Exhibit 1

Settlement Agreement

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Certified to be a correct and true translation from the source text in Spanish to the target language English.

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COMMONWEALTH OF PUERTO RICO 

TRIAL COURT

SUPERIOR COURT OF SAN JUAN

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY

PETITIONER

Vs.

LUIS ALBERTO MERCADO

JIMÉNEZ et al.

PARTY IN INTEREST

CASE NO. KEF2011-0240

ROOM NO. 1003

ABOUT:

EMINENT DOMAIN

SETTLEMENT AGREEMENT

TO THE HONORABLE COURT:

The above-named parties appear before the Court through their respective attorneys, who

respectfully state, allege and request:

1. In the present case the parties in interest, Mr. Adrián Mercado Jiménez, his wife Teresa 

Vizcarrondo Toro, and the legal partnership comprised of the two, are the only parties 

with an interest in parcels 021-01 and 021-04, which are not yet subject to a final and 

enforceable judgment.

2. This Court issued a Resolution on April 25, 2017, served on April 28, 2017, page 3, 

paragraph1 and footnote 1, in which it acknowledges that the above parties in interest 

are the only parties with any cause of action pending litigation.

"1. The parties in interest Luis Alberto Mercado Jiménez, Adrián Mercado Jiménez 

and Teresa Vizcarrondo Toro contested the compensation they would obtain for the 

expropriated property in their answer to the Petition and, after the judgment was entered, 

they participated in the proceedings aimed at determining the fair compensation for the 

property acquired." See page 3, paragraph 1.

"2...

"3...

Thus, having ruled, the parties in interest now have the burden of proof to show that 

the fair value of the subject property is greater than the amount deposited by the ACT.1" 

See page 3, fourth paragraph.

"1The parties in interest are understood to be Adrian Mercado Jimenez and Teresa 

Vizcarrondo Toro, since in substitution of Luis Alberto Mercado Jimenez, his heirs, Luis 

Alberto Mercado Barrera, Javier Antonio Mercado Barrera, Isabel Amalia Mercado 

Barrera and the widow, Isabel Barrera, filed a request with consent for the withdrawal of 

the allocated funds." See footnote 1 on page three.

[Initials in left margin]

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3. We request that judicial notice be taken of said Resolution. A copy is enclosed.

4. On April 25, 2017, this Court entered a partial consent judgment with regard to Luis Alberto 

Mercado Barrera, Javier Antonio Mercado Barrera, Isabel Amalia Mercado Barrera and the 

widow of Luis Alberto Mercado Jimenez, Isabel Barrera. We request that judicial notice be 

taken of said judgment. A copy is enclosed.

5. This Court has jurisdiction over this agreement, which is limited to the monetary interests of 

the parties in interest, Mr. Adrián Mercado Jiménez, Teresa Vizcarrondo Toro, and the legal

partnership comprised of the two with respect to parcels 021-01 and 021-04, subject of the 

present lawsuit and as described in the November 2015 Amended Exhibit A, authorized on 

November 24, 2015, since the Bankruptcy Court has kept the stay lifted only for those 

purposes.

6. Enclosed is a copy of the Bankruptcy Court's order, entitled "Order Denying Relief Sought in 

Notice of Compliance and Petition for Payment of Funds (Docket Entry No. 345) and Motion 

Informing Status of Case and Request of Order (Docket Entry No. 406)," dated May 29, 2018.

7. In said order, the bankruptcy court rules that the stay remain lifted so that this Court may hear 

as to the agreement between the petitioner and Mr. Adrián Mercado Jiménez, Teresa 

Vizcarrondo and the legal partnership comprised of the two, in that case being the "movants."

8. Accordingly, the following appear before this Court: The Highway Authority, Mr. Adrián 

Mercado Jiménez, Teresa Vizcarrondo Toro, and the legal partnership comprised of the latter 

two, to give their approval to the present agreement putting an end to all lawsuits and causes 

of action regarding parcels 021-01 and 021-04.

[Initials in left margin]

See Page three, third line and on.

Emphasis added.

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SETTLEMENT PROVISIONS

a) Mr. Esteban Núñez Camacho, an appraiser by profession, was hired in 

substitution of Mr. Néstor Algarín López, as the petitioner’s expert appraiser in this 

case.

b) The qualifications of the appraiser are stipulated by the party in interest hereto.

c) Mr. Núñez conducted an independent appraisal of parcels 021-01 and 021- 04, 

as part of the property from which they are partitioned and arrived at a unit value 

of $17,300.00 per cuerda.

d) The party in interest here has analyzed the appraisal report prepared by Mr. 

Núñez and without any coercion or intimidation of any kind, knowingly, freely, and 

voluntarily accepts the report’s conclusions on unit value as correct and 

reasonable. 

e) The party in interest here, Mr. Adrián Mercado Jiménez, Teresa Vizcarrondo,

and the legal partnership comprised of the two, acknowledge having only a 25% 

interest in parcels 021-01 and 021-04.

f) Therefore, they recognize and accept that, from parcel 021-01 they are entitled 

to $20,606.00, and from parcel 021-04 they are entitled to $11,035.32. 

g) The total amount due to the party in interest hereto is $31,641.32.

h) Of the above sum, $5,500.00 has already been withdrawn by the party in 

interest from the original allocated amount at the time the case was filed, 

$16,448.00 has been deposited with the court, and together with this agreement,

we deposited a check for $9,693.32, for a total not yet withdrawn of $26,141.32.

i) The parties hereto, knowingly, freely, and voluntarily and without coercion or 

intimidation of any kind, hereby acknowledge and affirm that with the total 

allocation of $31,641.32, all inclusive, the petitioner has complied with the payment 

of fair compensation for the interest of Mr. Adrián Mercado Jiménez, Teresa 

Vizcarrondo and the legal partnership comprised of the two, with regard to parcels 

021-01 and 021-04.

j) Likewise, in good faith, freely and voluntarily and without coercion or 

intimidation of any kind, the party in interest hereto knowingly acknowledges and 

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affirms that there are no remaining matters in dispute of any kind in this lawsuit and 

if there are any, they are hereby waived with prejudice.

k) The petitioner agrees that the party in interest hereto, Mr. Adrián Mercado 

Jiménez, Teresa Vizcarrondo and the legal partnership comprised of the two, 

withdraw the $16,448.00 allocated to their name on February 23, 2018, and the 

$9,693.32 that we also allocated to their names today by way of check number 

58234, issued on June 15, 2018, by Motion to enforce compliance with order filed 

at the same time as this provision.

9. By virtue of the agreements described above and considering that no matters remain 

pending, the parties hereto request that this Court to enter judgment by provision, concluding 

in its entirety any matter between the parties hereto.

WHEREFORE, it is respectfully requested that this Honorable Court take cognizance of 

the foregoing and approve the agreements described above, enter a consent judgment with 

regard to the parties and authorize the withdrawal of funds to the parties in interest hereto, upon 

compliance with the requirements of Puerto Rico Rule of Civil Procedure 58.9 of 2009, as 

amended.

In San Juan, Puerto Rico, on this date, June 22, 2018.

[Signature]

Adrian Mercado Jimenez

On his own behalf and in representation of 

Teresa Vizcarrondo Toro and the legal

partnership comprised of the two

Parties in Interest

RUA 2,286

PO Box 9023980

San Juan, P.R. 00902-3980

Phone: (787)273-0611

Fax: (787) 273-1540

amercado@mercadosotolaw.com

[Signature]

Anita Cortés Centeno

Petitioner

RUA Number: 11,368

Highways and Transportation Authority

PO Box 42007

San Juan, PR 00940-2007

Phone: (787) 721-8787 Ext 1228

Fax: (787) 722-1541

Icda.anitacortescenteno@gmail.com

[Signature]

Esteban Núñéz Camacho 

Expert Appraiser

Petitioner

[Signature]

Soledad I. Ruscalleda Reyes 

Director,

Property Acquisition Unit

Highways and Transportation Authority 

PO Box 42007

San Juan, PR 00940-2007

Phone: (787) 721-8787 Ext. 1301

Fax (787)726-8023 

sruscalleda@dtop.pr.gov

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COMMONWEALTH OF PUERTO RICO 

GENERAL COURT OF JUSTICE

TRIAL COURT

SUPERIOR COURT OF SAN JUAN

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY

PETITIONER

v.

SUCN. BY LUIS ALBERTO MERCADO

JIMÉNEZ et al.

PARTY IN INTEREST

CASE NO. KEF2011-0240

ROOM NO. 1003

CIVIL ACTION OF:

EMINENT DOMAIN

RESOLUTION

Having considered: 1) the Motion to Vacate Judgment filed by Adrián Mercado 

Jiménez on his own behalf on August 26, 2016; 2) the Motion to Enforce Compliance with 

Order filed on November 30, 2016, by the petitioner, Puerto Rico Highways and 

Transportation Authority (HTA), and; having held oral argument on these on December 

7, 2016, we rule as follows:

The January 16, 2015, Partial Consent judgment s hereby vacated. The 

aforementioned ruling sought to grant the relief requested by the parties in interest, Luis 

Alberto Mercado Jiménez, Adrián Mercado Jiménez and Teresa Vizcarrondo Toro in the 

motions entitled Request for Withdrawal of Funds, filed on December 10, 2014, in which 

the parties described their interest in the expropriated property, requested disbursement 

of the amount deposited by the petitioner as an estimate of the Fair Value and alleged 

in paragraph seven (7): "[t]hat these parties accept the deposited amount." Likewise, no 

objection to or defense of the forced acquisition of the property was presented in the 

pleadings, therefore, the opportunity to 

Identifying number:

RES2017 ___________

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KEF2011-0240 2

present evidence as to the amount of compensation to be paid as fair value was 

deemed waived. However, upon examining the affidavits annexed to the motions, 

where the parties attested before a notary to the truthfulness of the contents of the 

request for withdrawal of the money deposited, we notice that in paragraph number 

four (4) they added: "[t]hat we accept the fair compensation that may be determined 

by this Honorable Court, but we reserve the right to claim any increase in value that may 

arise in our favor in the estate". (Emphasis added.)

Said statement, besides being clearly contradictory, was contained in the affidavit

requiring the parties by law to certify that the expropriation file has been reviewed and 

that it adequately reflects all the persons who, according to their knowledge, have a 

right over the property. Certainly, the text of the affidavit, a legal condition proper to the 

disbursement of the deposited money, should not include additional allegations by the 

declarant and, much less, any that are antagonistic to those formulated in the request 

for relief included in the accompanying motion.

However, as the matter concerns governmental intervention with the fundamental 

right to the enjoyment of private property (Art. II, Sec. 7, Const. of the Commonwealth, 1 

L.P.R.A.), “which is not to be destroyed with levity” (Mun. de Guaynabo v. Acquisition M2, 

180 D.P.R. 206, 229 (2010)), as anticipated, the January 16, 2015 Partial Consent judgment 

is hereby vacated. To adopt a position contrary to this would be to undermine the 

constitutional protection that "[n]o private property shall be taken or impaired for public 

use except upon payment of fair compensation and in the manner provided by law." 

Art. II, Sec. 9, Const. of the Commonwealth, 1 L.P.R.A. In so acting, we also find that:

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KEF2011-0240 3

1. The parties in interest Luis Alberto Mercado Jiménez, Adrián Mercado Jiménez and 

Teresa Vizcarrondo Toro contested the compensation they would obtain for the 

expropriated property in their answer to the Petition and, after the judgment was 

entered, they participated in the proceedings to determine the fair compensation 

for the property that was acquired.

2. The Clerk of the Court did not serve a copy of the January 16, 2015, Partial Consent 

judgment on Mr. Ricardo Pascual, the attorney who filed the Request for Withdrawal 

of Funds on behalf of Adrián Mercado Jiménez and Teresa Vizcarrondo Toro; Mr. 

Mercado Jiménez was instead served directly.

3. Said judgment was not entered as to Teresa Vizcarrondo Toro, owner of the 

expropriated right in legal partnership regime together with Adrián Mercado 

Jiménez.

Thus having found, the burden of proof now rests with the parties in interest to 

demonstrate that the fair value of the subject is greater than the amount deposited by 

the HTA.1

On the other hand, having examined the Court file, it is ordered:

1. Within a final term of fifteen (15) days, Anita Cortés Centeno, Esq., counsel for the 

petitioner, must file with the Court:

a. The Registry Certification for property number 47,536.

Regarding this property, the petitioner has only included a title search with the motion 

 5 The parties in interest are Adrián Mercado Jiménez and Teresa Vizcarrondo Toro, since in 

substitution of Luis Alberto Mercado Jiménez, his heirs: Luis Alberto Mercado Barrera, Javier Antonio 

Mercado Barrera, Isabel Amalia Mercado Barrera and Isabel Barrera widow of Mercado, they requested 

the withdrawal of the allocated funds.

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filed on February 1, 2012.

The relevant portion of Rule 58.3 of Civil Procedure of 2009, 32 L.P.R.A. Ap. V, provides 

that one of the documents to be included in the expropriation file is:

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KEF2011-0240 4

A certification issued by the Land Registry within six (6) months prior to the filing 

of the lawsuit. However, in cases where the certification was issued within the 

six (6) month period provided above, but on a date that exceeds three (3) 

months prior to the filing of the lawsuit, a recent title search must accompany 

the certification issued by the Land Registry.

Therefore, nowhere in the Rule is the requirement to file a registry certification replaced 

with the filing of a title search instead. Even when the Rule mandates that a title study 

be attached to the certification issued on a date exceeding three (3) months prior to 

the filing of the case, both the title study and the registry certification must be 

attached to the expropriation file.

b. The acquisition survey plan (Exhibit B to the Petition).

The July 12, 2013 motion stated that a copy was enclosed, but same was not filed with 

the Court.

c. An appraisal report entered by an appraiser for each of the nine (9) parcels of land 

to be expropriated, as described in Exhibit A of the Petition.

Likewise, the July 12, 2013 motion stated that a copy of these had been submitted, 

but same were not filed with the Court.

d. Proof of service of process on Sylvia Teresa Méndez Álvarez,

Exhibit A to the Petition stated that she is the mother and sole heir of the deceased 

Carlos Mercado Méndez.

2. On reconsideration of the sworn motions requesting withdrawal of funds with 

consent, filed by 1) LUÍS ALBERTO MERCADO BARRERA2 , 2) JAVIER ANTONIO MERCADO 

BARRERA3 , 3) ISABEL AMALIA MERCADO BARRERA4 , and; 4) 

 2 The motion titled Withdrawal of Funds with Consent was filed under oath on 

March 18, 2016.

3 The motion titled Withdrawal of Funds with Consent was filed under oath on 

March 14, 2016.

4 The motion titled Withdrawal of Funds with Consent was filed under oath on 

March 15, 2016.

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KEF2011-0240 5

ISABEL BARRERA widow of MERCADO5 , all members of the estate of Luis Alberto 

Mercado Jiménez6 , we make the following findings:

The disbursement of money deposited in an in rem eminent domain case (32 

L.P.R.A. App. V R. 58.9) is not the judicial avenue available to the descendants of 

a registered owner of the subject property to request the partition of the estate 

or the division of the estate. Therefore, any sum of money deposited for their 

benefit will remain allocated until the co-heirs exercise the ordinary action to 

obtain the partition (32 L.P.R.A. § 2 or 21 et seq.) or appear proving their consent 

to the disbursement of the inheritance in the manner they deem fit (31 L.P.R.A. § 

2877). In order to do so, through their legal counsel (attorneys Juan Ramirez and 

Jose Ramirez), the parties must submit the following documents7 :

a. Lien Payoff Certification issued by the Treasury Department, evidencing the 

release of the preferential lien established by law on the estate of the 

deceased Luis Alberto Mercado Jimenez. 13 L.P.R.A. § 894, 901, 31101 to 31165.

b. Certification of child support debt issued by the Administration for Child

Support (ASUME) of the deceased party in interest Luis Alberto Mercado 

Jimenez. 8 LPRA § 528a-1.

c. Calculation of the commutation of the usufructuary quota of ISABEL BARRERA 

widow of MERCADO.

d. Calculation of the participation share of each component of the estate of Luis 

Alberto Mercado Jiménez regarding the fair

 5 The motion titled Withdrawal of Funds with Consent was filed under oath on 

March 15, 2016. 6 The Resolution on Declaration of Heirs of Luis Alberto Mercado Jimenez was 

joined to the Court's file by motion filed on September 30, 2015.

7 The certification of land tax debt issued by CRIM for the expropriated property 

was joined to the Court's file by motion filed on September 30, 2015.

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KEF2011-0240 6

compensation and the consent of all these to the disbursement of the 

inheritance in the agreed manner.

2. Furthermore, having reviewed the Answer to the Petition filed on December 2, 2015

by Randolph Raldiris Dominiccí, Esq., we rule as follows:

a. Counsel has a term of thirty (30) days to file the resolution declaring heirs or the 

wills of: 1) Domingo A. Vallejo Ruiz, and; 2) Carmen Rosa Chardón Reyes, thus 

providing proof of the transfer of the right of these parties to their represented 

parties: 1) Dominic Henry Valleío Chardón; 2) Desiree Felixa Valíeio Chardón, 

and; 3) Yanihra del Carmen Valleio Chardón.

b. The following should also be filed with the Court:

• Lien Payoff Certification issued by the Department of Treasury, proving the 

release of the preferential lien established by law on the estate of: 1) 

Domingo A. Vallejo Ruiz, and; 2) Carmen Rosa Chardón Reyes. 13 L.P.R.A. 

§ 894, 901, 31161 to 31165.

• Certification of child support debt issued by the Administration for the 

Support of Minors (ASUME) for the deceased parties in interest: 1) Domingo 

A. Vallejo Ruiz, and 2) Carmen Rosa Chardon Reyes. 8 LPRA § 528a-1.

• Land tax debt certification issued by the CRIM for property 47,536; property 

affected by the expropriation of Parcel 29-01.

• Calculation of shares in the fair compensation of each component of the 

estates of: 1) Domingo A. Vallejo Ruiz, and; 2) Carmen Rosa Chardón 

Reyes; as well as the consent of all of them to the disbursement of the 

inheritance in the manner agreed upon.

• The deed of sale of the interest of Daisy Vallejo Hernández in the estate of 

Domingo A. Vallejo Ruiz.

Counsel is warned that the Court will not order the withdrawal of the funds 

deposited to the names of the individuals he represents until they comply with 

the provisions of Act No. 90 of 

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KEF2011-0240 7

May 17, 2012, which amended Rule 58.9 of the 2009 Rules of Civil Procedure, 32 

L.P.R.A. Ap. V, requiring that any request for withdrawal or disbursement of money 

appropriated in a compulsory expropriation case be under oath. Said rule reads:

Any request for withdrawal or disbursement of the deposited money must be 

under oath. The party must certify within the request as to having reviewed the 

expropriation docket and that the same adequately reflects all persons known 

to said party to have a right in the property, including owners, occupants, 

lessees, usufructuaries, and mortgagees. In the event the party has knowledge 

of any transaction or right over the property that does not arise from the 

expropriation file, that party must notify the court accordingly. (Emphasis 

added).

In order for the parties to comply with the ruling, the May 10, 2017 hearing is hereby 

adjourned. Nonetheless, counsel is warned that failure to comply with the order within 

the term granted will lead to sanctions being imposed on the attorneys. The case was 

filed in 2011 and the laxity in complying with the procedural rules is detrimental to the 

fair, expeditious and cost-effective resolution of the lawsuit.

Lastly, the parties are to proceed to exchange the reports of their respective 

appraisers, meet with each other and report to the Court on the outcome of said

meeting within sixty (60) days. The pre-trial conference to determine the fair value of the 

expropriated subject and the damages caused by the expropriation, if any, shall be held 

on October 4, 2017, at 9:00am, in Room 1003 of the San Juan Judicial Center. Same must 

be attended by the parties with their respective attorneys and expert witnesses. The 

following matters will be discussed at the conference:

1. The possibility of a settlement of the case, with the assistance of the

parties, their attorneys, and experts.

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KEF2011-0240 8

2. The adjudication of all pending disputes arising out of the preliminary 

report between counsel, including the admissibility of evidence.

3. Documentary evidence duly identified by counsel will be marked in the 

preliminary inter-counsel report.

4. The matter will be set down for trial.

Counsel for the parties shall meet with each other at least fifteen (15) 

days prior to the pretrial conference date to prepare the inter-counsel pretrial 

briefing. 32 L.P.R.A. App. V R. 37.4. The report, which must contain abundant 

and specific stipulations of facts, documents and matters while avoiding to 

present unnecessary evidence, shall be submitted to the Clerk of the Court 

ten (10) days prior to the scheduled date. Attorneys are advised that these 

terms are to be strictly complied with, subject to sanctions pursuant to Rule 

37.7 of Civil Procedure, 32 L.P.R.A. Ap. V.

TO BE SERVED.

ENTERED IN SAN JUAN, PUERTO RICO, ON THIS [handwritten:] 25th DAY OF 

APRIL 2017.

[initial]

LETICIA D. ORTIZ FELICIANO 

JUDGE OF THE SUPERIOR COURT

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COMMONWEALTH OF PUERTO RICO 

GENERAL COURT OF JUSTICE

TRIAL COURT

SUPERIOR COURT OF SAN JUAN

PUERTO RICO HIGHWAY AND 

TRANSPORTATION AUTHORITY

PETITIONER

v.

ESTATE OF LUIS ALBERTO 

MERCADO

JIMÉNEZ et al.

PARTY IN INTEREST

CASE NO. KEF2011-0240

COURTROOM 1003

CIVIL ACTION IN RE.:

EMINENT DOMAIN

[Seal:] COMMONWEALTH OF PUERTO RICO 

TRIAL COURT

SUPERIOR COURT OF SAN JUAN

GENERAL COURT OF JUSTICE

K047 [initials]

PARTIAL JUDGMENT

Having considered the motions for withdrawal of funds with consent filed 

by: LUIS ALBERTO MERCADO BARRERA1, JAVIER ANTONIO MERCADO BARRERA2, 

ISABEL AMALIA MERCADO BARRERA3, ISABEL BARRERA VIUDA DE MERCADO4, the 

Court hereby enters a partial judgment as to these parties, ruling as follows:

1. It is hereby declared and decreed that the full dominion over Parcel 

Number 021-01 and Parcel Number 021-04 both partitioned from 

Property 14953, as described in the November 2015 Amended Exhibit A

to the Petition on record, is hereby vested in favor of the PUERTO RICO 

HIGHWAYS AND TRANSPORTATION AUTHORITY.

2. It is hereby decreed that fair compensation be paid for the 

expropriated properties in the amount of TWENTY-TWO THOUSAND

1 The motion titled Withdrawal of Funds with Consent was filed under oath on March 18, 2016.

2 The motion titled Withdrawal of Funds with Consent was filed under oath on March 14, 2016.

3 The motion titled Withdrawal of Funds with Consent was filed under oath on March 15, 2016.

4 The motion titled Withdrawal of Funds with Consent was filed under oath on March 15, 2016.

IDENTIFICATION NUMBER: SEN2017 [Handwritten:] 26046

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Certified to be a correct and true translation from the source text in Spanish to the target language English.

25/OCTOBER/2022 - Andreea I. Boscor ATA-certified Spanish-English #525556

By Targem Translations Inc.

KEF20110240 2

DOLLARS ($22,000), amount deposited with the Court prior to this date.

Pursuant to Rule 42.3 of Civil Procedure of 2009, 32 L.P.R.A. App. V, it is 

expressly ordered that this partial judgment be filed and served, since there is no 

reason to postpone the ruling until the full resolution of the lawsuit.

This partial judgment is entered without costs.

TO BE FILED AND SERVED.

ENTERED IN SAN JUAN, PUERTO RICO, ON APRIL [handwritten:] 25, 2017.

[initial]

LETICIA D. ORTIZ FELICIANO 

JUDGE OF THE SUPERIOR COURT

[Illegible stamps and initials]

Case:17-03283-LTS Doc#:24153-1 Filed:05/05/23 Entered:05/05/23 17:40:04 Desc:

Exhibit 1 Page 17 of 18
TRANSLATOR’S CERTIFICATE OF TRANSLATION

Translation from: Spanish (Puerto Rico) into English (US)

TARGEM Translations Inc.

I, Andreea I. Boscor, ATA-certified Spanish-English #525556, acting as translator at TARGEM Translations Inc., a NEW YORK 

City corporation, with its principal office at 185 Clymer Street, Brooklyn, NY, 11211, USA, certify that:

the English translated document is a true and accurate translation of the original Spanish and has been translated to the best of my 

knowledge.

Original Document Name: Estipulación KEF 2011-0240

 

Signed this 25th October 2022 

__________________________ 

 Andreea I. Boscor

Case:17-03283-LTS Doc#:24153-1 Filed:05/05/23 Entered:05/05/23 17:40:04 Desc:

Exhibit 1 Page 18 of 18