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, the 

Employee Retirement System of the 

Government of the Commonwealth of Puerto 

Rico, and the Puerto Rico Public Buildings 

Authority

Debtors

PROMESA Title III 

No. 17 BK 3283 (LTS)

(Jointly Administered)

MOTION ADDING CERTIFIED TRANSLATION OF RESOLUTION OF THE 

COURT OF FIRST INSTANCE

TO THE HONORABLE COURT:

By counsel, excepting Javier Mandry Mercado, Oscar Adolfo Mandry Aparicio; María del Carmen 

Amalia Mandry Llombart; Selma Verónica Mandry Llombart; María del Carmen Llombart Bas; Oscar 

Adolfo Mandry Bonilla; Gustavo Alejandro Mandry Bonilla; Yvelise Helena Fingerhut Mandry; Margaret 

Ann Fingerhut Mandry; Victor Robert Fingerhut Mandry; Juan Carlos Esteva Fingerhut; Pedro Miguel 

Esteva Fingerhut; Mariano Javier McConnie Fingerhut; Janice Marie McConnie Fingerhut, Victor Michael 

Fingerhut Cochran; Michelle Elaine Fingerhut Cochran; Rosa Estela Mercado Guzmán: Eduardo José

Mandry Mercado; Salvador Rafael Mandry Mercado; Margarita Rosa Mandry Mercado; Adrián Roberto 

Mandry Mercado members of the estate of Pastor Mandry Mercado (hereafter collectively designated as 

“Sucesión Mandry Mercado”), through its undersigned counsel and respectfully states and requests: 

1. On August 14, 2019, Sucesión Mandry Mercado filed a Memorandum of Costs with the 

Court of First Instance of Puerto Rico, Superior Section of Ponce (the “Court of First Instance”) in Civil 

Number JAC-2008-0853 in reference to the inverse condemnation judgment entered by the Court of First 

Case:17-03283-LTS Doc#:23213 Filed:01/09/23 Entered:01/09/23 12:13:15 Desc: Main

Document Page 1 of 2
2

Instance on August 6, 2019, as amended on December 19, 2019, in favor of Sucesión Mandry Mercado for 

$30,496,000.00 (the “Judgment”).

2. On August 22, 2019, the Court of First Instance notified the parties that it would reserve its 

ruling on the Memorandum of Costs until the Judgment became final and firm. 

3. As it appears from ECF No. 18994-2 and 20528-2, the Judgment became final and firm on 

April 1, 2022.

4. Sucesión Mandry Mercado is forwarding herewith the resolution of the Court of First 

Instance in Spanish with a certified translation to the English language granting the Memorandum of Costs 

in the amount of $20,522.24, entered on December 14, 2022. 

WHEREFORE, it is respectfully requested that the attached resolution of the Court of First Instance

and its certified translation to the English be directed to be made part of the record of this case and that 

proof of claim number 179550 be deemed amended by adding thereto the costs granted by the Court of 

First Instance in the amount of $20,522.24. 

CERTIFICATE OF SERVICE: I hereby certify that on this date, I electronically filed the foregoing

motion with the Clerk of the Court using the EM/ECF system, which will send a notification to all attorneys 

of record.

San Juan, Puerto Rico, this 9

th day of January 2023

s/CHARLES A. CUPRILL-HERNÁNDEZ

USDC-PR 114312

Charles A. Cuprill, P.S.C. Law Offices Counsel for 

Sucesión Mandry Mercado 

356 Fortaleza Street, Second Floor

San Juan, PR 00901 

Tel.787-977-0515

Fax: 787-977-0518

E-mail: cacuprill@cuprill.com

Case:17-03283-LTS Doc#:23213 Filed:01/09/23 Entered:01/09/23 12:13:15 Desc: Main

Document Page 2 of 2