181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 1 

EXHIBIT 1 

TITLE III STAY MODIFICATIONS AGREED TO BY THE DEBTORS 

FROM AUGUST 18, 2018 THROUGH OCTOBER 16, 2018 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

1. Autoridad de 

Carreteras y 

Transportación de 

Puerto Rico v. Finca 

Perseverancia, Inc. et 

al., 

Puerto Rico Court of 

First Instance, Case 

No. KEF-2011-0244 

(1002) 

Eminent Domain 

Action 

Sucesión 

Pastor 

Mandry 

Mercado 

HTA The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow Movant to withdraw the 

Deposit consigned to the Prepetition 

Court in the Prepetition Action; 

provided, however, the Title III Stay 

shall continue to apply in all other 

respects to the Prepetition Action, 

including, but not limited to, the 

execution and enforcement of any 

judgment and for any claims for 

money damages and provisional 

remedies against HTA or any other 

Title III Debtor, and any requirement 

for HTA to supplement the Deposit. 

August 21, 2018 

2. Autoridad de 

Carreteras y 

Transportación de 

Puerto Rico v. Finca 

Matilde, Inc. et al., 

Puerto Rico Court of 

First Instance, Case 

No. KEF-2004-0377 

Eminent Domain 

Action 

Finca 

Matilde, Inc. 

HTA The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow (i) Movant to withdraw the 

Deposit consigned to the Prepetition 

Court, (ii) to allow HTA to make a 

one-time payment of $10,329.59 to 

Movant pursuant to the terms of the 

Prepetition Judgment (the “Principal 

Payment”) which shall be consigned 

to the Prepetition Court for 

withdrawal by Movant (iii) to allow 

HTA to pay the sum of $56.55 

corresponding interest owed with 

regards to the Principal Payment (the 

“Interest Payment”) which shall also 

be consigned to the Prepetition Court 

for withdrawal by Movant and (iv) to 

allow the Prepetition Court to enter 

an order closing the Prepetition 

Action, with prejudice, once Movant 

has received the Deposit, the 

Principal Payment and the Interest 

Payment; provided, however, the 

Title III Stay shall continue to apply 

in all other respects to the Prepetition 

Action, including, but not limited to, 

any claims for money damages and 

provisional remedies against HTA or 

any other Title III Debtor, and any 

requirement for HTA to supplement 

August 22, 2018 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 1 of 7
181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 2 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

the Deposit, the Principal Payment 

or the Interest Payment. 

3. Autoridad de 

Carreteras y 

Transportación de 

P.R. v. José Collazo 

Pérez et als. 

Puerto Rico Court of 

First Instance, Case 

No. KEF2005-0084 

Eminent Domain 

Action 

Rexach 

Hermanos, 

Inc. 

HTA The Title III Stay is hereby modified 

solely to the limited extent necessary 

to enable the Prepetition Action to 

proceed to judgment before the State 

Court; provided, however, the Title 

III Stay shall continue to apply in all 

other respects to the Prepetition 

Action, including, but not limited to, 

the execution and enforcement of 

any judgment and for any claims for 

money damages and provisional 

remedies against HTA or any other 

Title III Debtor, and any requirement 

for HTA to supplement the Deposit. 

August 28, 2018 

4. Autoridad de 

Carreteras y 

Transportación de 

Puerto Rico v. Lucas 

Pérez Valdivieso 

Torruella et als., 

Puerto Rico Court of 

First Instance, Case 

No. KEF-2006-0227 

(1003) 

Eminent Domain 

Action 

Lucase Pérez 

Valdivieso 

Torruella, and 

the Estate of 

Yesmin Galib 

Frau, 

composed by 

Yesmin 

Marie, Lucas 

P., María 

Teresa, and 

María 

Cristina 

Valdivieso 

Galib and 

Jorge Lucas 

Pérez 

Valdivieso 

Torruella 

HTA The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow Movants to withdraw the 

Deposit consigned to the Prepetition 

Court; provided, however, the Title 

III Stay shall continue to apply in all 

other respects to the Prepetition 

Action, including, but not limited to, 

the execution and enforcement of 

any judgment and for any claims for 

money damages and provisional 

remedies against HTA or any other 

Title III Debtor, and any requirement 

for HTA to supplement the Deposit. 

August 31, 2018 

(Approved by the 

Court on 

September 7, 2018, 

Case No. 17-3567-

LTS, ECF No. 

500) 

5. Autoridad de 

Carreteras y 

Transportación de 

Puerto Rico v. 

Tallaboa Industrial 

Development, Inc., 

Puerto Rico Court of 

First Instance, Case 

No. KEF-2006-0283 

(1003) 

Eminent Domain 

Action 

Tallaboa 

Industrial 

Development, 

Inc. 

HTA The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow Movant to withdraw the 

Deposit consigned to the Prepetition 

Court; provided, however, the Title 

III Stay shall continue to apply in all 

other respects to the Prepetition 

Action, including, but not limited to, 

the execution and enforcement of 

any judgment and for any claims for 

money damages and provisional 

remedies against HTA or any other 

Title III Debtor, and any requirement 

for HTA to supplement the Deposit. 

August 31, 2018 

(Approved by the 

Court on 

September 7, 2018, 

Case No. 17-3567-

LTS, ECF No. 

499) 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 2 of 7
181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 3 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

6. Beltrán-Cintrón, 

Francisco Et Als. v. 

Depto. Familia, Et 

Als., 

Puerto Rico Court of 

First Instance, Civil 

No. K AC2009-0809 

Employment Action 

(wage and hours) 

Plaintiffs1 in 

the case 

BeltránCintrón, 

Francisco Et 

Als. v. Depto. 

Familia, Et 

Als., Civil 

Number K 

AC2009-

0809 

Commonwealth The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow (a) the Certiorari Petition to 

proceed to final judgment before the 

PR Supreme Court; (b) the 

Prepetition Action to proceed to final 

judgment before the Prepetition 

Court, and (c) any appeal of such 

final judgment of the Prepetition 

Court to proceed to final judgment 

before the Puerto Rico Court of 

Appeals and the PR Supreme Court; 

provided, however, the Title III Stay 

shall continue to apply in all other 

respects to the Prepetition Action 

and Certiorari Petition including but 

not limited to, the execution and 

enforcement of any judgment and 

any claims for money damages and 

provisional remedies against the 

Commonwealth or any other Title III 

Debtor. 

September 7, 2018 

7. Acevedo- Arocho, 

Prudencio et als. v. 

Depto. de Hacienda, 

Puerto Rico Court of 

First Instance, Civil 

Number K AC2005-

5022 

Employment Action 

(wage and hours) 

Plaintiffs2

 in 

the case 

AcevedoArocho, 

Prudencia Et 

Als. v. Depto. 

Hacienda, 

Civil Number 

K AC2005-

5022 

Commonwealth The Title III Stay is hereby modified 

solely to the limited extent necessary 

to (a) allow the Prepetition Action to 

proceed to judgment, partial 

judgment or resolution before the 

Prepetition Court only with respect 

to a pending Motion for Summary 

Judgment dated March 18, 2014 (the 

“Motion for Summary Judgment”), 

(b) allow any appeal of the 

Prepetition Court’s determination 

with respect to the Motion for 

Summary Judgment to proceed to 

judgment before the Puerto Rico 

Court of Appeals, and (c) allow any 

certiorari petition with respect to the 

Motion for Summary Judgment to 

proceed to final judgment and/or 

resolution in the Puerto Rico 

Supreme Court; provided, however, 

the Title III Stay shall continue to 

apply in all other respects to the 

Prepetition Action, including, but 

not limited to, the execution and 

enforcement of any judgment and for 

any claims for money damages and 

September 7, 2018 

 

1

 The plaintiffs includes 3,793 former or active employees of the Department of Family, 696 former or active 

employees of the Vocational Rehabilitation Administration and 104 former or active employees of the Program 

of Youth Affairs. 

2

 The plaintiffs include 1,379 former or active employees of the Department of Treasury. 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 3 of 7
181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 4 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

provisional remedies against the 

Commonwealth or any other Title III 

Debtor. 

8. Giménez, Abraham-, 

Jorge L. y otros v. 

DTOP, 

Puerto Rico Court of 

First Instance, Civil 

Number K AC 2013-

1019 

Employment Action 

(wage and hours) 

Plaintiffs3 in 

the case 

Giménez, 

Abraham-, 

Jorge L. y 

otros v. 

DTOP, Civil 

Number K 

AC 2013-

1019 

Commonwealth The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow (a) the Certiorari Petition to 

proceed to final judgment before the 

PR Supreme Court; (b) the 

Prepetition Action to proceed to final 

judgment before the Prepetition 

Court, and (c) any appeal of such 

final judgment of the Prepetition 

Court to proceed to final judgment 

before the Puerto Rico Court of 

Appeals and the PR Supreme Court; 

provided, however, the Title III Stay 

shall continue to apply in all other 

respects to the Prepetition Action 

and Certiorari Petition including but 

not limited to, the execution and 

enforcement of any judgment and 

any claims for money damages and 

provisional remedies against the 

Commonwealth or any other Title III 

Debtor. 

September 7, 2018 

9. Cruz-Santos, Alejo y 

otros v. DTOP, 

(CASP) Case RET 

2002-06-1493 

Employment Action 

(wage and hours) 

Plaintiffs4 in 

the case Alejo 

Cruz-Santos, 

et als. v. 

DTOP, 

(CASP) 

CASE RET 

2002-06-1493 

Commonwealth The Title III Stay is hereby modified 

solely to the limited extent necessary 

to (a) allow the Prepetition Action to 

proceed to final judgment and/or 

resolution before the Administrative 

Forum, and (b) allow any appeal of 

the Administrative Forum’s decision 

to proceed to final judgment in the 

courts of the Commonwealth; 

provided, however, the Title III Stay 

shall continue to apply in all other 

respects to the Prepetition Action, 

including, but not limited to, the 

execution and enforcement of any 

judgment and for any claims for 

money damages and provisional 

remedies against the Commonwealth 

or any other Title III Debtor. 

September 12, 

2018 

10 Sun and Sand 

Investment Corp. v. 

Commonwealth of PR, 

Sun and Sand 

Investment 

Corp. 

Commonwealth The Title III Stay is hereby modified 

solely to the limited extent necessary 

to allow Movant and the 

Commonwealth to continue 

settlement discussions in connection 

with the Prepetition Action limited to 

September 13, 

2018 

 

3

 The plaintiffs are 1,046 former or active employees of the Department of Transportation and Public Works. 

4

 The plaintiffs include 262 former or active employees of the Department of Transportation and Public Works 

(“DTOP”). 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 4 of 7
181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 5 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

Puerto Rico Court of 

First Instance, Civil 

No. N2CI201600089 

Regulatory Taking 

the controversies pertaining to 

applicable zoning and environmental 

regulations relating to the 

development of land in Vieques, 

Puerto Rico; provided, however, the 

Title III Stay shall continue to apply 

in all other respects to the Prepetition 

Action, including, but not limited to, 

the continuation of any proceeding 

before the Prepetition Court, the 

execution and enforcement of any 

judgment and for any claims for 

money damages and provisional 

remedies against the Commonwealth 

or any other Title III Debtor. 

11 Lortu-TA, LTD. v. 

ELA, 

Puerto Rico Court of 

First Instance, Case 

No. NSCI2014-00371 

Supreme Court of 

Puerto Rico, Case No. 

CC-2017-59 

Regulatory Taking 

LORTU-TA 

LTD, INC., 

La 

Cuarterola, 

Inc., and 

Juaza, Inc. 

Commonwealth The Title III Stay is hereby 

modified solely to the limited extent 

necessary to allow (a) the Certiorari 

Petition to proceed to final 

judgment before the PR Supreme 

Court, and (b) the Prepetition 

Action to proceed to final partial 

judgment before the Prepetition 

Court, both preceding clauses (a) 

and (b) solely with respect to the 

issues of whether and when a 

regulatory taking or a taking 

occurred; provided, however, the 

Title III Stay shall continue to apply 

in all other respects to the 

Prepetition Action and the Certiorari 

Petition including but not limited to, 

the execution and enforcement of 

any judgment and any claims for 

money damages against the 

Commonwealth or any other Title 

III Debtor, without prejudice to 

Movant’s right to seek further relief 

from the Title III Stay after the PR 

Supreme Court and the Prepetition 

Court have rendered their 

determinations regarding whether 

and when a regulatory taking or a 

taking occurred. 

September 17, 

2018 

12 Puerto Rico Electric 

Power Authority v. 

Antonio Fuentes 

Gonzalez, et al., 

Puerto Rico Court of 

First Instance, Case 

No. KEF 2012-0039, 

Antonio 

FuentesGonzalez, 

Maria I. 

VigueFernandez, 

and the 

conjugal 

partnership 

PREPA The Title III Stay is hereby 

modified solely to the extent 

necessary to permit the Prepetition 

Action to proceed in the ordinary 

course until its conclusion, 

including the right of the Movants 

to withdraw the funds awarded 

thereto in the Prepetition Action. 

September 18, 

2018 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 5 of 7
181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 6 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

Eminent Domain 

Action 

comprised by 

them 

13 Ismael L. PurcellSoler, Alys CollazoBougeois v. Puerto 

Rico Electric Power 

Authority, 

Puerto Rico Court of 

First Instance, Case 

No. J DP 2012-0406, 

Eminent Domain 

Action 

Ismael L. 

Purcell-Soler, 

Alys CollazoBougeois, 

and the 

community 

property 

comprised by 

them 

PREPA The Title III Stay is hereby 

modified solely to the extent 

necessary to permit the Prepetition 

Action to proceed in the ordinary 

course until its conclusion. 

October 3, 2018 

14 Finca Matilde, Inc. v. 

Puerto Rico Highways 

and Transportation 

Authority, 

Puerto Rico Court of 

First Instance, Case 

No. JAC2015-0577 

Inverse Condemnation 

Action 

Finca 

Matilde, Inc. 

Commonwealth 

and HTA 

The Title III Stay is hereby modified 

solely to the limited extent necessary 

to enable the Prepetition Action to 

proceed to final judgment before the 

State Court; provided, however, the 

Title III Stay shall continue to apply 

in all other respects to the Prepetition 

Action, including, but not limited to, 

the execution and enforcement of 

any judgment, for any claims for 

money damages and provisional 

remedies against the Debtors or any 

other Title III Debtor and any 

requirement for the Debtors to 

consign a deposit. 

October 4, 2018 

15 Acevedo Camacho, 

Madeline et als. v. 

Depto. Familia, et als., 

CASP, Case No. 2016-

05-13403 

Appellants in 

the case 

Acevedo 

Camacho, 

Madeline et 

als. v. Depto. 

Familia, et 

als.,

5

Commonwealth The Title III Stay is hereby modified 

solely to the limited extent necessary 

to (a) allow any appeal of the 

Administrative Forum’s decision 

with respect to the resolution dated 

November 23, 2016 (the 

“Resolution”) to proceed to final 

judgment before the Puerto Rico 

Court of Appeals, and (b) allow any 

certiorari petition with respect to the 

Resolution to proceed to final 

judgment and/or resolution before 

the Puerto Rico Supreme Court; 

provided, however, the Title III Stay 

shall continue to apply in all other 

October 5, 2018 

 

5

 The appellants are 2,818 former or active employees of the Department of Family Affairs of Puerto Rico. 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 6 of 7
181109 ORD RE 6TH OMNI MOT FOR APPROVAL OF MODIFICATIONS TO STAY.DOCX VERSION NOVEMBER 9, 2018 7 

CASE 

INFORMATION 

MOVANT DEBTOR 

BRIEF DESCRIPTION OF THE 

MODIFICATION STIPULATION 

DATE 

respects to the Prepetition Action 

including but not limited to, the 

execution and enforcement of any 

judgment and any claims for money 

damages and provisional remedies 

against the Commonwealth or any 

other Title III Debtor. 

. 

Case:17-03283-LTS Doc#:4201-1 Filed:11/09/18 Entered:11/09/18 16:15:52 Desc:

Exhibit Title III Stay Modifications Agreed to by the Debtors from August 18 20 Page 7 of 7