UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

FINANCIAL OVERSIGHT AND 

ADMINISTRATION BOARD FOR 

PUERTO RICO,

 As a representative of the

COMMONWEALTH OF PUERTO RICO et 

al.,

Debtors.

PROMESA

Title III

Number 17BK 3283-LTS

(Jointly administered)

MOTION ASKING TO INCLUDE MEMBERS OF THE GROUP THAT WERE NOT 

INCLUDED

To the Honorable United States Court Judge Laura Taylor Swain:

The group of plaintiffs under the case Maggie Acevedo Sepúlveda et al. V. Department of 

Health of Puerto Rico, before the Public Service Appellate Commission (CASP), under number 

2000-06-1639, Case before the Supreme Court of Puerto Rico CC-2012-1050, file this Motion

and respectfully state the following:

1. On June 2, 2023 we received NOTICE OF ADJOURNMENT OF OMNIBUS 

OBJECTIONS SCHEDULED FOR HEARING AT THE JUNE 7, 2023 OMNIBUS 

HEARING TO THE AUGUST 30, 2023 OMNIBUS HEARING.

2. Upon analysis of our records, we noticed the number of claims of our group stated on 

Appendix 1 didn’t match the numbers of claim we have. For this reason, we searched on 

Case:17-03283-LTS Doc#:24477 Filed:06/09/23 Entered:06/09/23 08:13:57 Desc: Main

Document Page 1 of 3
the Kroll webpage and asked our clients to send us their claim numbers to see if they 

were not included on the Notice.

3. After this task we found a group of clients that were not included on the Notice, but were 

part of the case against the Department of Health and precented the Proof of Claim on 

time. We are including a list with these clients’ names, claim number and date filed as 

Appendix I of this Motion. We’re also including a table combining both tables.

4. All these clients are part of the group of plaintiffs under the Maggie Acevedo Sepúlveda 

et al. V. Department of Health of Puerto Rico. It should also be noted that we were the 

only active lawyer on the case, so that any other creditor who based the proof of claim on 

the case should be added to our group.

5. This case hasn’t been resolved yet, so there shouldn’t be any problem to include them in 

the group.

WHEREFORE, the group of plaintiffs under the Maggie Acevedo Sepúlveda et al. V. 

Department of Health of Puerto Rico respectfully requests that this honorable court approve this 

MOTION ASKING TO INCLUDE MEMBERS OF THE GROUP THAT WERE NOT 

INCLUDED, update record so that the clients listed on the Appendix I are included on the group 

of plaintiffs under the case Maggie Acevedo Sepúlveda et al. V. Department of Health of Puerto 

Rico, before the Public Service Appellate Commission (CASP), under number 2000-06-1639, 

Case before the Supreme Court of Puerto Rico CC-2012-1050 and grant any other remedy 

deemed just.

RESPECTFULLY SUBMITTED.

Case:17-03283-LTS Doc#:24477 Filed:06/09/23 Entered:06/09/23 08:13:57 Desc: Main

Document Page 2 of 3
I HEREBY CERTIFY that on this date I electronically filed the foregoing with the Clerk of the 

Court using the CM/ECF system which will send notification of such filing to all participants of 

the CM/ECF system including the Trustee and Debtors’ counsel.

Dated: June 9, 2023

Ponce, Puerto Rico /s/ Santiago A. Iturregui Del Toro

Santiago A. Iturregui Del Toro

USDC No.225006

P.O. Box 7341

Ponce, Puerto Rico 00732-7341

saiturregui@gmail.com

(787) 298-8155

Case:17-03283-LTS Doc#:24477 Filed:06/09/23 Entered:06/09/23 08:13:57 Desc: Main

Document Page 3 of 3