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. 24045

 

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, Badillo Saatchi & Saatchi Inc. (“BSS”), by and through the undersigned 

legal counsel, and respectfully requests as follows: 

BSS filed its Response to the Five Hundred Sixty-Ninth Omnibus Objection (Substantive) 

Of The Commonwealth Of Puerto Rico, The Puerto Rico Highways And Transportation Authority, 

And The Puerto Rico Public Buildings Authority To Claims That Are Partially Satisfied And/Or 

Partially Assert Amounts For Which The Debtors Are Not Liable on June 22, 2023. See Dkt. No.

24637 (“Response”). The Response contains the unsworn declaration under penalty of perjury 

issued by Carmen Teresa León Vicéns on June 22, 2023 (the “Declaration”) (Dkt. No. 24637-1), 

which Declaration includes certain documentation in the Spanish language. See Dkt. No. 24637-

2 – 24637-4, and 24637-8 – 24637-11. 

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).

Case:17-03283-LTS Doc#:24638 Filed:06/22/23 Entered:06/22/23 19:40:14 Desc: Main

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BSS hereby moves for leave to file Dkt. No. 24637-2 – 24637-4, and 24637-8 – 24637-11

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 22nd 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 Badillo Saatchi & Saatchi Inc.

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