IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO

 as representative of 

THE COMMONWEALTH OF PUERTO RICO,

et al

 Debtors

PROMESA

 Title III

 No. 17 BK 3283-LTS

MOTION FOR RELIEF FROM STAY 

RESPECTING SECOND CAUSE OF ACTION (ATTORNEYS FEES)

IN ARES ET AL V. SECRETARY OF LABOR

AFTER COMPLETION OF CONFERRAL PROCESS

TO THE HONORABLE JUDGE LAURA TAYLOR SWAIN:

NOWCOMES the attorney for PETITIONERSin the Mandamus case of Ares

et al v. Secretario del Trabajo, Civ. No. SJ2017CV02280, part of a group of seventeen (17) 

long-time employeesof the Department of Labor of the Commonwealth of Puerto Rico

1 who

requested mandamus relief against the Secretary of the Department, respecting an alleged

violation of their right to an early retirement pursuant to Law 211-2015. Among other

things, the petitioners in the above-referenced case indicated that their inclusion in the

above retirement plan would represent a savings for the Government of Puerto Rico. 

The original Mandamus petition (copy appended hereto) pled two causes of action. 

The first cause of action, pursuant to Mandamus jurisdiction, was based on the ministerial

1

The original petitioners in the Mandamus petition are: Gilberto Ares Candelaria; Nilda P. Barbosa

Rodriguez; Ana E. Collazo Guzmán; Arnaldo Colón Colón; Melvin Colón Vélez, Angel L. De Jesús

Fernández; Maribel García Cruz; Carlos González Juarbe; Marilyn Hernández Santiago; Carmen D. López

Hernández; Tomás Montañez Rosado; Julia T. Pena De Jesús; Evelyn Pratts Collazo; Norma I. Rivera Nieves;

Edna Sáez Sánchez; Manuel F. Sánchez Incle and Juan D. Sierra Ortega.

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duty of the Secretary of Labor to include all of the petitioners in the above-mentioned

retirement program. As of approximately two weeks ago, after more than five years of

litigation, each and every one of the 17 original petitioners has either accepted alternative

voluntary retirement or has had his/her right to the Act 211 “pre-retirement” affirmed by

the Courts of Puerto Rico and eventually agreed-to by the Commonwealth. Accordingly,

there is absolutely no legal issue remaining with respect to the mandamus action itself.

This lift-stay request is addressed exclusively to the second cause of action, related

to attorneys fees for undersigned counsel who has successfully represented the

petitioners for over five years without charging for her services. 

The request is made pursuant to a special (and quite unusual) law of Puerto Rico,

Law 402 of 1950, 32 LPRA sec. 3114 et seq, which prohibits attorneys who successfully

pursue any claims by employees against their employers from charging any amounts to

their clients under threat of a potential law suit against them and ethical issues. See,

Berkan/Méndez v. Mead Johnson, 204 DPR 183 (2020). Berkan/Méndez v. Mead

Johnson, 204 DPR 183 (2020) (affirming the interpretation of Law 402 put forth by the

undersigned); See, also, In re Martí, 2016 TSPR 1; and In re Rivera Franco, 169 DPR 237

(2006) (concerning the ethical violations.)

It should be noted that under the statutory framework under Law 402, the request

for attorneys fees is separate from the original action. It is a cause of action for which the

attorneys can file separately from the employees, once there has been a successful

resolutionof the underlying case, but no agreement onattorneys fees. See, Berkan/Méndez

v. Mead Johnson, op cit. Accordingly, this second cause of action did not accrue until the

final resolution of the underlying matter. 

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The tortuous history ofthe case canbe summarized as follows: Several years ago, the

underlying mandamus case was stayed, provoking several requests for Relief from the Stay

imposed by the San Juan Superior Court, at the behest of the Government of Puerto Rico.

See, eg. Docket 3691, Docket No. 3725. 

This Court issued a Memorandum Order denying the Motion for Relief from Stay,

at Docket No. 3751. After exhausting the meet-and-confer process mandated by the

operative Case Management Order, the petitioners moved this Court for relief from the

Stay. Following significant efforts and conversations among the parties, the Stay was lifted

pursuant to a Settlement, which prohibited the final “execution” of any judgment. 

Thereafter, the Commonwealth answered the Petition/Complaint which had been filed in

October of 2017, a trial was held, and the mandamus was issued. This was confirmed on

appeal; there were then subsequent proceedings, and finally, the underlying case was

resolved. All petitioners are currently enjoying their retirement benefits as required.

As noted above, however, count “b” on the separate statutory fees has not yet been

addressed for reasons which will be set forth below.

The undersigned hereby certifies that prior to filing this motion, she utilized the

meet and confer procedures required under the Management Order, by sending a request

to the listed attorneys, dated February 7, 2023, to reach an agreement which would allow

her to seek and obtain attorneys fees for this hard-fought struggle, for which she has

receivedno compensation whatsoever. A copy of the February 7

th

letter andits attachments

are appended hereto. 

The attorneys to whom the letter was addressed have not responded to the same.

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PROCEDURAL BACKGROUND

The original mandamus action in the local court, presented on October 31, 2017

(i.e. after the Title III action) addressed the failure of the Department of Labor and Human

Resources and its then secretary, to perform the ministerial duty which would have

mandated the pre-retirement ofthe petitioners pursuant to Law 211-2015 “pre-retirement”

program(later amendedby Law 106-2017, by Law 262-2018) andmore recently by Law 72-

2019.

After the Superior Court initially issued a ruling in favor of the petitioners on a

preliminary issue back in late 2017, the Government requested discretionary review in the 

Puerto Rico Court of Appeals (TA). When the Government failed to prevail on the

interlocutory appeal and on its request for reconsideration thereof, it notified the

PROMESA Stay, and the case was paralyzed for over a year.

The progress of the Interlocutory Appeal was as follows:

The Government requested discretionary review in Ares et al v. Secretario del

Trabajo, KLCE 20180076. The Government also presented a Motion to Stay the case

below, which was granted immediately by the Court of Appeals pending action on the

petition for discretionary review. It should be noted that this Stay was procedural and had

nothing to do with the Title III case.

On February 28, 2018, however, the Court of Appeals in the case denied the

Petition for discretionary review (“certiorari”) and lifted the Stay previously ordered. On

March 14. 2018, the Government presented a Request for Reconsideration regarding the

denial of its petition for discretionary review, which was denied on March 27, 2018.

On April 4, 2018, the Government presented to the Superior Court a“Notice of Stay

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of the Procedures by Virtue of the Petition presented by the Government of Puerto Rico

under Title III of PROMESA.” Attached to the “Notice” was a copy of the “Fourth Amended

Case Management Procedures” issued by this court on that same day, April 4, 2018.

On April 20, 2018, the Superior Court issued Judgement in Ares et al v. Secretario

del Trabajo, Civ. No. SJ2017CV02280, which reads in its entirety as follows:

JUDGMENT

The Department of Justice of the Government of Puerto Rico has appeared through

a “Notice of Stay of the Procedures by Virtue of the Petition presented by the

Government of Puerto Rico underTitle III of Promesa.,” in which it requests a stay of the

proceeding, pursuant to Sections 362(a) and 922(a) of the Bankruptcy Code, as

incorporated by reference under Section 301(a) of Promesa, 48 USC §2161(a).

To that effect, a Judgment is issued declaring the stay of the proceedings in this case.

We reserve jurisdiction expressly to declare the reopening [of the case], at the request

of the interested party, in case the stay order is lifted at any time after the date of the

current judgment and the interested party appears before this forum requesting the

continuation of the proceedings.

On May 24, 2018, the Court of Appeals in Ares et al v. Secretario del Trabajo,

KLCE 20180076 issued the Mandate with respect to the denial of the Petition for

Interlocutory Review (certiarori) which had been requested by the Government. By that

time, however, the Superior Court had already stayed the case. 

Thereafter, further efforts were made to be able to litigate the case, with the

presentation of requests to lift the stay directed at this Court. See, eg., Doc. Number 3476-1

in the instant case. 

These efforts eventually resulted in a Stipulation and an agreement to modify the

Stay, to permit litigation of the action. This was finally done in August of 2019, when a

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stipulation was signed by the parties, allowing for “modification of the Title III Stay, to the

limited extent necessary to proceed to final judgment,” short of execution. 

By Motion dated September 17, 2019, the attorneys for the Government this Court

they were joining the lift-stay relief contemplated in the aforementioned agreed upon

modification of the stay. See, Docket No. 8825 in 17 BK 3283-LTS; see, also, Stipulation

regarding the Lifting of Stay, both documents appended hereto.

Following the lifting of the stay by this Court, the parties in Ares v. Secretary,

continued the litigation. After several hearings and a trial, on July 15, 2020, Judge Judge

Laurecelis Roqués) of the Extraordinary Remedies Section of the Court of First Instance in

San Juan (“TPI”) issued a Judgment finding in favor of the petitioners. See, Attached

Judgment of July 15, 2020 in Case No. SJ2017CV02280. JudgeRoqués,however, explicitly

reserveddecision any determination on the Second Cause ofAction(for statutory attorneys

fees), because in her understanding, “the Stipulation for the modification of the Stay

excluded from her consideration all “monetary claims.”2

The Commonwealth appealed the Judgment to the Puerto Rico Court of Appeals,

in Case No. 2020-0715. On November 18, 2020, the Court of Appeals (TA) affirmed the

Judgment, modifying it, however, to return the matter to the Office of Management and

Budget(OPG) “to reevaluate the viability of funds taking into accountthe current economic

situation ofthe agency.” November 18th TA Judgment, at page 26 (translation of pertinent

language provided). 

2 Note that the undersigned disputes this interpretation on the basis of (1) the language of

the Stipulation; and (2) the nature of statutory attorneys fees, which have been analyzed in the

analogous Eleventh Amendment context. See, for example, Fitzpatrick v. Bitzer, 427 U.S. 445 (1976)

(discussing waiver and Section 5 of the 14th Amendment). There is a difference between money claims -

which were not involved in this case about pre-retirement - and a claim for statutory fees.)

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This was followed by close to two years of administrative bureaucracy, coupled with

several hearings in the Superior Court. Eventually all of the petitioners were “pre-retired”

appropriately(upon the required positive feedback from OPG regarding budgetary impact).

According to representations the trial attorney for the Commonwealth, Department of

Justice (DOJ) attorney, Susanne Lugo, made to the Superior Court, the FOMB was

consulted throughout the process.

On December 9, 2022, the DOJ presented a motion to the TPI, affirming that the

underlying issues in the case, concerning the pre-retirement of the petitioners, were finally

resolved. We quote from the motion, Entry Number 120 in SUMAC, in the original

Spanish:

Este Honorable Tribunal ha ordenado a las partes a mantenerlo informado de

cualquier desarrollo relacionado al cumplimiento con las órdenes dictadas en el

presente caso.

2) Conforme a ello, el compareciente informa que la Oficina de Gerencia y

Presupuesto (OGP) aprobó el planteamiento sometido en agosto de 2022. Este

planteamiento tenía el propósito de añadir a los empleados [Fulano y Sutano] quienes

eran los últimos dos empleados demandantes que restaban por ser incluidos a los

beneficios del Preretiro ....y finiquitar los asuntos concernientes con la sentencia

adversa en este caso.

... 3) Ante ello, toda vez que todos los trámites requeridos a la Agencia han sido

realizados y no resta acción a realizar por el DTRH para preretirar empleados

demandantes, se solicita con el mayor de los respetos que se dé por cumplida la

sentencia dictada y se decrete el cierre y archivo del caso de autos.

In compliance with an Order of the TPI, the undersigned presented an Informative

Motionto the Superior Court, datedDecember 19, 2022, in which she advised the courtthat

the underlying issues of pre-retirement had finally been resolved, but that there remained

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the issue of statutory attorneys fees, stating inter alia, as follows: 

On the other hand, the Cause of Action numbered “b”, about attorneys fees,

remains pending. That cause of action is primarily based on Law 402 of 1950,

which prohibits attorneys for employees from charging for their services

rendered ... and condemns the employer to pay those fees. 

Pursuant to the statutory prohibition, as well as her ethical duty, the

undersigned affirms before this Honorable Court that she has not charged any

amount for her professional services ....” (Motion presented December 19, 2022

in Ares v. Sec., 2017-CV02199, Translation provided)

The undersigned also informed the TPI that on December 19, 2022, she had written

to DOJ attorney Lugo, asking for the DOJ to agree to a stipulation lifting any stay with

respect to attorneys fees.3In her December 19themail to atty. Lugo, the undersigned

specifically invoked the conferral procedures, but stated that “I am writing to you first, but

ifthere is someone else to whom I must direct this request, please let me know. (In the past,

I’ve been told to direct it to the Board’s attorneys, but they in turn have told me to direct it

to the DOJ.”)

Having heard no response from the DOJ, on January 9, 2023, the undersigned sent

a follow-up email, dated January 9, 2023, in which she noted that the TPI had set a close

deadline for a further report on the matter. That same day, attorney Lugo informed the

undersigned that“[e]l asunto ha sido referido a la Secretaría Auxiliar de lo Civil (SAC) [o

sea, sus supervisores dentro del Departamento de Justicia] para la determinación

3

 It should be observed that the undersigned addressed her request directly 

to the DOJ at that time, in light of previous experience, since in 2018, when she first

attempted to lift the stay, addressing a letter to attorneys Hermann Bauer, Ubaldo

Fernánez, Diana Pérez and Andrés López (pursuant to the Case Management Order then

in effect), she was instructed to direct her request to the Department of Justice (DOJ). 

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correspondiente. Una vez tenga una respuesta de la SAC, le informaré. Por el momento, no

tengo información adicional para brindarle.”

It was not until January 18th, 2023, that the DOJ finally expressed its position. It did

so in a filing before the TPI titled “Moción en Cumplimiento de Orden y Oposición a

Reapetura (sic) de Segunda Causa de Acción”. See, attached. Rather than address the

request by the undersigned made as early as December to lift any remaining stay, the DOJ,

now urges the TPI to declare itself without jurisdiction to hear the request for attorneys

fees, by adopting its view that this Court’s January Confirmation Order, and the Injunction

enforcing the Adjustment Plan applies to this case. TheDOJ has argued before the Superior

Court that the claim is barred because there has been no proof of claim filed (this, despite

the fact that the underlying case was stayed for years, as a claim against the

Commonwealth).Thiswas the firsttime thattheCommonwealthraisedthe aforementioned

Confirmation order and Injunction as a bar to the attorneys fees claim. Moreover, it should

be noticed that the attorneys fees claim, although first alleged in 2017, did not ripen until

all the matters in the underlying case were resolved in November of 2022, and therefore

should not be considered a “claim” covered in any manner by the Adjustment Plan and/or

Injunction referenced above.

On March 20, 2023, the Superior Court addressed these matters in a resolution,

which held in abeyance the resolution of the separate request for attorneys fees until this

matter could be addressed by the instant forum. The Resolution states in pertinent part:

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.... por razones de prudencia y autolimitación judicial, dictamos la presente Resolución mediante

la cual mantenemos en suspenso la solicitud de la parte peticionaria a los fines de que se decrete la

reapertura de la causa de acción de honorarios de abogado incluida en la demanda de epígrafe.

Ello hasta tanto se nos informe el desenlace de la solicitud cursada por la parte peticionaria a la

Junta de Supervisión Fiscal y la AAFAF en virtud de la orden de manejo de caso emitida por el

Tribunal Federal en el caso núm. 17-03283.

No obstante, se aclara que este Tribunal aún no ha adjudicado la controversia jurisdiccional aquí

reseñada. Por consiguiente, el Tribunal se reserva la facultad para emitir una determinación

definitiva sobre este asunto y decretar la reapertura de la reclamación de honorarios de abogado,

de ello ser procedente (una vez se conteste la carta cursada por la parte peticionaria o a solicitud

fundamentada de las partes). A su vez, las partes podrán dar seguimiento a dicho trámite, por lo

que se ordena que mantengan al Tribunal informado sobre cualquier desarrollo pertinente con

relación a este asunto.

4

In other words, the Superior Court is awaiting the determination of the instant

request before going forward with its own determination respecting the viability of the

second cause of action, for attorneys’ fees.

4

.... “On the basis of prudence and judicial restraint, we issue the current Resolution, through

which we hold in abeyance the request by the petitioner to have the Court reopen the case n order to

address the cause of action re attorneys fees, included in the Complaint in this case. This is until we

are informed what has transpired with respect to the request sent by the petitioner to the FOMB and

AAFAF, in compliance with the Management Order issued by the Federal Court in Case Number17-

03283.

“However, it is clarified that this Court has not yet adjudicated the jurisdictional controversy

described (in this resolution). Therefore, the Court reserves the power to issue a definitive

determination regarding this matter and to declare the reopening of the attorneys fees claim, if this is

appropriate (once the letter sent by the petitioner is answered or on the basis of a reasoned request by

the parties.) At the same time, the parties can give follow-up to that effort. Accordingly, they are

ordered to keep the Court informed about any development respecting this matter.

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CERTIFICATION REGARDING MEET-AND-CONFER PROCESS

I, Judith Berkan, attorney for the movants, do hereby certify as follows:

1. On February 7, 2023, the undersigned directed an extensive letter by email and

by messenger to the attorneys for the Oversight Board and for AAFAF, advising them of the

intent of the petitioners to request a lifting of the stay and to requesting their engagement

in the conferral process. 

2.The aforementionedletter includedthe following: IdentityofMovantsandcontact

information; a description of the lawsuit; the amount claimed and cause of action; the

status of the underlying claims; and an explanation of the cause as to why the stay should

be lifted. Id.

3. To date, although several weeks have passed since the above-referenced

communication, the undersigned has not received any additional feedback from the

atorneys for AAFAF and the FOMB, to whom the original communication had been

directed.

4. The motivation for this renewed request for a lifting of the stay can be found in

the title of the aforementioned letter, as well as in this motion.

5. In addition to the above, the undersigned further complied with the Case

Management Order in the PROMESA litigation, by providing attorneys for AAFAF, for the

OversightBoard, andfor the Commonwealth of Puerto Rico Department of Justicewith the

following information: Identify of Movants and Contact Information; identification of the

cause of action related to attorneys fees; the underlying cause of action and its accrual, the

status of the underlying claims, why attorneys fees under Law 402 present a separate cause

of action; cause as to why the stay should be lifted

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6. Section 362(d)(1) of Title 11 of the United States Code, incorporated into Section

201 of the PROMESA law, 48 U.S.C. 2161 et seq, provides for the relief from the automatic

stay for “cause.” Although “cause” is not defined, this court has looked to the factors

enunciated in the bankruptcy context by the SecondCircuit in In reSonnax Indus, Inc., 907

F.2d 1280, 1286 (2nd Cir. 1990), to address such questions. 

7. Factors applicable to such stay decisions include, but are not limited to: the

following: (1) the relationship between the action and the bankruptcy case; (2) whether

relief would result in a partial or complete resolution of the issues; (3) whether litigation

in another forum will prejudice the interests of other creditors; (4) the interest of judicial

economy and the expeditious and economical determination of litigation for the parties;

and (5) the impact of the stay on the parties; and the balance of harms. Goya Foods v.

Ulpiano Unanue-Casal, et al, 159 B.R. 90, at 95-96 (D.P.R. 1993).

8. In the instant case, there is basically no relationship between the Title III filing

and the request for attorneys fees. The Litigation would completely resolve the second

cause of action; allowing the Litigation to proceed will cause no prejudice the interests of

other creditors; the cause of action did not accrue until approximately one month ago (and

is therefore neither a pre-petition action nor one which is covered by the recent Injunction

and Approval; the “interest of judicial economy and the expeditious and economical

determination of litigation” clearly favors allowing this case to go forward. The second

cause of action is a simple matter, which in all likelihood will be resolved expeditiously on

the basis of motion papers. Pursuant to an equitable analysis of the “impact of the stay on

the parties and the balance of harms,” the granting of relief will allow the undersigned to

receive payment for some of the five years of uncompensated labor, just to assure

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compliance with the government’s ministerial duties. An equitable case-by-case balancing

of the various harms at stake clearly mitigates against the imposition of a stay in this

Litigation.

9. Not a single one of the attorneys to whom the February 7th letter was addressed

responded to the undersigned

/s/ Judith Berkan

Judith Berkan

It is respectfully submitted that the facts set forth herein are more than sufficient

to justify the failure of the petitioners’ undersigned counselto further meet and confer with

the Debtors’ attorneys, who simply have ignored her requests to agree to lift the stay or

otherwise resolve this impasse. 

WHEREFORE, the undersigned attorney for the Petitioners respectfully requests

that this court enter an Order vacating the PROMESA stay issued by the Superior Court in

the case of Ares et al v. Secretario del Trabajo, Civ. No. SJ2017CV02280, allowing it to

resolve the only remaining issue, that of attorneys fees.

Attorney Verification under penalty of perjury:

I, Judith Berkan, do hereby state as follows: 

1. I have been a practicing attorney since 1974, admitted to practice in Connecticut

that year and in the courts of Puerto Rico in 1980.

2. I represented the petitioners in the Mandamus action before the Superior Court

of Puerto Rico, Ares et al v. Secretario del Trabajo, Civ. No. SJ2017CV02280, and before

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theCourt of Appeals for Puerto Rico, Ares et al v. Secretario del Trabajo, KLCE 20180076.

3. I drafted the pleadings, motions and briefs in the aforementioned cases in the

Spanish language.

4. I am completely bilingual. 

5. All references to translations of the text of Spanish-language documents in the

instant motion are based on my own translations.

6. My clients do not have the economic resources to pay for translations of the

pleadings, briefs and motions in the above-referenced cases.

7. I also affirmatively state that the asseverations contained in the Certification

regarding compliance with the Case Management Order contained at pages 11-13 of this

Motion are true and correct.

I make this statement under penalty of perjury and declare it to be true pursuant to

the provisions of 28 USC §1746.

In San Juan, Puerto Rico this 17th day of September, 2019.

/s/ JUDITH BERKAN

Respectfully submitted in San Juan, Puerto Rico this 17th day of September, 2019

Berkan/Mendez

O’Neill St. G-11

San Juan, P.R. 00918-2301

Tel. (787) 764-0814;Fax (787) 250-0986

berkanmendez@gmail.com

By: /s/ JUDITH BERKAN

 USDC No.200803

 berkanj@microjuris.com

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CERTIFICATION: This is to certify that this motion is being submitted through

the ECF filing system, which will automatically notify all counsel of record.

/s/ JUDITH BERKAN

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