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IN THE UNITED ST ATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

CENTRO DE PERIODISMO 

INVESTIGATIVO 

Plaintiff CIVIL NO. 2017-

v. 

FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR 

PUERTO RICO 

COMPLAINT FOR DECLARATORY 

RELIEF; PRELIMINARY AND 

PERMANENT INJUNCTION; 

MANDAMUS 

Defendant 

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF 

"To permit the government to manage public affairs under the mantle of secretiveness is to 

invite arbitrary actions, poor administration, goverrunental indifference, public 

irresponsibility and corruption. A citizenry which is alert and militant against these 

potential evils of all government machinery can perform its fiscalizing function only if it 

has possession of the information which will permit it to discover the potential dangers in a 

timely manner and demand responsible action. To deprive the citizenry of this information 

is equivalent to producing an aggravated collective paralysis attributable to civil myopia of 

a citizenry which knows only part of the actions of its govcrruncnt or knows only halftruth.s related thereto." 

Efren Rivera Ramos, La libertad de informaci6n: Necesidad de su 

reglamentaci6n en Puerto Rico,44 REV. )UR. UPI~ 67, 69 (1975) 

(translation provided) 

TO THE HONORABLE COURT: 

NOW COMES the plaintiff CENTRO DE PERIODISMO 

INVESTIGATIVO, (!iereinafter "CPI") represented by the undersigned attorneys 

and respectfully states and prays as follows: 

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I. INTRODUCTION 

1.1 This action for declaratory, injunctive and mandamus relief seeks access 

to information necessary to inform the citizenry of the workings of the government 

of Puerto Rico and to allow citizens to make informed decisions about their future. 

1.2 This action is brought before this court pursuant to the Declaratory 

Judgment Act, 28 U.S.C. §2201 and the All Writs Act, 28 U.C. §1651, well as the 

specific jurisdictional provisions of the "Puerto Rico Oversight, Management and 

Economic Stability Act of 2016. 

1.3 Plaintiff Centro de Periodismo Investigativo ("CPI") is a non-profit 

organization dedicated to investigative reporting, access to information litigation 

and journalist's training, as ways to obtain information necessary for the people of 

Puerto Rico to make informed decisions and better understand the realities of the 

current climate, wherein determinations are being made behlnd closed doors, or 

by people who have not been elected by the people of Puerto Rico. 

1.4 Through this action, the CPI seeks access to documents which are within 

the power and possession of the Financial Oversight and Management Board of 

Puerto Rico (hereinafter, the Junta, for its Spanish first name), an organism 

promulgated by the United States Congress, which granted the junta plenary 

powers in Puerto Rico, including the power to supersede many actions taken by 

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Puerto Rico officials elected by the citizenry. 

1.5 CPI has previously made requests to the Junta for the documents sought 

through this action, but the Junta has either ignored the requests or provided 

inadequate or incomplete documentation through its website. 

1.6 The actions of the Junta violate the Constitution of Puerto Rico, which 

guarantees access to government documents and information. 

1.7 The granting of the relief sought herein will advance the interest of the 

people of Puerto Rico, who have a right to know the events which will affect their 

daily lives and the future of Puerto Rico. 

1.8 The plaintiff is seeking solely declaratory, injunctive and mandamus 

relief, requesting access to information. No damages are sought herein. 

1.9 Accordingly, the current action bears no relationship to the recent 

"Petition for Covered Territory or Covered Instrumentality," presented by the 

Commonwealth of Puerto Rico on May 3, 2017 pursuant to Title III of the ''Puerto 

Rico Oversight Management and Stability Act" or 11PROMESA,11 hereinafter 

referred to as the "Law Creating the Junta." See, Case No. 17-01578, before Judge 

Laura Taylor Swain, appointed by the Chief Judge of the United States of America. 

II. IURISDICTION 

2.1 The jurisdiction of this court is invoked pursuant to Law Creating the 

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Junta, which in its Section 106, 48 U.S.C. §2126, provides in relevant part that" ... 

any action against the Oversight Board .... shall be brought in a United States 

district court for the covered territory ... " (i.e Puerto Rico). 

2.2 This is an action "against the Oversight Board" (otherwise known as the 

"Junta"). 

2.3 Jurisdiction is also founded on the All Writs Act, 28 U.S.C. §1651(a), 

which provides for all courts established by Act o.f Congress to issue writs 

necessary or appropriate in aid of their respective jurisdictions and agreeable to 

the usages and principles of law, including the Writ of Mandamus. 

2.4 Venue is proper in this court pursuant to the above-cited Section 106. 

III. PARTIES 

The Centro de Periodismo Investigativo 

3.1 The plaintiff Centro de Periodismo Investigativo ("CPI'') is a non-profit 

organization which was founded in 2007. 

3.2 It is a news organization which engages in investigative journalism and 

has won more than 15 national awards for its work in this field. 

3.3 The CPI has a website, www.periodismoinvestig'1tivo.com, where 

citizens inter alia can access its investigative pieces, and which is visited by some 

500,000 unique users on an annual basis. 

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3.4 Since its inception, the CPI has published articles which are available for 

free to interested readers and which have been reproduced by more than 25 other 

news media outlets in Puerto Rico, the United States and beyond. 

3.5 In addition to its work as a news medium, the CPI has two other 

important missions: to assure that the citizens of Puerto Rico have access to the 

information they require to exercise their basic rights as citizens, and to monitor 

"fiscalizar" those governmental bodies which make decisions affecting the rights 

and the future of the public. 

3.6 These two areas of work are related to litigation to assure proper access 

to information, and education and training of both professionals in the field of 

journalism and lay-people as to the right to access to information and the methods 

for assuring compliance with these rights. 

3.7 Among the employees, contractors and Board members of the CPI are 

dedicated journalists and attorneys who engage in work designed to assuring that 

the citizenry in Puerto H.ico has access to the information necessary to the exercise 

of democratic rights. 

3.8 As stated on its website, "the CPI recognizes that the fundamental 

requirement for a true democracy is that the citizenry be well informed ... " The 

CPI engages in work to avoid the citizens being "ill informed, unaware of 

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important truths, and limited in their capacity to democratically monitor those 

who hold power. Being convinced that these tendencies have to be combated, this 

is the vision that nourishes the CPI and all of its work." (Translation supplied) 

3.9 11With this vision in mind, [the CPI] was organized as an autonomous 

non-profit entity, which allows it to act with independence from political and 

commercial interests." (Id., Translation supplied). 

The Financial Oversight and Management Board for Puerto Rico 

3.10 The Financial Oversight and Management Board for Puerto Rico ("the 

Junta") was created by virtue of the provisions of the "Puerto Rico Oversight, 

Management, and Economic Stability Act," Public Law 114-187, approved by the 

1141

h Congress of the United States on June 30,2016, and signed by then President 

Barack Obama. 48 U.S.C. §2121(b)(1). 

3.11 The Junta was established pursuant to Congress's invocation of its 

power under Article IV §3 of the Constitution of the United States, commonly 

known as the Territorial Clause. This Clause grants plenary power to the 

Congress of the United States to dispose of and make all "needful Rules and 

Regulations" for the territory held by the Uni.ted States. 

3.12 According to Public Law 114-187, "the purpose of the Oversight Board 

is to provide a method for [Puerto Rico J to achieve fiscal responsibility and access 

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to the capital markets." 48 U.S.C §2121(a). 

3.13 Public Law 114-187 provides that the Junta is to be considered "an 

entity within the territorial government for which it is established ... " (i.e. Puerto 

Rico), 48 U.S.C §2I2I(c)(l), and all expenses of the Junta are paid for by the 

Government of Puerto Rico. 48 U.S.C §2127(b). 

3.14 Congress has provided that the Junta ''shall not be considered to be a 

department, agency, establislunent, or instmmentality of the Federal 

Government." 48 U.S.C §2121(c)(2). 

3.15 The seven members of the Junta were all appointed by the President of 

the United States. Two members of the Junta were selected from a list submitted 

by the Speaker of the House of Representatives, Paul Ryan. Two were selected 

from a list submitted by the Majority Leader of the Senate, Mitch McConnell. Two 

others were selected from a list submitted by the Minority Leader of the House of 

Representatives, Nancy Pelosi, and two were selected from a list submitted by the 

Minority Leader of the Senate of the United States, Harry Reid. The final member 

was selected by then President Barack Obama. See, 48 U.S.C §2121(e) 

3.16 The Governor of Puerto Rico is an ex officio member of the Junta, 

without any voting rights. 48 U.S.C §212.1(e)(3). 

3.17 Among other things, the Junta has the power to /1 secure copies, 

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whether written or electronic, of such records, documents, information, data or 

metadata from the territorial government (Puerto Rico) necessary to enable the 

Oversight Board to carry out its responsibilities ... At the request of the Oversight 

Board [it[ shall be granted direct access to such information systems, records, 

documents, information or data as will enable [it] to carry out its responsibilities 

under this Act." 48 U.S.C §2124(c ). 

IV. FACTS 

4.1 For the first several months after Public Law 114-187 was passed, there 

was a lengthy process of selecting the members of the Junta. 

4.2. After the Junta's members were selected, it held its first meeting in the 

City of New York on September 30, 2016, where the President of the Junta was 

selected and its By-laws were adopted. 

4.3 Although the September 3Qth meeting was open to the public, the 

detern:tinations reached therein had been previously agreed to by the Junta. 

4.4 As part of the first public meeting of the Junta on September 30, 2016, 

the President of the Junta, Jose Carrion stated during the press conference that the 

members of the Junta had gone through a "rigorous process" with the United 

States Department of the Treasury, prior to their selection as members of the Junta, 

during which they submitted financial disclosure and conflict of interest 

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documents. 

4.5 During that same meeting, the Junta requested the Government of 

Puerto Rico a number of documents, including the following: 

a. Weekly cash flow reports, including all revenues received and all 

expenses paid (including any debt service) and broken down by main categories; 

b. Monthly downloads of bank account data and statements of all principal 

banking accounts (provided directly to the Board of each bank); 

c. Monthly and year to date report of compliance with the current approved 

budget by budgetary fund and by agency (including local special funds and 

federal funds); 

d. Monthly and year to date detailed report on revenues and a narrative 

about collection efforts and main initiatives of the Puerto Rico Treasury 

Department; 

e. Monthly detailed payroll reports by agency; 

f. Monthly reports on federal funds received and disbursed by area and by 

agency; 

g. Monthly reports of all debt obligations due this current fiscal year and 

which have been paid; and 

h. Quarterly report on each agency's productivity and performance with 

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appropriate metrics and a narrative description. 

i. Quarterly report on key Puerto Rico economic, financial, social and labor 

statistics. 

4.6 On October 24, 2017, the Junta contracted the services of Forculus PR 

(also known as Forculus Strategic Communications), a firm specializing in 

communications, public relations and media management services, with a 

Resident Agent in the Beverly Hills sector in Puerto Rico. 

4.7 This firm, whose employees and/ or contractors include Edward Zayas 

and Jose Cedeno, was hired by the Junta to inter alia develop and market the 

"reputation (branding) of the Junta and its members." (Parenthesis in the original). 

4.8 As set forth in the website for Forculus PR, this firm has performed 

communications, public relations and media management services for the 

Government of Puerto Rico, including the Government Development Bank of 

Puerto Rico, and its "Public-Private Partnership Arm, the Puerto Rico Industrial 

Development Company" (Fomento), as well as "the Office of the Governor of 

Puerto Rico and the Office of Management and Budget." 

4.9 In corrununications with Jose Cedeno, the CPI was informed that all 

press requests had to be made through Forculus, PR using official emails 

jcedeno@forculuspr.com and ezayas@forculuspr.com. 

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4.10 At all times relevant to this complamt and as to the matters set forth 

herein, Forculus PR, and its agents, including employees and/ or contractors 

Edward Zayas and Jose Cedeno, acted as agents of the Junta. 

4.11 On November 16, 2016, Joel Cintron Arbasetti, a reporter with the CPI, 

made a request to Edward Zayas, of Forculus, PR, to be given to access to any and 

all of the documents listed in if4.5 above, which were supposed to be provided by 

the Government of Puerto Rico to the Junta. 

4.12 Since September 30, 2016, Carla Minet, a veteran journalist who is the 

Executive Director of the CPI, requested the federal Office of Government Ethics 

(OGE) to provide the CPI with all financial disclosure and conflict of interest 

documents which the seven members of the Junta were supposed to submit during 

their evaluation process. Ms. Minet also submitted the request to the United States 

Department of Treasury and to The White House, as suggested by Junta President 

Carrion and the OGE. 

4.13 Ms. Minet was informed by the OGE on a follow-up phone 

conversation that the documents had to be requested from the Junta, rather than 

from the federal agencies. 

4.14 On December 12, 2016, Ms. Minet dfrected an email to Edward Zayas 

and Jose Cedeno of Forculus PR in which, on behalf of the CPI, she requested all 

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financial disclosure and conflict of interest documents which the seven members of 

the Junta submitted to the United States Department of Treasury, as stated by 

Junta President Carri6n during the September 30th meeting referenced at -n-n4.2 -

4.4 above. 

4.15 Ms. Min.et indicated to Messrs. Zayas and Cedeno that a prompt 

response was required, since the CPI was working on a news article for which the 

information was required. 

4.16 On that same day, Mr. Cedeno responded to Ms. Mi.net that her request 

would be "processed" and that a response "would be offered as soon as possible." 

(Translation provided). 

4.17 Subsequent emails with respect to these matters yielded no response 

from the Junta. 

4.18 On February 9, 2017, CPI Executive Director Carla Minet did additional 

follow-up with respect to the requests made on November 16, 2016 by CPI 

reporter Joel Cintr6n Arbasetti. 

4.19 At that time, Ms. Minet also followed up with respect to a separate 

corrununication which had been sent on December 12th, 2016, wherein Ms. Minet 

solicited additional documents and information from the Junta, via Edward Zayas, 

from Forculus PR. 

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4.20 The documents requested in the February 9th communication included 

the following: (a) records relating to communications, inquiries or requests for 

information, documents, reports or data by any member of the Junta and/ or its 

staff to any agency of the federal government or federal government official, or by 

the federal government, its agencies or staff, to the Junta; (b) communications, 

reports, consultations, updates, documents or information provided by any 

member of the Junta and/or its staff to La Fortaleza, its officers, or any other 

agency or official of the Government of Puerto Rico, or by the Government of 

Puerto Rico to the Junta, its members or staff; (c) contracts granted by the Junta to 

private entities (also originally requested on November 11, 2016); (d) protocols, 

regulations, manuals or memorandums generated by the Junta to conduct its 

work; and (e) minutes of meetings held by the Junta and its committees or its 

members. 

4.21 On or about February 28, 2017, the Junta published on its website 

certain financial information forms regarding the individual members of the Junta. 

The documents of the seven board members were dated in February 2017. 

4.22 On the following day, March 1, 2017, Ms. Minet, on behalf of the CPI, 

directed a number of questions to the Junta regarding the documents published on 

the website. 

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4.23 In her March 1st email to Edward Zayas, of Forculus PR, Ms. Minet 

requested inter alia the following information: whether the published documents 

were the same ones submitted to the U.S. Department of the Treasury, as part of 

the "rigorous process" referred to by Junta President Jose Carrion in the meeting 

in New York on September 30, 2016, as set forth in ~~4.2 to 4.4 abovei to which 

agency the documents were submitted; why there was missing information on the 

documents, including but not limited to the signatures of the Ethics official, salary 

information for some of the Junta member, and financial information concerning 

spouses of the Board members. 

4.24 Ms. Minet indicated to Mr. Zayas that the inquiries were urgent, since 

the information was needed for a deadline for publication later that day. 

4.25 To date, neither Forculus PR nor the Junta has provided any 

substantive response to the inquiries and document requests set forth at ,1,14.5 and 

4.26 To date, the CPI has received no response to the inquiries made in Ms. 

11 On February 10•h, 2017, the CPI received from the Commonwealth of Puerto Rico ce1tain documents, in 

response to similarrequesls for infonnation which had been directed to the Commonwealth itself. The documents 

are as follows: Letter to Governor and to newly elected Govem()r, December 20, 2016; Press Communique of the 

Junta, January 18, 2017; Letter from tl1e Junta to Govemor Rossel16, January 18, 2017; Press Conununique, 

January 20, 2017; Letter from Governor Rossell6 a the Junta, January 21, 2017; Letter from Governor Rossell6 to 

the Junta, January 23, 2017; Liquidity Plan, January 28, 2017; Puerto Rico fiscal update, January 28, 2017; Debt 

service payments, February I, 2017; Letter from the Junta to Elias Sanchez, Febrnary 7, 2017. With the exception 

of the document related to debt service payments, all of these documents can be found on the website of the Junta. 

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Minet' s email of March 1, 2017. 

V. CAUSE OF ACTION 

5.1 In declarations made when he announced the appointment of the seven 

members to the Junta, then President Barack Obama stated that "[i]n order to be 

successful, the Financial Oversight and Management Board will need to establish 

an open process for working with the people and Government of Puerto Rico ... [in 

order to build] a better future for all Puerto Ricans." 

5.2 Since the Junta is not considered a federal organism, but rather is "an 

entity within the territorial government for which it is established ... " (i.e. Puerto 

Rico),48 U.S.C §2121(c)(1), and all expenses of the Junta are paid for by the 

Government of Puerto Rico, 48 U.S.C §2127(b), the Constitution and laws of the 

Commonwealth of Puerto Rico apply to its operations. 

5.3 Pursuant to Section 4 of the "Puerto Rico Oversight, Management, and 

Economic Stability Act," 48 U.S.C §2103, Puerto Rico law applies with respect to 

the operation of the Junta, as long as it is not "inconsistent with [the] Act." 

5.4 There is nothing inconsistent between the right of access to information 

and the Act establishing the Junta. 

5.5 In point of fact, providing access to the requested documents would 

further the purpose of the Financial Oversight and Management Board, as publicly 

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stated by the then President of the United States, Barack Obama, set forth in ~5.1 

above. 

5.6 Under the Constitution of Puerto Rico, there exists an undisputed right 

of the people to access information produced or in the power of the Government of 

Puerto Rico. 

5.7 This right derives from the Constitution of Puerto Rico and is considered 

a fundamental human right. See, for example, Trans Ad PR v. Jrmta Subastas, 174 

DPR 56, 67 (2008); Col6n Cabrera v. Caribbean Petroleum, 170 DPR 582, 590 (2007); 

Ortiz v. Dir. Adm. Tribunales, 152DPR161, 175 (2000). 

5.8 The Supreme Court of Puerto Rico has observed that this right is a 

critical component of the rights of free speech, free press and freedom of 

association set forth explicitly in the Bill of Rights, Article II of the Constitution of 

the Commonwealth of Puerto Rico. See, eg., Soto v. Srio. Justicia, 12 P.R. Offic. 

Trans. 597, 607-608 (1982). 

5.9 As expressed by the Puerto Rico Supreme Court, access to information 

constitutes an important component of a democratic society, in which the citizen 

can issue an informed judgment regarding the actions of the government. Col6n 

Cabrera, 170 DPR at 590. The right to redress grievances is also implicated, in that 

without knowledge of the facts, one cannot judge, nor demand remedies with 

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respect to grievances against the government either through judicial or electoral 

processes. 

5.10 Given the importance of this right under the Constitution of Puerto 

Rico, the Government cannot deny access to documents capriciously. 

5.11 The Junta, as an organism "within" the government of Puerto Rico, 

has a ministerial duty to comply with the Constitution of Puerto Rico with respect 

to the public nature of the information and documents sought herein. 

5.12 The critical role of the press in guaranteeing access to information has 

also been recognized in the Constitutional law of Puerto Rico. "[T]he press. 

constitutes a vehicle of information and opinion to inform and educate the public, 

to offer criticism, to provide a forum for discussion and debate, and to act as a 

surrogate to obtain for readers news and information that individual citizens could 

not or would not gather on their own." Santiago v. Bobby El Mundo, 17 P.R. Offic. 

Trans. 182, 190 (1986) (citing B. F. Chamberlain & J. Brown, The First Amendment 

Reconsidered 110, New York, Longman (1982)). 

5.13 The right of access to information is also codified in Article 409 of the 

C6digo de Enjuiciamiento Civil, 32 LPRA § 1781 (2015), which provides for access 

to "public documents" in Puerto Rico. 

5.14 To date, the Junta has held seven (7) public meetings on the following 

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dates: October 14, 2016 (New York)i November 18, 2016 (Fajardo, Puerto Rico); 

January 28, 2017 (Fajardo, Puerto Rico)i March 13, 2017 (New York); March 31, 

2017 (San Juan, Puerto Rico)i and April 28, 2017 (New York). 

5.15 Other than the brief public sessions, largely to reaffirm decisions 

already made, and the placement of some selected documents on its website, the 

Junta has not provided the citizenry of Puerto Rico with substantive access to the 

proceedings of the Junta, which take place behind closed doors. 

5.16 The Centro de Periodismo Investigativo has attempted to obtain 

documents which are critical for providing the citizens of Puerto Rico with the 

access to information guaranteed under the Constitution and Laws of Puerto Rico 

and to allow the CPI, as an important and respected news organization, to provide 

information to the citizens regarding the operations of the Junta. 

5.17 These efforts by the CPI have been met with stonewalling on the part of 

the Junta and its designated marketing and branding group. Forculus PR. 

- 5.18 Access to the information requested by the CPI is essential to assure an 

informed citizeruy and the validation of the rights existing under the Constitution 

and laws of Puerto H.ico. 

5.19 The aforementioned rights apply to the Junta, as they are not 

inconsistent with Law 114-187. 

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5.20 Since Congress designated the Junta not only to be paid for by the 

people of Puerto Rico, but also to be an entity "within" the goverruncnt of Puerto 

Rico, the Constitution and laws of the Commonwealth of Puerto Rico apply to the 

Junta. 

5.21 There is no adequate remedy at law to address the fundamental 

constitutional harms for which redress is sought herein. 

5.22 The citizens of Puerto Rico and the population served by the 

investigative and reporting work done by the CPI will be irreparably harmed if the 

relief requested herein is not granted. 

5.23 The public interest will be served by the granting of the relief 

requested herein, be it in the form of injunctive relief or through the issuance of a 

writ of Mandamus. 

5.24 Mandamus is an appropriate writ to assure that Junta exercises its 

ministerial duty to assure compliance with the Constitution and laws of Puerto 

Rico. 

WHEREFORE, the plaintiff Centro de Periodismo Investigativo hereby 

requests the following relief: 

1. A Declaratory Judgment that the actions of the Junta in effectively 

denying access to the documents and information set forth in ~1[4.4 to 4.26 above. 

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2. Issue a preliminary injunction and a permanent injunction ordering the 

Junta to deliver to the Centro de Periodismo lnvestigativo the following 

documents: 

a. ·weekly cash flow reports, including all revenues received and all 

expenses paid (including any debt service) and broken down by main categories; 

b. Monthly downloads of bank account data and statements of all principal 

banking accounts (provided directly to the Board of each bank); 

c. Monthly and year to date report of compliance with the current approved 

budget by budgetary fund and by agency (including local special funds and 

federal funds); 

d. Monthly and year to date detailed report on revenues and a narrative 

about collection efforts and main initiatives of the Puerto Rico Treasury 

Department; 

e. Monthly detailed payroll reports by agency; 

f. Monthly reports on federal funds received and disbursed by area and by 

agency; 

g. Monthly reports of all debt obligations due this current fiscal year and 

which have been paid; and 

h. Quarterly report on each agency's productivity and performance with 

20 

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appropriate metrics and a narrative description. 

i. Quarterly report on key Puerto Rico economic, financial, social and labor 

statistics. 

j. All financial statements and other financial and conflict of interest 

submissions made by the members of the Junta prior to their designations or 

subsequent thereto. 

k. Records relating to communications, inquiries or requests for 

information, documents, reports or data by any member of the Junta and/ or its 

staff to any agency of the federal government or federal goverrunent official, or by 

the federal goverrunent, its agencies or staff, to the Junta; 

1. Communications, reports, consultations, updates, documents or 

information provided by any member of the Board and/ or its staff to La Fortaleza, 

its officers, or any other agency or official of the Goverrunent of Puerto Rico, or by 

the Government of Puerto Rico to the Junta, its members or staff; 

m. Contracts granted by the Junta to private entities; 

n. Protocols, regulations, manuals or memorandums generated by the Junta 

to conduct its work; 

o. Minutes of meetings held by the Junta, its committees or its members; 

p. Complete financial disclosure forms for all Junta members. 

21 

I 

1. 

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3. Issue a Writ of Mandamus requiring the Junta to comply with its 

ministerial duty to provide the information and documents set forth in the 

previous paragraph. 

4. Issue whatever other relief this court deems just and appropriate. 

In San Juan Puerto Rico, this tst day of June, 2017. 

Respectfully Submitted 

Berkan/Mendez 

Calle O'Neill G-11 

San Juan, Puerto Rico 00918-2301 

Tel.: (787) 764-0814 

Fax.: (787)250-0986 

bermen@prtc.net 

By: /s/ ]udith Berkan 

Judith Berkan 

US DC No. 200803 

berkanj@rnicroj uris. com 

/s/ Steven Lausell Recurt 

Steven Lausell Recurt 

USDC No. 226402 

slausell@gmail.com 

(787) 751-1912 

22 

~ 1 

i 

I 

i 

f 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

CENTRO DE PERIODISMO 

INVESTIGATIVO 

Plaintiff CIVIL NO. 2017-

v. 

FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR 

PUERTO RICO 

COMPLAINT FOR DECLARATORY 

RELIEF; PRELIMINARY AND 

PERMANENT INJUNCTION; 

MANDAMUS 

Defendant 

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF 

"To permit the goverrunent to manage public affairs under the mantle of secretiveness is to 

invite arbitrary actions, poor administration, govenunental indifference, public 

irresponsibility and corruption. A citizeruy which is alert and militant against these 

potential evils of all govemment machinery can perform its fiscalizing function only if it 

has possession of the information which will permit it to discover the potential dangers in a 

timely manner and demand responsible action. To deprive the citizcruy of this information 

is equivalent to producing an aggravated collective paralysis attributable to civil myopia of 

a citizcruy which knows only part of the actions of its government or knows only halftruths related thereto." 

Efren mvera Ramos, La libertad de infonnaci6n: Necesidad de SU 

reglamentaci6n en Puerto Rico,44 REV. JUR. UPR 67, 69 (1975) 

(translation provided) 

TO THE HONORABLE COURT: 

NOW COMES the plaintiff CENTRO DE PERIODISMO 

INVESTIGATIVO, (hereinafter "CPT") represented by the undersigned attorneys 

and respectfully states and prays as follows: 

1 

r ' 

i 

I f 

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I. INTRODUCTION 

1.1 lhis action for declaratory, injunctive and mandamus relief seeks access 

to information necessary to inform the citizemy of the workings of the government 

of Puerto Rico and to allow cifuens to make informed decisions about their future. 

1.2 lhis action is brought before this court pursuant to the Declaratory 

Judgment Act, 28 U.S.C. §2201 and the All Writs Act, 28 U.C. §1651, well as the 

specific jurisdictional provisions of the "Puerto Rico Oversight, Management and 

Economic Stability Act of 2016. 

1.3 Plaintiff Centro de Periodismo Investigativo ("CPI") is a non-profit 

organization dedicated to investigative reporting, access to information litigation 

and journalist's training, as ways to obtain information necessary for the people of 

Puerto Rico to make informed decisions and better understand the realities of the 

current climate, wherein determinations are being made behind closed doors, or 

by people who have not been elected by the people of Puerto Rico. 

1.4 Through this action, the CPI seeks access to documents which arc within 

the power and possession of the Financial Oversight and Management Board of 

Puerto Rico (hereinafter, the Junta, for its Spanish first name), an organism 

promulgated by the United States Congress, which granted the Junta plenary 

powers in Puerto Rico, including the power to supersede many actions taken by 

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Puerto Rico officials elected by the citizenry. 

1.5 CPI has previously made requests to the Junta for the documents sought 

through this action, but the Junta has either ignored the requests or provided 

inadequate or incomplete documentation through its website. 

1.6 The actions of the Junta violate the Constitution of Puerto Rico, which 

guarantees access to government documents and information. 

1.7 The gr.anting of the relief sought herein wilt advance the interest of the 

people of Puerto Rico, who have a right to know the events which will affect their 

daily lives and the future of Puerto Rico. 

1.8 The plaintiff is seeking solely declaratory, injunctive and mandamus 

relief, requesting access to information. No damages are sought herein. 

1.9 Accordingly, the current action bears no relationship to the recent 

"Petition for Covered Territory or Covered Instrumentality," presented by the 

Commonwealth of Puerto Rico on May 3, 2017 pursuant to Title III of the "Puerto 

Rico Oversight Management and Stability Act" or 11PROMESA," hereinafter 

referred to as the "Law Creating the Junta." See, Case No. 17-01578, before Judge 

Laura Taylor Swain, appointed by the Chief Judge of the United States of America. 

II. JURISDICTION 

2.1 The jurisdiction of this court is invoked pursuant to Law Creating the 

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Junta, which in. its Section 106, 48 U.S.C. §2126, provides in relevant part that"··' 

any action against the Oversight Board .... shall be brought in a United States 

district court for the covered territory ... " (i.e Puerto Rico). 

2.2 This is an action "against the Oversight Board" (otherwise known as the 

"Junta"). 

2.3 Jurisdiction is also founded on the All Writs Act, 28 U.S.C. §1651(a), 

which provides for all courts established by Act of Congress to issue writs 

necessary or appropriate in aid of their respective jurisdictions and agreeable to 

the usages and principles of law, including the Writ of Mandamus. 

2.4 Venue is proper in this court pursuant to the above-cited Section 106. 

III. PARTIES 

The Centro de Periodismo Investigativo 

3.1 The plaintiff Centro de Periodismo lnvestigativo ("CPI") is a non-profit 

organization which was founded in 2007. 

3.2 It is a news organization which engages in investigative journalism and 

has won more than 15 national awards for its work in this field. 

3.3 The CPI has a website, W'ti\rw.periodismoi.nvestigativo.com, where 

citizens inter alia can access its investigative pieces, and which is visited by some 

500,000 unique users on an annual basis. 

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3.4 Since its inception, the CPI has published articles which are available for 

free to interested readers and which have been reproduced by more than 25 other 

news media outlets in Puerto Rico, the United States and beyond. 

3.5 In addition to its work as a news medium, the CPI has two other 

important missions: to assure that the citizens of Puerto Rico have access to the 

information they require to exercise their basic rights as citizens, and to monitor 

11 fiscalizar" those governmental bodies which make decisions affecting the rights 

and the future of the public. 

3.6 These two areas of work are related to litigation to assure proper access 

to information, and education and training of both professionals in the field of I 

r 

journalism and lay-people as to the right to access to information and the methods 

for assuring compliance with these rights. 

3.7 Among the employees, contractors and Board members of the CPI are 

dedicated journalists and attorneys who engage in work designed to assuring that 

the citizenry in Puerto Rico has access to the information necessary to the exercise 

of democratic rights. 

3.8 As stated on its website, "the CPI recognizes that the fundamental 

requirement for a true democracy is that the citizenry be well informed ... " The 

CPI engages in work to avoid the citizens being 11 ill informed, unaware of 

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important truths, and limited in their capacity to democratically monitor those 

who hold power. Being convinced that these tendencies have to be combated, this 

is the vision that nourishes the CPI and all of its work." (Translation supplied) 

3.9 "With this vision in mind, [the CPI] was organized as an autonomous 

non-profit entity, which allows it to act with independence from political and 

commercial interests." (Id., Translation supplied). 

The Financial Oversight and Management Board for Puerto Rico 

3.10 The Financial Oversight and Management Board for Puerto Rico ("the 

Junta") was created by virtue of the provisions of the "Puerto Rico Oversight, 

Management, and Economic Stability Act/' Public Law 114-187, approved by the 

114th Congress of the United States on June 30,2016, and signed by then President 

Barack Obama. 48 U.S.C. §2121(b)(l). 

3.11 The Junta was established pursuant to Congress's invocation of its 

power under Article IV §3 of the Constitution of the United States, conunonly 

known as the Territorial Clause. This Clause grants plenary power to the 

Congress of the United States to dispose of and make all "needful Rules and 

Regulations" for the territory held by the United States. 

3.12 According to Public Law 114-187, "the purpose of the Oversight Board 

is to provide a method for [Puerto RicoJ to achieve fiscal responsibility and access 

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to the capital mar.kets." 48 U.S.C §2121(a). 

3.13 Public Law 114-187 provides that the Junta is to be considered "an 

entity within the territorial government for which it is established ... " (i.e. Puerto 

Rico), 48 U.S.C §2121(c)(l), and all expenses of the Junta are paid for by the 

Government of Puerto Rico. 48 U.S.C §2127(b). 

3.14 Congress has provided that the Junta "shall not be considered to be a 

department, agency, establishment, or instrumentality of the Federal 

Government." 48 U.S.C §2121(c)(2). 

3.15 The seven members of the Junta were all appointed by the President of 

the United States. Two members of the Junta were selected from a list submitted 

by the Speaker of the House of Representatives, Paul Ryan. Two were selected 

from a list submitted by the Majority Leader of the Senate, Mitch McConnell. Two 

others were selected from a list submitted by the Minority Leader of the House of 

Representatives, Nancy Pelosi, and two were selected from a list submitted by the 

Minority Leader of the Senate of the United States, Harry Reid. The final member 

was selected by then President Barack Obama. See, 48 U.S.C §2121(e) 

3.16 The Governor of Puerto Rico is an ex officio member of the Junta, 

without any voting rights. 48 U.S.C §2121(e)(3). 

3.17 Among other things, the Junta has the power to "secure copies, 

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whether written or electronic, of such records, documents, information, data or 

rnetadata from the territorial government (Puerto Rico) necessary to enable the 

Oversight Board to carry out its responsibilities ... At the request of the Oversight 

Board [it[ shall be granted direct access to such information systems, records, 

documents, information or data as will enable [it] to carry out its responsibilities 

under this Act." 48 U.S.C §2124(c ). 

IV.FACTS 

4.1 For the first several months after Public Law 114-187 was passed, there 

was a lengthy process of selecting the members of the Junta. 

4.2. After the Junta's members were selected, it held its first meeting in the 

City of New York on September 30, 2016, where the President of the Junta was 

selected and its By-laws were adopted. 

4.3 Although the September 3Qth meeting was open to the public, the 

determinations reached therein had been previously agreed to by the Junta. 

4.4 As part of the first public meeting of the Junta on September 30, 2016, 

the President of the Junta, Jose Carrion stated during the press conference that the 

members of the Junta had gone through a "rigorous process" with the United 

States Department of the Treasury, prior to theix selection as members of the Junta, 

during which they submitted financial disclosure and conflict of interest 

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documents. 

4.5 During that same meeting, the Junta requested the Goverrunent of 

Puerto Rico a number of documents, including the following: 

a. Weekly cash flow reports, including all revenues received and all 

expenses paid (including any debt service) and broken down by main categories; 

b. Monthly downloads of bank account data and statements of all principal 

banking accounts (provided directly to the Board of each bank}; 

c. Monthly and year to date report of compliance with the current approved 

budget by budgetary fund and by agency (including local special funds and 

federal funds); 

d. Monthly and year to date detailed report on revenues and a narrative 

about collection efforts and main initiatives of the Puerto Rico Treasury 

Department; 

e. Monthly detailed payroll reports by agency; 

f. Monthly reports on federal funds received and disbursed by area and by 

agency; 

g. Monthly reports of all debt obligations due this current fiscal year and 

which have been paid; and 

h. Quarterly report on each agency's productivity and performance with 

9 

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appropriate metrics and a narrative description. 

i. Quarterly report on key Puerto Rico economic, financial, social and labor 

statistics. 

4.6 On October 24, 2017, the Junta contracted the services of Forculus PR 

(also known as Forculus Strategic Communications), a firm specializing in 

communications, public relations and media management services, with a 

Resident Agent in the Beverly Hills sector in Puerto Rico. 

4.7 This firm, whose employees and/ or contractors include Edward Zayas 

and Jose Cedeno, was hired by the Junta to inter alia develop and market the 

"reputation (branding) of the Junta and its members." (Parenthesis in the original). 

4.8 As set forth in the website for Forculus PR, this firm has performed 

communications, public relations and media management services for the 

Government of Puerto Rico, including the Government Development Bank of 

Puerto Rico, and its "Public-Private Partnership Arm, the Puerto Rico Industrial 

Development Company" (Fomento ), as well as /1 the Office of the Governor of 

Puerto Rico and the Office of Management and Budget." 

4.9 In communications with Jose Cedeno, the CPI was informed that all 

press requests had to be made through Forculus, PR using official emails 

jcedeno@forculuspr.com and ezayas@forculuspr.com. 

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4.10 At all times relevant to this complaint and as to the matters set forth 

herein1 Forculus PR, and its agents, including employees and/ or contractors 

Edward Zayas and Jose Cedeno, acted as agents of the Junta. 

4.11 On November 16, 2016, Joel Cintron Arbasetti., a reporter with the CPI, 

made a request to Edward Zayas, of Forculus, PR, to be given to access to any and 

all of the documents listed in 1[4.5 above, which were supposed to be provided by 

the Government of Puerto Rico to the Junta. 

4.12 Since September 30, 2016, Carla Minet, a veteran journalist who is the 

Executive Director of the CPI, requested the federal Office of Government Ethics 

(OGE) to provide the CPI with all financial disclosure and conflict of interest 

documents which the seven members of the Junta were supposed to submit during 

their evaluation process. Ms. Minet also submitted the request to the United States 

Department of Treasury and to The White House, as suggested by Junta President 

Carrion and the OGE. 

4.13 Ms. Minet was informed by the OGE on a follow-up phone 

conversation that the documents had to be requested from the Junta, rather than 

from the federal agencies. 

4.14 On December 12, 2016, Ms. Minet directed an email to Edward Zayas 

and Jose Cedeno of Forculus PR, in which, on behalf of the CPI, she requested all 

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financial disclosure and conflict of interest documents which the seven members of 

the Junta submitted to the United States Department of Treasury, as stated by 

Junta President Carrion during the September 30th meeting referenced at ifif4.2 -

4.4 above. 

4.15 Ms. Minet indicated to Messrs. Zayas and Cedeno that a prompt 

response was required/ since the CPI was working on a news article for which the 

information was required. 

4.16 On that same day, Mr. Cedeno responded to Ms. Minet that her request 

would be '/processed// and that a response "would be offered as soon as possible." 

(Translation provided). 

4.17 Subsequent emails with respect to these matters yielded no response 

from the Junta. 

4.18 On February 9, 2017/ CPI Executive Director Carla Minet did additional 

follow-up with respect to the requests made on November 16/ 2016 by CPI 

reporter Joel Cintron Arbasetti. 

4.19 At that time, Ms. Minet also followed up with respect to a separate 

communication which had been sent on December 12th, 2016, wherein Ms. Minet 

solicited additional documents and information from the Junta, via Edward Zayas/ 

from Forculus PR. 

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4.20 The documents requested in the February 9th communication included 

the following: (a) records relating to conununications, inquiries or requests for 

information, documents, reports or data by any member of the Junta and/ or its 

staff to any agency of the federal government or federal government official, or by 

the federal government, its agencies or staff, to the Junta; (b) communications, 

reports, consultations, updates, documents or information provided by any 

member of the Junta and/ or its staff to La Fortaleza, its officers, or any other 

agency or official of the Government of Puerto Rico, or by the Government of 

Puerto Rico to the Junta, its members or staff; (c) contracts granted by the Junta to 

private entities (also originally requested on November 11, 2016); (d) protocols, 

regulations, manuals or memorandums generated by the Junta to conduct its 

work; and (e) minutes of meetings held by the Junta and its committees or its 

members. 

4.21 On or about February 28, 2017, the Junta published on its website 

certain financial information forms regarding the individual members of the Junta. 

The documents of the seven board members were dated in February 2017. 

4.22 On the following day, March 1, 2017, Ms. Minet, on behalf of the CPI, 

directed a number of questions to the }Wlta regarding the documents published on 

the website. 

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4.23 In her March 1st email to Edward Zayas, of Forculus PR, Ms. Minct 

requested inter alia the following information: whether the published documents 

were the same ones submitted to the U.S. Department of the Treasury, as part of 

the "rigorous process" referred to by Junta President Jose Carri6n in the meeting 

in New York on September 30, 2016, as set forth in ifif4.2 to 4.4 above; to which 

agency the documents were submitted; why there was missing information on the 

documents, including but not limited to the signatures of the Ethics official, salary 

information for some of the Junta member, and financial information concerning 

spouses of the Board members. 

4.24 Ms. Minet indicated to Mr. Zayas that the inquiries were urgent, since 

the information was needed for a deadline for publication later that day. 

4.25 To date, neither Forculus PR nor the Junta has provided any 

substantive response to the inquiries and document requests set forth at 11~4.5 and 

~~4.11-4.21 above.n 

4.26 To date, the CPI has received no response to the inquiries made in Ms. 

11 On February JO'\ 2017, the CPI received from the Commonwealth of Puc1to Rico certain documents, in 

response to similar requests for information which had been directed to the Commonwealth itself. The documents 

are as follows: Letter to Governor and to newly elected Governor, December 20, 2016; Press Communique of the 

Junta, January 18, 2017; Letter from the Junta to Governor Rossell6, January I 8, 2017; Press Communique, 

January 20, 2017; Letter from Governor R.ossel16 a the Jwtta, January 21, 2017; Letter from Governor Rosscll6 to 

the Junta, January 23, 2017; Liquidity Plan, Januaiy 28, 2017; Puc1to Rico fiscal update, January 28, 2017; Debt 

service payments, Fcbrnary 1, 2017; Letter from the Junta to Elias Sanchez, Pcbmary 7, 2017. With the exception 

of the docLtment related to debt service payments, all of these docLtments can be foLtnd on th~ website of the Junta. 

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Minet' s email of March 1, 2017. 

V. CAUSE OF ACTION 

5.1 In declarations made when he announced the appointment of the seven 

members to the Junta, then President Barack Obama stated that "[i]n order to be 

successful, the Financial Oversight and Management Board will need to establish 

an open process for working with the people and Government of Puerto Rico ... [in 

order to build] a better future for all Puerto Ricans." 

5.2 Since the Junta is not considered a federal organism, but rather is "an 

entity within the territorial government for which it is established ... " (i.e. Puerto 

Rico),48 U.S.C §2121(c)(1), and all expenses of the Junta are paid for by the 

Government of Puerto Rico, 48 U.S.C §2127(b), the Constitution and laws of the 

Commonwealth of Puerto Rico apply to its operations. 

5.3 Pursuant to Section 4 of the "Puerto Rico Oversight, Management, and 

Economic Stability Act," 48 U.S.C §2103, Puerto Rico law applies with respect to 

the operation of the Junta, as long as it is not "inconsistent with [the] Act." 

5.4 There is nothing inconsistent between the right of access to information 

and the Act establishing the Junta. 

5.5 In point of fact, providing access to the requested documents would 

further the purpose of the Financial Oversight and Management Board, as publicly 

15 

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stated by the then President of the United States, Barack Obama, set forth in irs.1 

above. 

5.6 Under the Constitution of Puerto Rico, there exists an undisputed right 

of the people to access information produced or in the power of the Government of 

Puerto Rico. 

5.7 This right derives from the Constitution of Puerto Rico and is considered 

a fundamental human right. See, for example, Trans Ad PR v. Junta Subastas, 174 

DPR 56, 67 (2008); Col6n Cabrera v. Caribbean Petroleum, 170 DPR 582, 590 (2007); 

Ortiz v. Dir. Adm. Tribunales, 152 DPR 161, 175 (2000). 

5.8 The Supreme Court of Puerto Rico has observed that this right is a 

critical component of the rights of free speech, free press and freedom of 

association set forth explicitly in the Bill of Rights, Article II of the Constitution of 

the Commonwealth of Puerto Rico. See, eg., Soto v. Srio. Justicia, 12 P.R. Offic. 

Trans. 597, 607-608 (1.982). 

5.9 As expressed by the Puerto Rico Supreme Court, access to information 

constitutes an important component of a democratic society, in which the citizen 

can issue an informed judgment regarding the actions of the government. Colon 

Cabrera, 170 DPR at 590. The right to redress grievances is also implicated, in that 

without knowledge of the facts, one cannot judge, nor demand remedies with 

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respect to grievances against the government either through judicial or electoral 

processes. 

5.10 Given the importance of this right under the Constitution of Puerto 

Rico, the Government cannot deny access to documents capriciously. 

5.11 The Junta, as an organism "withln" the government of Puerto Rico, 

has a ministerial duty to comply with the Constitution of Puerto Rico with respect 

to the public nature of the information and documents sought herein. 

5.12 The critical role of the press in guaranteeing access to information has 

also been recognized in the Constitutional law of Puerto Rico. "[T]he press 

constitutes a vehicle of information and opinion to inform and educate the public, 

to offer criticism, to provide a forum for discussion and debate, and to act as a 

surrogate to obtain for readers news and information that individual citizens could 

not or would not gather on their own." Santiago v. Bobby EI Mundo, 17 P.R. Offic. 

Trans. 182, 190 (1986) (citing B. F. Chamberlain & J. Brown, The First Amendment 

Reconsidered 110, New York, Longman (1982)). 

5.13 The right of access to information is also codified in Article 409 of the 

C6digo de Enjuiciarniento Civil, 32 LPRA § 1781 (2015), which provides for access 

to "public documents" in Puerto Rico. 

5.14 To date, the Junta has held seven (7) public meetings on the following 

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dates: October 14, 2016 (New York); November 18, 2016 (Fajardo, Puerto Rico); 

January 28, 2017 (Fajardo, Puerto Rico); March 13, 2017 (New York); March 31, 

2017 (San Juan, Puerto Rico); and April 28, 2017 (New York). 

5.15 Other than the brief public sessions, largely to reaffirm decisions 

already made, and the placement of some selected documents on its website, the 

}wlta has not provided the citizenry of Puerto Rico with substantive access to the 

proceedings of the Junta, which take place behind closed doors. 

5.16 The Centro de Periodismo Investigativo has attempted to obtain 

documents which are critical for providing the citizens of Puerto Rico with the 

access to information guaranteed under the Constitution and Laws of Puerto Rico 

and to allow the CPI, as an important and respected news organization, to provide 

information to the citizens regarding the operations of the Junta. 

5.17 These efforts by the CPI have been met with stonewalling on the part of 

the Junta and its designated marketing and branding group. Forculus PR. 

5.18 Access to the information requested by the CPI is essential to assure an 

informed citi.zeruy and the validation of the rights existing under the Constitution 

and laws of Puerto Rico. 

5.19 The aforementioned rights apply to the Junta, as they are not 

inconsistent with Law 114-187. 

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5.20 Since Congress designated the Junta not only to be paid for by the 

people of Puerto mco, but also to be an entity "within" the government of Puerto 

Rico, the Constitution and laws of the Commonwealth of Puerto Rico apply to the 

Junta. 

5.21 There is no adequate remedy at law to address the fundamental 

constitutional harms for which redress is sought herein. 

5.22 The citizens of Puerto Rico and the population served by the 

investigative and reporting work done by the CPI will be irreparably harmed if the 

relief requested herein is not granted. 

5.23 The public interest wilt be served by the granting of the relief 

requested herein, be it in the form of injunctive relief or through the issuance of a 

writ of Mandamus. 

5.24 Mandamus is an appropriate writ to assure that Junta exercises its 

ministerial duty to assure compliance with the Constitution and laws of Puerto 

Rico. 

WHEREFORE, the plaintiff Centro de Periodismo Investigativo hereby 

requests the following relief: 

1. A Declaratory Judgment that the actions of the Junta in effectively 

denying access to the documents and information set forth in 1[1f4.4 to 4.26 above. 

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2. Issue a preliminary injunction and a permanent injunction ordering the 

Junta to deliver to the Centro de Periodismo Investigativo the following 

documents: 

a. Weekly cash flow reports, including all revenues received and all 

expenses paid (including any debt service) and broken down by main categories; 

b. Monthly downloads of bank account data and statements of all principal 

banking accounts (provided directly to the Board of each bank); 

c. Monthly and year to date report of compliance with the current approved 

budget by budgetary fund and by agency (including local special funds and 

federal funds); 

d. Monthly and year to date detailed report on revenues and a narrative 

about collection efforts and main initiatives of the Puerto Rico Treasury 

Department; 

e. Monthly detailed payroll reports by agency; 

f. Monthly reports on federal funds received and disbursed by area and by 

agency; 

g. Monthly reports of all debt obligations due this current fiscal year and 

which have been paid; and 

h. Quarterly report on each agency's productivity and performance with 

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appropriate metrics and a narrative description. 

i. Quarterly report on key Puerto Rico economic, financial, social and labor 

statistics. 

j. All financial statements and other financial and conflict of interest 

submissions made by the members of the Junta prior to thefr designations or 

subsequent thereto. 

k. Records relating to communications, inquiries or requests for 

information, documents, reports or data by any member of the Junta and/ or its 

staff to any agency of the federal goverrunent or federal government official, or by 

the federal government, its agencies or staff, to the Junta; 

I. Corrununications, reports, consultations, updates, documents or 

information provided by any member of the Board and/ or its staff to La Fortaleza, 

its officers, or any other agency or official of the Government of Puerto Rico, or by 

the Government of Puerto Rico to the Junta, its members or staff; 

m. Contracts granted by the Junta to private entities; 

n. Protocols, regulations, manuals or memorandums generated by the Junta 

to conduct its work; 

o. Minutes of meetings held by the Junta, its corrunittees or its members; 

p. Complete financial disclosure forms for all Junta members. 

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3. Issue a Writ of Mandamus requiring the Junta to comply with its 

ministerial duty to provide the information and documents set forth in the 

previous paragraph. 

4. Issue whatever other relief this court deems just and appropriate. 

In San Juan Puerto Rico, this 1s1 day of June, 2017. 

Respectfully Submitted 

Berkan/M.endez 

Calle O'Neill G-11 

San Juan, Puerto Rico 00918-2301 

Tel.: (787) 764-0814 

Fax.: (787)250-0986 

bennen@prtc.net 

By: /s/ ludith Berkan 

Judith Berkan 

US DC No. 200803 

berkani@microjuris.com 

/s/ Steven Lausell Recurt 

Steven Lausell Recurt 

USDC No. 226402 

slausell@gmail.com 

(787) 751-1912 

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