UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

MOTION SUBMITTING CERTIFIED TRANSLATIONS

TO THE HONORABLE COURT: 

The Government Development Bank for Puerto Rico (the “GDB”) and the Puerto Rico 

Fiscal Agency and Financial Advisory Authority (“AAFAF”), through the undersigned attorneys, 

respectfully state as follows: 

1. On August 29, 2018, AAFAF and the GDB filed their Objection of the Government 

Development Bank for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory 

Authority to the Urgent Motion of Official Committee of Unsecured Creditors, Pursuant to 

Bankruptcy Code Sections 105(a) and 362, for Entry of Order Enforcing Automatic Stay and 

Court’s June 29, 2017 Order Confirming Application of Automatic Stay with Respect to GDB 

Restructuring (the “Objection”) [ECF No. 3826]. 

2. In support of the arguments included in the Objection, AAFAF and GDB cited

various cases from the Puerto Rico Supreme Court including: Rodríguez Román v. Banco 

Gubernamental de Fomento para Puerto Rico, 151 D.P.R. 383 (2000), Commoloco of Caguas, 

 

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 (Bankruptcy Case No. 17 BK 3283-LTS) (Last Four Digits 

of Federal Tax ID: 3481); and (ii) The Employees Retirement System of the Government of the Commonwealth of 

Puerto Rico (“ERS”) (Bankruptcy Case No. 17 BK 3566) (Last Four Digits of Federal Tax ID: 9686).

Case:17-03283-LTS Doc#:3858 Filed:09/05/18 Entered:09/05/18 09:57:20 Desc: Main

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Inc. v. Benítez Díaz, 126 D.P.R. 478 (1990) and Amieiro Gozález v. Pinnacle Real Estata Home 

Team, 173 D.P.R. 363 (2008) (jointly, the “Spanish Case Law”). 

3. Based on the above, on the same date, AAFAF and GDB sought leave from this 

Court to submit the Spanish Case Law and requested an extension of seven (7) days to file certified 

English translations of the Spanish Case Law pursuant to Local District Court Rule 5(g) (the 

“Motion for Leave”). [ECF No. 3829]. 

4. On August 30, 2018, this Court granted the Motion for Leave [ECF No. 3835].

5. In compliance with this Court’s order, AAFAF and GDB submit the certified 

translations of the Spanish Case Law attached to this motion as Exhibit A, Exhibit B and Exhibit 

C. 

WHEREFORE, AAFAF and GDB respectfully request this Honorable Court take notice of 

the foregoing. 

Dated: September 5, 2018

San Juan, Puerto Rico

Respectfully submitted,

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC No. 222301 

Carolina Velaz-Rivero

USDC No. 300913

MARINI PIETRANTONI MUÑIZ LLC

MCS Plaza, Suite 500

255 Ponce de León Ave.

San Juan, Puerto Rico 00917

Tel: (787) 705-2171

Fax: (787) 936-7494

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