IN THE UNITED STATES BANKRUPTCY COURT

FOR THE 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)

MOTION TO WITHDRAW AS LEGAL COUNSEL 

AND REQUEST TO CEASE NOTIFICATIONS TO THE UNDERSIGNED

To the Honorable Court:

Creditor, Cooperativa de Ahorro y Crédito Lomas Verdes (“CLV”), by counsel, 

respectfully states and prays:

1. On August 28, 2018, CLV filed a Motion to Withdraw Duplicate Proof of Claim 

#112806. (ECF Docket #3817)

2. On August 29, 2018, this Honorable Court entered an order granting the withdrawal 

of Proof of Claim #112806 and instructing the clerk of court and the claims agent to reflect the 

withdrawal of said proof of claim in their respective registries. (ECF Docket #3823)

3. With the voluntary withdrawal of duplicate Proof of Claim #112806, the 

undersigned has fulfilled her legal representation of CLV in this case, and CLV will continue to 

be informed of the matters related to this case by prior retained legal representation.

4. CLV’s address, phone, and e-mail information is as follows: 

Address: P.O. Box 1142, Bayamón, PR 00960

E-mail: vrodriguez@lomasverdes.coop

Tel: 787-787-6200

Fax: 787-780-3618

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5. The undersigned certifies that she has advised CLV of any deadlines or matters 

pending related to the legal representation of the undersigned in this case. The undersigned 

further certifies that she does not owe any amounts whatsoever to CLV related to fees collected 

in advance, as no fees have been charged or collected in advance by the undersigned. 

6. The undersigned has delivered to CLV true and correct copies of the documents 

in the case file, in PDF format. 

NOW WHEREFORE, the undersigned attorney respectfully requests that this Honorable 

Court take notice of the above stated for all pertinent purposes and: (i) authorize her withdrawal as 

legal counsel for CLV in this case; (ii) order the cease of notifications in the instant case to the 

undersigned counsel; and (iii) order that all future documents and notices in this case be sent to CLV 

by prior retained counsel, pursuant to ECF Docket #171.

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

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

CM/ECF participants, including Debtors’ counsel, the Acting United States Trustee for Region 

21, and to Vanessa Medina Romero, Esq.:vmedina@mhlex.com.

I FURTHER CERTIFY that, on this same date, I served the foregoing upon any nonCM/ECF participant Standard Parties as identified and defined at ¶ II of the CMP Order, as 

amended on April 4, 2018, (Docket No. 2839 of Case No. 17-03283) "Order Further Amending 

Case Management Procedures".

I FURTHER CERTIFY that a true and correct copy of this motion is being sent by email 

to CLV, on the same date of its filing, as follows: vrodriguez@lomasverdes.coop

RESPECTFULLY SUBMITTED, in Guaynabo, Puerto Rico, this 10th day of 

September, 2018.

DELGADO-MIRANDA LAW OFFICES

Offices: Calico Court, #173 Carr. #2, Suite 201, 

Guaynabo, PR 00966

Mail: PMB 112, 130 Winston Churchill Ave., Ste. 1

San Juan, PR 00926

T: (787)717-7178

S/BRISEIDA Y. DELGADO-MIRANDA

U.S.D.C.P.R. #223214

E-mail: delgadomirandalaw@gmail.com

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