UNITED STATES DISTRICT COURT 

 DISTRICT OF PUERTO RICO 

IN RE: PROMESA 

 TITLE III 

THE FINANCIAL OVERSIGHT MANAGEMENT 

BOARD FOR PUERTO RICO, 

 as representative of No. 17 BK 3283-LTS 

 

THE COMMONWEALTH OF PUERTO RICO, et al., (Jointly Administered) 

 

 DEBTORS 

_________________________________________________ 

 

IN RE: PROMESA 

 TITLE III 

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO, 

 as representative of No. 17 BK 4780-LTS 

PUERTO RICO ELECTRIC POWER AUTHORITY 

(“PREPA”) 

 DEBTOR 

_________________________________________________ 

MOTION FOR RELIEF FROM STAY 

TO THE HONORABLE COURT: 

COMES NOW creditor, Sucesión Sastre Wirshing, through its undersigned counsel and 

very respectfully states and prays: 

1. Pursuant to Paragraphs III.Q and III.U of Section III (Scheduling) of the Case 

Management Procedures, as amended by Order Further Amending Case Management Procedures 

(docket no. 1512), and subject to Paragraphs III. F and III.T, at least fifteen (15) business days 

prior to filing a Stay Relief Motion to continue a prepetition ordinary course civil action against a 

Debtor, the movant shall contact counsel for the Oversight Board and AAFAF by electronic-mail 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

2 

to advise them of the movant’s intent to seek relief from the automatic stay (the “Lift Stay 

Notice” and the notice period, the “Lift Stay Notice Period”). 

2. The Lift Stay Notice shall include (i) the identity of the movant and its contact 

information, (ii) the claim(s), lawsuit(s), or other proceeding(s) for which movant seeks relief 

from the automatic stay, including the relevant case number and court information, (iii) the 

amount of the claim(s) and the asserted causes of action, (iv) a brief description of the status of 

the underlying claim(s), lawsuit(s), or proceeding(s), and (v) cause as to why the stay should be 

lifted. 

3. If (i) the Debtors disagree with the movant’s request for relief from the automatic stay 

and/or (ii) the Lift of Stay Notice Period expires without the parties reaching an agreement 

governing the scope of the relief from the automatic stay, then the movant may file a Stay Relief 

Motion pursuant to Case Management Procedures. Such Stay Relief Motion must include a 

certification that the movant has met and conferred with the Debtors regarding the requested 

relief. 

4. Movant, Suseción Sastre Wirshing, in compliance with the above mentioned Order 

Further Amending Case Management Procedures, submits an unsworn statement under penalty 

of perjury certifying the undersigned counsel has taken the necessary steps to confer and/or meet 

with Debtor’s counsel and no agreement was reached. See Exhibit I. 

I. INTRODUCTION

4. On July 2, 2017, Debtor, Puerto Rico Electric Power Authority (hereinafter “PREPA”) 

by its representative and pursuant to section 315 of the Puerto Rico Oversight, Management, and 

Economic Stability Act (hereinafter “PROMESA”), the Financial Oversight and Management 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

3 

Board for Puerto Rico filed a voluntary petition in the United States District Court for the 

District of Puerto Rico under Title III of PROMESA seeking relief from creditors. 

5. PREPA has an eminent domain case pending final disposition at the Puerto Rico Court 

of First Instance in San Juan, courtroom with expertise in eminent domain, against creditor, 

Sucesión Sastre Wirshing (hereinafter “the Estate”), Puerto Rico Electric Power Authority v. 

Sucesión Sastre Wirshing, et al, civil case no. KEF2004-1226; and Sucesión Sastre Wirshing 

has an inverse condemnation suit against PREPA, Miguel Pedro Sastre Wirshing, et al v. Puerto 

Rico Electric Power Authority, et al, civil case number KAC2011-0384, pending final 

disposition at the Puerto Rico Court of First Instance in San Juan, courtroom with expertise in 

eminent domain. The cases were consolidated and on both cases on July 14, 2017, PREPA filed 

a motion at the state court requesting the automatic stay of the proceedings pursuant to sections 

362(a) and 922(a) of the Bankruptcy Code, as incorporated by reference under section 301(a) of 

PROMESA. Dated August 8, 2017, on Puerto Rico Electric Power Authority v. Sucesión Sastre 

Wirshing, et al, and September 11, 2017, on Miguel Pedro Sastre Wirshing, et al v. Puerto Rico 

Electric Power Authority, et al, the state court issued an administrative judgment staying the

proceedings. 

II. BACKGROUND

6. Dated November 17, 2004, PREPA filed a petition of eminent domain against the 

Estate at the Puerto Rico Court of First Instance in San Juan, courtroom with expertise in 

eminent domain, civil case no. KEF2004-1226. The property consists of certain piece of land 

with an area of 224.5022 square meters located at Jayuya Arriba ward in the municipality of 

Jayuya, Puerto Rico, segregated from a larger rural property owned by the Estate at the time of 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

4 

the taking. PREPA estimated the just compensation to be $10,000.00, deposited the amount with 

court and that amount was never withdrawn by the parties with interest. 

On August 25, 2005, the parties with interest, the Estate, answered the petition of eminent 

domain. The amount of just compensation estimated by PREPA was not accepted and the Estate 

claimed compensation for the usufruct of the piece of land before the taking. PREPA had the 

usufruct of the piece of land before the taking and the right expired on October 6, 1986. 

However, PREPA continued to occupy the property until the taking occurred. This fact was 

admitted by PREPA on a hearing held on November 28, 2006. 

After multiple procedural issues and after PREPA refused to amend the Exhibit A of the 

petition to include claims made by the Estate in their answer to the petition, dated November 17, 

2008, Mr. Miguel Pedro Sastre Wirshing, as receiver of the estates of Miguel Sastre Oliver and 

Margarita Wirshing Serrallés, filed an inverse condemnation suit at the Puerto Rico Court of 

First Instance in Utuado against PREPA, Miguel Pedro Sastre Wirshing, et al v. Puerto Rico 

Electric Power Authority, et al, civil case number LCD 2009-0003, claiming compensation for 

the use of their property, structures and infrastructure, among other things, from the date the 

usufruct right expired, October 6, 1986, until November 17, 2004, when the eminent domain 

petition was filed. 

Dated May 20, 2009, PREPA filed an answer to the inverse condemnation suit filed by 

Mr. Miguel Pedro Sastre Wirshing as receiver of the estates of Miguel Sastre Oliver and 

Margarita Wirshing Serrallés. After various procedurals issues, discovery completed and pre-trial 

conference having been scheduled, PREPA requested the transfer and consolidation of the 

inverse condemnation suit, civil case number LCD 2009-0003, with the eminent domain case 

pending at the Puerto Rico Court of First Instance in San Juan, courtroom with expertise in 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

5 

eminent domain, civil case no. KEF2004-1226. On March 1st, 2011, the state court granted the 

transfer request and on June 17, 2011, the cases were consolidated. The now consolidated civil 

case number LCD 2009-0003 was assigned a new number: KAC2011-0384. 

The court scheduled various pre-trial hearings that for different reasons never took place. 

Among the reasons being that PREPA never submitted their part of the Pre-Trial Conference 

Report and the resignation of PREPA’s legal representatives. 

Among the agreements reached by the expert witnesses of both parties, on a meeting held 

on April 1st, 2014, in compliance with a court order to try to reduce the controversies between 

the parties were the following: 

a) The parties agreed that the value for the use of the property that is the subject of the 

eminent domain petition from October 6, 1986, to November 17, 2004, is 

$234,792.00; 

b) The value of the property that is the subject of the eminent domain petition is 

$33,675.33; 

c) The value of the structures, except for the communication towers, in the property that 

is the subject of the eminent domain petition is $80,138.87; 

d) PREPA recognized it does not have a blueprint “as built” of the construction of the 

communication towers and that the value given by the expert of the parties with 

interest is based on the blueprint of a similar one. PREPA, subject to review by the 

Design Department, made a transactional offer of $32,400.00 for the value of the 

communication towers based on the blueprint provided by the parties with interest. 

The parties with interest would evaluate the offer and/or make a counteroffer. 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

6 

On July 17, 2017, PREPA filed the automatic stay motion due to the filing of the 

voluntary petition under Title III of PROMESA. 

III. APPLICABLE LAW 

7. Section 362(d)(1) of the Bankruptcy Code (11 U.S.C. §362(d)(1)) reads as follows: 

(d) On request of a party in interest and after 

notice and a hearing, the court shall grant relief from 

the stay provided under subsection (a) of this section, 

such as by terminating, annulling, modifying, or 

conditioning such stay -- (1) for cause, including the 

lack of adequate protection of an interest in property of 

such party in interest... 

8. The courts examine numerous different factors, including those set forth in In re 

Sonnax Indus., 907 F.2d 1280 to determine whether “cause” exists to grant relief from stay. The 

twelve factors adopted by the court in Sonnax are: 

(1) whether relief would result in partial or complete issue 

resolution; (2) lack of connection with or interference with 

bankruptcy case; (3) whether other proceeding involves debtor as 

fiduciary; (4) whether specialized tribunal with necessary expertise 

has been established to hear cause of action; (5) whether debtor's 

insurer has assumed full defense responsibility; (6) whether the 

action primarily involves third parties; (7) whether litigation in 

another forum would prejudice interests of other creditors; (8)

whether judgment claim arising from other action is subject to 

equitable subordination; (9) whether movant's success in other 

proceeding would result in a judicial lien avoidable by debtor; (10) 

interests of judicial economy and expeditious and economical 

resolution of litigation; (11) whether parties are ready for trial in 

other proceeding; (12) impact of stay on parties and balance of

harms. In re Sonnax Inds., supra, at 1287 citing In re Curtis, 40 

Bankr. 795, 799-800 (Bankr. D. Utah 1984). 

 Other courts have established that the Curtis moving party “need not prove a plurality of 

Curtis factors before it has shown cause existed for lifting the stay.” Goya Foods v. UnanueCase:17-03283-LTS Doc#:2962 Filed:04/26/18 Entered:04/26/18 16:07:43 Desc: Main

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

7 

Casal (In re Unanue-Casal), 159 B.R. 90, 96 (1993). Some courts have relied on only a few 

factors to determine that sufficient cause existed to lift the stay. See, e.g., In re Unioil, 54 Bankr. 

192, 194-195 (Bankr. D. Colo. 1985) (court considered five factors such as resolution of the 

issues, lack of connection with the bankruptcy case, judicial economy and balance of hurt). See 

also In re Highcrest Management Co., Inc., 30 Bankr. 776, 778-779 (Bankr. S.D. N.Y. 1983).

(court considered only the debtor's misconduct, without any Curtis factors). 

 The court in Goya Foods v. Unanue-Casal (In re Unanue-Casal), supra, at 96 correctly 

stated that “the question of what is cause . . . is developed primarily by case law.” In other words, 

the determination of cause is made on a case by case basis. 

 9. Article II, section 9, of the Constitution of the Commonwealth of Puerto Rico, P.R. 

Const. Art. II, § 9, states that “private property shall not be taken or damaged for public use 

except upon payment of just compensation and in the manner provided by law.” (Emphasis 

added). 

10. The Takings Clause of the Fifth Amendment mandates that “private property [shall 

not] be taken for public use, without just compensation.” U.S. Const. amend. V. This 

amendment is made applicable to the states, and thus to municipalities, through the Fourteenth 

Amendment. U.S. Const. amend. XIV. In re City of Detroit, 524 B.R. 147, 268 (Bankr. E.D. 

Mich. 2014) citing Dolan v. City of Tigard, 512 U.S. 374, 383, 114 S. Ct. 2309, 129 L. Ed. 2d 

304 (1994); Penn Cent. Transp. Co. v. City of N.Y., 438 U.S. 104, 122, 98 S. Ct. 2646, 57 L. Ed. 

2d 631 (1978). 

11. In First English Evangelical Lutheran v. Los Angeles, 482 U.S. 304, 315-16 (1987), 

the Supreme Court of the United States stated regarding the Fifth Amendment: 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

8 

This basic understanding of the Amendment makes clear that it is 

designed not to limit the governmental interference with property 

rights per se, but rather to secure compensation in the event of 

otherwise proper interference amounting to a taking. Thus, 

government action that works a taking of property rights 

necessarily implicates the "constitutional obligation to pay just 

compensation." Armstrong v. United States, 364 U.S. 40, 49 

(1960). 

We have recognized that a landowner is entitled to bring an action 

in inverse condemnation as a result of "'the self-executing 

character of the constitutional provision with respect to 

compensation. . . .'" United States v. Clarke, 445 U.S. 253, 257 

(1980), quoting 6 P. Nichols, Eminent Domain § 25.41 (3d rev. 

ed.1972). 

12. The Fourteenth Amendment of the United States Constitution provides that “nor 

shall any State deprive any person of life, liberty, or property, without due process of law.”

(Emphasis added). U.S. Const. amend. XIV. The limitations of the Fifth Amendment also apply, 

through the Due Process Clause of the Fourteenth Amendment, to takings by state governments 

and their subdivisions. See, e.g., Lucas v. S.C. Coastal Council, 505 U.S. 1003 (1992). 

Consequently, the Fifth Amendment is applicable to municipal debtors, and a municipal debtor 

may not take property without just compensation. 

13. The Supreme Court of the United States has addressed the takings issue in the context 

of bankruptcy on several occasions, holding each time that the bankruptcy power is limited by 

the Fifth Amendment. See United States v.Security Indus. Bank, 459 U.S. 70, 75, 78 (1982); 

Wright v. Vinton Branch of Mtn. Trust Bank, 300 U.S. 440, 456-58 (1937); Louisville Joint Stock 

Land Bank v. Radford, 295 U.S. 555, 589 (1935). The protections afforded by the Fifth 

Amendment are not abrogated by the Bankruptcy Code. The legislative history of the 

Bankruptcy Code indicates that the drafters of the Bankruptcy Code considered the Fifth 

Amendment to be a limitation upon the impairment of property rights in bankruptcy, and current 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

9 

bankruptcy law gives great deference to property rights. Julia Patterson Forrester, Bankruptcy 

Takings, 51 Fla. L. Rev. 851, 863 (Dec. 1999). 

IV. DISCUSION AND ARGUMENT 

14. In the case at hand, the Estate submits that the automatic stay should be modified to 

allow the state court proceedings to continue to determine the amount of damages caused by the 

taking. 

Of the twelve factors adopted by the court in Sonnax to determine if cause exists to grant 

relief from stay at least six weigh in favor of the Estate. 

First, whether relief would result in partial or complete issue resolution and second, 

whether specialized tribunal with necessary expertise has been established to hear cause of 

action. The Estate has a state eminent domain case pending final disposition at the Puerto Rico 

Court of First Instance in San Juan, courtroom with expertise in eminent domain, against PREPA 

in which certain agreements had been reached by the expert witnesses regarding the 

compensation to be paid for the taking and for the use of the property, the structures and 

infrastructure for a certain period of time before the taking occurred (between October 6, 1986, 

when a right to usufruct expired, and November 17, 2004, when the eminent domain petition was 

filed). The agreements reached by the expert witnesses were never ratified by PREPA. The 

discovery has been completed, the case is ready for a pre-trial conference and eventually for the 

trial. 

 Third, lack of connection with or interference with the bankruptcy case. The resolution 

of the consolidated cases pending at the state court will not interfere with the Title III case since 

there is no relationship between the issues and/or controversies. On June 10th, 2017 Sucesión 

Pastor Mandry Mercado, represented by the undersigned counsel, requested a relief from 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

10 

automatic stay for an inverse condemnation case stayed by the Commonwealth of Puerto Rico 

(hereinafter “Debtor”) pursuant to sections 362(a) and 922(a) of the Bankruptcy Code, as 

incorporated by reference under section 301(a) of PROMESA, were the only issue pending was 

the determination of just compensation (docket no. 305). Debtor opposed the request from relief 

from stay and the Court lifted the stay to allow the litigation to proceed to a determination of 

damages prior to the entry of judgment (Memorandum Order, docket no. 600). Moreover, the 

Court stated that “allowing the Litigation to proceed would not interfere with the Title III case.” 

(Memorandum Order, page 3, ¶2). 

Fourth, whether litigation in another forum would prejudice interests of other creditors. 

The litigation between PREPA and the Estate at the state courtroom with expertise in eminent 

domain has no direct or indirect effect on any of PREPA’s creditors. 

Fifth, the interests of judicial economy and expeditious and economical resolution of 

litigation. PREPA’s Legal Division would be responsible for handling the litigation at the state 

court. Thus, the only litigation expense will be for PREPA to hire an appraiser as expert witness 

to determine the amount of just compensation for the piece of land taken, and for the use of the 

taken piece of land, its structures and infrastructure during certain period of time before the 

taking occurred. In the alternative, removing the case from the state court to this forum will be 

in detriment to the Estate and PREPA since the costs of litigation will be very burdensome for 

both parties, e.g., translation costs. The court in In re Saunders, 103 Bankr. 298, 299 (B.C.N.D. 

Fl. 1989) allowed the stay to be lifted on the state proceedings that had begun almost two years 

before the filing of the bankruptcy petition and also found that that judicial economy was served 

because the court “could perceive no rationale for curtailing” the efforts of two years in court 

only for the court to retrace the same path. In the present case, the parties have been litigating in 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

11 

state court for almost fourteen years. Concluding the litigation at the state court will cause no 

prejudice to PREPA. 

Sixth, the impact of stay on parties and balance of harms. The Fifth Amendment and the 

Fourteenth Amendment of the United States Constitution and Article II, Section 9, of the 

Constitution of the Commonwealth of Puerto Rico provide that private property shall not be 

taken for public use without just compensation. The continuance of the stay will be detrimental 

to the Estate who will be deprived of its constitutional right to obtain a determination of damages 

for the taking of their property. Whereas, PREPA will suffer no harm if the stay is lifted. 

V. CONCLUSION 

15. The Estate has established with substantial arguments there is cause for the lifting of 

the automatic stay. Modifying the stay to allow the state court to determine the amount of just 

compensation for the piece of land taken, for the use of the taken piece of land, its structures and 

infrastructure during certain period of time before the taking occurred promotes the judicial 

economy and expeditious and economical resolution of the litigation. The Estate would then 

have a certain and allowable claim to file, facilitating PREPA the formulation of a confirmable 

plan and its eventual reorganization. 

WHEREFORE, it is respectfully prayed that the Estate be granted relief from the 

automatic stay pursuant to 11 U.S.C. §362(d)(1) as to the PREPA, and to the estate, to continue 

the proceedings at the state court civil cases no. KEF2004-1226 and KAC2011-0384 in order to 

determine the amount of just compensation for the taking, the use of the taken piece of land, its 

structures and infrastructure during certain period of time before the taking occurred, with such 

other and further relief as this Court deems just and proper. 

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Motion for Relief From Stay 

Puerto Rico Electric Power Authority v. Sucesión Miguel Sastre Wirshing, et al 

KEF2004-1226 and KAC2011-0384 

12 

CERTIFICATE: I hereby certify that pursuant to Paragraphs III.Q and III.U of 

Section III (Scheduling) of the Case Management Procedures, as amended by Order Further 

Amending Case Management Procedures (docket no. 1512), and subject to Paragraphs III. F and 

III.T, at least fifteen (15) business days prior to filing the present motion for relief from stay to 

continue a prepetition ordinary course civil action against HTA, the movant, Sucesión Sastre 

Wirshing, contacted the counsel for the Oversight Board and AFAA by electronic-mail to advise 

them of the movant’s intent to seek relief from the automatic stay and no agreement was reached. 

 RESPECTFULLY SUBMITTED. 

In Ponce, Puerto Rico, this 26th of April, 2018. 

 /s/María E. Vicéns Rivera 

 MARĺA E. VICÉNS RIVERA 

USDC- PR 226711 

9140 MARINA ST., SUITE 801 

PONCE, PUERTO RICO 00717 

TEL. / FAX: (787) 259-1999 

 E-mail: mevicens@yahoo.com 

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UNSWORN STATEMENT UNDER PENALTY OF PERJURY 

Comes now, MARIA E. VICENS RIVERA as legal representative of Sucesi6n Sastre 

Wirshing, under penalty of perjury and very respectfully declares that the foregoing is true and 

correct: 

1. On March 14, 2018, I sent an email to Herman Bauer, Esq., Ubaldo Fernandez, Esq., 

and Kevin Finger, Esq. notifying the Lift Stay Notice regarding Puerto Rico Electric Power 

Authority v. Sucesi6n Sastre Wirshing, et al, civil case no. KEF2004-1226; and Sucesi6n Sastre 

Wirshing's inverse condemnation suit against PREP A, Miguel Pedro Sastre Wirshing, et al v. 

Puerto Rico Electric Power Authority, eta!, civil case number KAC2011-0384, pending final 

disposition at the Puerto Rico Comi of First Instance in San Juan, courtroom with expertise in 

eminent domain. 

2. On April 5, 2018, I received a call from attorney Finger regarding another Lift Stay 

Notice pending and mentioned the fact that the Lift Stay Notice of Sucesi6n Sastre Wirshing was 

also pending, with the.fifteen business days expiring on April6, 2018. 

2. On April19, 2018, a second email was sent to counsels and no answer was received. 

3. On April 23, 2018, a call was placed to Katiushka Bolafios, Esq., to ask about the status 

of the Lift Stay Notice and she was not available at the moment. 

5. On April 24, 2018, an email was sent to attorney Bolafios in order to find out if a 

stipulation would be signed. Her answer was she had not received an approval from AAF AF yet. 

In Ponce, Puerto Rico, this 26th of April, 2018. 

/ / {):-._I, , 

~A~ e?~ !Jl ClMA-" 

MARiA E. VICENS RIVERA 

EXHIBIT I

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