UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO,

As representative of

THE COMMONWEALTH OF PUERTO 

RICO, et al.,

Debtors1

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 24645

 

INFORMATIVE MOTION AS TO SUBMISSION OF CERTIFIED TRANSLATION

To the Honorable United States District Judge Laura Taylor Swain:

COMES NOW, International Traffic Systems, LLC (“ITS”), a creditor, by and through 

the undersigned legal counsel, and in compliance with the Court’s Order at Dkt. No. 24645

granting ITS’s Motion for Leave to File Spanish Documents and Requesting a Term to File 

Certified Translation by July 6, 2023 (“the Motion”) at Dkt. No. 24636, respectfully submits the 

English version of the Spanish documents previously submitted at Dkt. Nos. 24634-3, 24634-5 -

24634-8, 24634-20 - 24634-21, 24634-26, and 24634-40 - 24634-41.

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1 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number listed as a bankruptcy 

case number due to software limitations 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) 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. 17-4780 (LTS)) (Last Four Digits of Federal Tax ID: 3747); and 

(vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of 

Federal Tax ID: 3801).

2 When submitting the attachments to the Response To The Five Hundred Seventieth Omnibus Objection 

(Substantive) Of The Commonwealth Of Puerto Rico, The Employees Retirement System Of The Government Of The 

Commonwealth Of Puerto Rico, The Puerto Rico Highways And Transportation Authority, And Puerto Rico Public 

Buildings Authority To Claims For Which The Debtors Are Not Liable at Docket No. 24634, ITS inadvertently 

submitted as Attachment 5 (Docket No. 24634-6) an illegible copy in Spanish of the Delivery Record included as 

part of its Proof of Claim at page 54. However, in the same Proof of Claim, ITS included a more legible copy of the 

same document at page 91. For completeness’s sake, attached please find the translation of the more legible version.

 

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WHEREFORE, ITS respectfully request this Honorable Court take notice of the filing 

of a certified translation of these Spanish Language Exhibits in compliance with the Court’s 

Order.

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 6

th day of July 2023.

CERTIFICATE OF SERVICE: In accordance with Fed. R. Bankr. P. 9014(b), Fed. R. 

Bankr. P. 7004(b), and the Court’s CMP Order, we hereby certify that a true and exact copy of 

the foregoing was sent by electronic mail upon all the parties listed in the Master Service List and 

by U.S. mail upon all the Standard Parties listed in the CMP Order.

MCCONNELL VALDÉS LLC

270 Muñoz Rivera Avenue, Suite 7

Hato Rey, Puerto Rico 00918

P.O. Box 364225

San Juan, PR 00936-4225

Tel: 787-250-5619

Fax: 787-759-9225

By: /s/ Nayuan Zouairabani Trinidad

 Nayuan Zouairabani Trinidad

 USDC No. 226411

 E-mail: nzt@mcvpr.com

By: /s/ Victoria Rivera Lloréns

 Victoria Rivera Llorens

 USDC No. 307808

 E-mail: vrll@mcvpr.com

Attorneys for International Traffic Systems, Inc.

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