UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

IN RE: THE FINANCIAL OVERSIGHT 

AND MANAGEMENT BOARD OF 

PUERTO RICO

As Representative of:

THE COMMONWEALTH OF PUERTO 

RICO, Debtor.

PROMESA

TITLE III

Civil No. 17-3283 (LTS)

JOINT MOTION IN COMPLIANCE WITH ORDER AT DKT. NO. 230 

TO THE HONORABLE COURT:

Come now, Lourdes Perdigón Acevedo (“Mrs. Perdigón”), and the Commonwealth of Puerto 

Rico (“Commonwealth”), through their undersigned counsel, to respectfully move the Court for an

Order granting relief from the automatic stay, and, in support of their motion, state as follows:

1. On May 26th 2017, Mrs. Perdigón appeared before this Honorable Court requesting relief from 

the automatic stay under PROMESA Title III to continue her state civil case no. FAC2016-1989

against the Commonwealth contesting the forfeiture of her automobile as a result of a criminal 

intervention by law enforcement agents. The Commonwealth is due to respond to this request as 

ordered by this Court.

2. The parties inform this Honorable Court, that after conferring about the underlying facts of 

Mrs. Perdigón’s forfeiture case, it is in the best interest of both parties to jointly request the lift of the 

stay in the state civil case no. FAC2016-1989.

3. Notwithstanding the above, the appearance made here by the Commonwealth should not be 

construed as a waiver of any right or defense as provided by law in relation to the stay under section 

362(a) of Title 11 of the United States Code (the “Bankruptcy Code”) (incorporated to Title III by 

section 301(a) of PROMESA), and any protection offered therein, in any other motions for relief of 

stay. The Commonwealth further reserves its rights with respect to any claim currently pending in 

Case:17-03283-LTS Doc#:272 Filed:06/08/17 Entered:06/08/17 11:29:33 Desc: Main

Document Page 1 of 3
2

case no. FAC2016-1989 or hereinafter asserted by Mrs. Perdigón other than the claim contesting 

forfeiture, seeking return of the bond posted, and seeking return of the vehicle that is the subject 

matter of that proceeding.

WHEREFORE, it is respectfully requested that this Honorable Court take notice of the 

above, and GRANT the relief requested in the Motion for Relief From Stay (the “Motion”) [D.I. 229], 

provided that the stay under section 362(a) of the Bankruptcy Code is lifted solely with respect to Mrs. 

Perdigón’s action to contest the forfeiture in civil case no. FAC2016-1989, in which she also seeks

return of the bond posted, and seeks return of the vehicle that is the subject matter of that proceeding. 

CERTIFICATE OF SERVICE

I hereby certify that on this date I electronically filed the foregoing Motion with the Clerk of 

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

parties and counsels using the Court's electronic system.

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, on June 8, 2017.

Attorney for Mrs. Perdigón:

/S/ Emanuel Rier-Soto

EMANUEL RIER-SOTO, ESQ

U.S.D.C. 304110

HT28 Ave. El Comandante

Carolina, PR 00982

(787)307-5991

E-Mail: rier.emanuel@gmail.com.

Attorney for the Commonwealth of Puerto 

Rico:

Wanda Vázquez Garced

Secretary of Justice

Wandymar Burgos Vargas

Acting Deputy Secretary in Charge of Litigation 

/S/Javier Burgos Ruiz

JAVIER BURGOS RUIZ

USDC-PR No. 301511

Director of Forfeiture & Criminal Bonds 

Division

Department of Justice

P.O. Box 9020192

San Juan, PR 00902-0192

Office (787) 721-2900 x2202

Email: jburgos@justicia.pr.gov

Case:17-03283-LTS Doc#:272 Filed:06/08/17 Entered:06/08/17 11:29:33 Desc: Main

Document Page 2 of 3
3

Case:17-03283-LTS Doc#:272 Filed:06/08/17 Entered:06/08/17 11:29:33 Desc: Main

Document Page 3 of 3