UNITED STATES DISTRICT COURT

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.1

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

THIS DOCUMENT RELATES ONLY 

TO THIS TITLE III CASE2

NOTICE OF APPEARANCE AND REQUEST FOR SERVICE

TO THE HONORABLE LAURA TAYLOR SWAIN

UNITED STATES DISTRICT COURT JUDGE:

COMES NOW, the undersigned counsel, who respectfully states and prays as follows:

1. The Plaintiffs in the case of Jorge Abraham Giménez et al (1,046 Plaintiffs) v. 

Commonwealth (specifically, the Department of Transportation and Public Works “DTOP” for its 

initials in Spanish), Civil Case Num. K AC2013-1019, currently under advisement of the Puerto 

Rico Supreme Court, Case Num. TSPR A C2016-0120, (collectively the “Abraham Giménez

Plaintiff Group”), all creditors of the estate pursuant to the Cause of Action being prosecuted 

 

1 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number 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) Puerto 

Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of 

Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 

BK 3567-LTS) (Last Four Digits of Federal Tax ID: 3808); and (iv) 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). (Title III case numbers are listed as Bankruptcy Case numbers due to software limitations).

2 This clarification is made in accordance to the Court’s Order (A) Pursuant to PROMESA Section 304(G), Directing 

Joint Administration of Initial Title III Cases and Additional Title III Cases, and (B) Pursuant to Section 105(A) of 

The Bankruptcy Code, Making Certain Orders Entered on First Day Pleadings Applicable to the Additional Title III 

Cases. See, Docket No. 167 at ¶ 5 of p. 4.

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therein3, have retained the services of the undersigned counsel to represent them in the present 

case.

2. Therefore, the undersigned respectfully requests that all pleadings, orders, notices, 

and documents filed and entered in this case be notified upon the undersigned counsel.

WHEREFORE, it is respectfully requested from this Honorable Court to enter an order 

for all notices, pleadings, orders and documents filed in this case to be sent to the undersigned.

I HEREBY CERTIFY that on this same date, we electronically filed the foregoing with 

the Clerk of the Court using the CM/ECF system, which will send notification of such filing to all 

CM/ECF participants in this case.

RESPECTFULLY SUBMITTED,

San Juan, Puerto Rico, on this 29th day of June 2018.

/s/ Ivonne González-Morales

IVONNE GONZÁLEZ-MORALES

USDC NUM. 202701

E-mail: ivonnegm@prw.net

IVONNE GONZÁLEZ-MORALES

PO BOX 9021828

San Juan, PR 00902-1828

Tel. (787) 410-0119

 

3 The Cause of Action currently under advisement in the Puerto Rico Supreme Court is consolidated with the Cause 

of Action of the Francisco Beltrán-Cintrón Plaintiff Group v. Puerto Rico Family Department, ARV and AIJ, Case 

Num. TSPR A C2016-0120.

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