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. 24050

 

MOTION FOR LEAVE TO FILE SPANISH DOCUMENTS AND REQUESTING A 

TERM TO FILE CERTIFIED TRANSLATION BY JULY 6, 2023

To the Honorable United States District Judge Laura Taylor Swain:

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

undersigned legal counsel, respectfully alleges and prays as follows: 

ITS filed its Response to the Five Hundred Seventieth Omnibus Objection (Substantive) 

of the Commonwealth of Puerto Rico, the Employees Retirement Systems 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 Debtors Are Not Liable. See Dkt. 

No. 24634 (“Response”). The Response contains the unsown declaration under penalty of perjury 

issued by Jonathan Miller on January 22, 2023 (the “Declaration”) (Dkt. No. 24634-1), which 

Declaration includes certain documentation in the Spanish language. See Dkt. Nos. 24634-3, 

24634-5 - 24634-8, 24634-20 - 24634-21, 24634-26, and 24634-40 - 24634-41.

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).

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ITS hereby moves for leave to file Dkt. Nos. Dkt. Nos. 24634-3, 24634-5 - 24634-8,

24634-20 - 24634-21, 24634-26, and 24634-40 - 24634-41 in their original Spanish language, and 

for a term of two (2) weeks to file a certified English translation pursuant to Local District Court 

Rule 5(c).

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 22th day of June 2023.

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

Bankr. P. 7004(b), and the Sixteenth Amended Notice, Case Management and Administrative 

Procedures Order (Docket No. 20190-2 of Case No. 17-03283 (LTS)) (the “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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