IN THE 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.

1

Debtor

CASE NO.: 17-03283 (LTS)

TITLE III; PUERTO RICO 

OVERSIGHT, MANGEMENT AND 

ECONOMIC STABILITY ACT 

(PROMESA)

MOTION TO WITHDRAW AS COUNSEL OF RECORD AND REQUEST TO CEASE 

SERVICE OF NOTICE, ORDERS, PLEADINGS AND DOCUMENTS

TO THE HONORABLE COURT:

COMES NOW, the undersigned attorney and very respectfully STATES and PRAYS:

1. The undersigned attorney will no longer continue to be a member of the law firm of C. 

Conde & Assoc. since she will be permanently relocating, within the next months, to 

France. Therefore, she respectfully requests that the Honorable Court authorize her 

withdrawal as counsel for Cantor Katz Collateral Monitor, LLC in this case. 

2. The undersigned respectfully files this Motion to Withdraw and requests that pursuant to 

Local Bankruptcy Rule 9010-1(d)(3), that her name, address and email address be removed 

from the general matrix and all special or limited mailing and service lists in this case, as 

well as the Honorable Court’s electronic notice system.

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); (ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 

17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees Retirement System of the Government 

of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal 

Tax ID: 9686); (iv) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-

LTS) (Last Four Digits of Federal Tax ID: 3808); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy 

Case No. 17 BK 4780 (LTS)) (Last Four Digits of Federal Tax ID: 3747) and (vi) Puerto Rico Building Authority (“PBA”) 

Bankruptcy Case No.: 19-BK-5523 (LTS) (Last Four Digits of Federal Tax ID: 3801).

Case:17-03283-LTS Doc#:24898 Filed:08/16/23 Entered:08/16/23 15:49:28 Desc: Main

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3. This withdrawal will not cause any disruption in the case because attorneys Carmen D. 

Conde Torres and William Alemañy Méndez from the law firm of C. Conde & Assoc. and 

Douglas S. Mintz, Peter J. Amend and Kelly V. Knight of Schulte Roth & Zabel LLP from 

the firm of Davis Polk & Wardwell, LLP remain as counsel of record.

WHEREFORE the undersigned very respectfully requests that this Honorable Court allow 

her to withdraw as counsel of record in this case as requested above.

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 16th day of August 2023.

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 

parties appearing in said system including the Debtors and the US Trustee. 

C. CONDE & ASSOC.

San Jose Street #254, 5th Floor

San Juan, PR 00901-1253

Tel: (787) 729-2900

Fax: (787) 729-2203

E-mail: condecarmen@condelaw.com

S/Luisa S. Valle Castro

Luisa S. Valle Castro, Esq.

USDC No.: 215611

Case:17-03283-LTS Doc#:24898 Filed:08/16/23 Entered:08/16/23 15:49:28 Desc: Main

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