.5 of 

the aforementioned Act is zero or negative. Those appropriate units whose formula result is 

positive, but less than one hundred (100) dollars, shall receive an increase equivalent to the 

difference between one hundred (100) dollars and the result of said formula. 

The statement of legislative intent of the law states: 

"therefore, even in the face of the economic hardship we are facing and recognizing the demands of the 

various groups representing the government labor sector, it is imperative to do justice to our public employees by 

granting a salary increase of one hundred (100) dollars per month to public employees who meet the conditions set 

forth below." 

According to the calculations related to this law, based on my years of service (18 years), it is estimated that I am 

owed $21,600.00. 

2. Act 161 of December 24, 2013, states that the pay scale of the teachers of the Puerto Rico Department of 

Education is to be increased by twenty-five dollars ($25) per month, effective July 1, 2014, through 2023, and 

the same was not granted to me. 

Due to the high inflation of expenses, raises have been happening recently and this is a right that corresponds to me 

according to the law. I did not make the claim before 2018, since I understood that it was only for teachers who had a 

teaching career and it corresponded to all public employees. 

Therefore, it is respectfully requested that I not be removed from the case and that the claim be taken into 

consideration. 

Cordially, 

[Signature] 

Luz M. Acevedo Mercado [Handwritten:] Phone 787 – 316 – 2356 

8 calle Andalucia 

Urb. Doraville 

Dorado PR 00646 

luzacevedo.21@gmail.com 

Case:17-03283-LTS Doc#:23987-47 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 47 Page 3 of 5
Certified to be a correct and true translation from the source text in Spanish to the target language English.

18 / OCTOBER / 2022 – PHILLIP BERRYMAN ATA-certified Spanish-English #432118 

By Targem Translations Inc.

Case:17-03283-LTS Doc#:23987-47 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 47 Page 4 of 5
 

 

 

 

 

TRANSLATOR’S CERTIFICATE OF TRANSLATION 

 

 

Translation from: Spanish (Puerto Rico) into English (US) 

TARGEM Translations Inc. 

I, PHILLIP BERRYMAN, ATA-certified Spanish-English #432118, acting as translator at TARGEM 

Translations Inc., a NEW YORK City corporation, with its principal office at 185 Clymer Street, Brooklyn, 

NY, 11211, USA, certify that: 

the English translated document is a true and accurate translation of the original Spanish and has been 

translated to the best of my knowledge. 

 

Original Document Name: 005 Tab 005 Response

 

 Signed this 18th day of October 2022 

 

 

 Phillip Berryman 

 

 

Case:17-03283-LTS Doc#:23987-47 Filed:04/11/23 Entered:04/11/23 21:08:29 Desc:

Exhibit 47 Page 5 of 5