Hidalgo-Velez et al v. San Juan Asset Management, Inc. et al

Filing 80

ORDER granting 40 Motion to Dismiss; granting 43 Motion to Dismiss; granting 45 Motion to Dismiss; granting 47 Motion to Dismiss; denying 77 Motion for Certificate of Appealability; denying 77 Motion to Stay. Signed by Steve McAuliffe on 3/15/13. (gsr)

UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF PUERTO RICO
Eduardo Hidalgo-Vélez, et al.,
Plaintiffs
v.

Case No. 11-cv-02175-SJM

San Juan Asset Management,
Inc., et al.,
Defendants
O R D E R
The plaintiffs brought suit against the defendants in the
Commonwealth of Puerto Rico’s Court of First Instance on behalf
of themselves and a class consisting of those who had invested in
the Puerto Rico & Global Income Target Maturity Fund Inc. (the
“Fund”).

Plaintiffs asserted various claims under Puerto Rico

law based on fraudulent disclosures in, and omissions from, a
prospectus on which they relied in purchasing shares of the Fund.
On December 7, 2011, Defendant PricewaterhouseCoopers LLP (“PwC”)
removed the case to the United States District Court for the
District of Puerto Rico pursuant to the Securities Litigation
Uniform Standards Act, 15 U.S.C. §§ 78bb, et seq. (“SLUSA”).
Plaintiffs filed a motion to remand the case to the Court of
First Instance, but that motion was denied.

Defendants then

moved to dismiss the action on numerous grounds, including the
application of SLUSA.

Plaintiffs did not oppose the motions to

dismiss, but instead moved to certify the order denying their

motion to remand for interlocutory appeal and sought a stay
pending appeal.

PwC objects to that motion.1

Background
The Fund is registered as a non-diversified investment
company under the Puerto Rico Investment Company Act, 10 Puerto
Rico Laws Annotated §§ 661, et seq.

Plaintiffs allege that they

invested in the Fund based on the representations contained in
the prospectus.
The prospectus provided that the Fund would invest in
various categories of securities, such as preferred stock and
debt securities of corporations, partnerships, trusts, or other
similar issuers; securities issued by investment companies
registered under the Investment Companies Act of 1940, 15 U.S.C.
§§ 80a-1, et seq.; and notes issued by financial institutions
with equally weighted exposure to both European and American
investment-grade bond indices that are tied to certain publicly
traded securities.

The prospectus also provided that the Fund

would invest at least seventy-five percent of its assets in
certain fixed or variable income securities from issuers outside
of Puerto Rico (the “75% standard”).

1

The prospectus prohibited

The case was reassigned to the undersigned judge on
October 1, 2012.
2

the Fund from investing more than twenty-five percent of its
assets in securities of a single issuer (the “25% standard”).
Plaintiffs allege that the defendants violated the
investment principles contained in the prospectus and “induced
the Plaintiffs . . . to invest in the Fund” through “false and
erroneous statements and substantial omissions.”

Compl. ¶ 77.

Specifically, plaintiffs allege that the Fund failed to invest in
certain highly specialized notes issued by Banco-Bilbao Vizcaya
Argentaria, S.A., which was “[t]he reason for the existence of
the Fund.”

Compl. ¶ 71.

They also allege that the Fund made

investments in certain Lehman Brothers notes (the “Lehman Notes”)
that represented a significant concentration in a single issuer
outside of Puerto Rico, in violation of both the 75% standard and
the 25% standard.

The Fund experienced a significant loss in

market value beginning in 2008, in part due to the decrease in
value of the Lehman Notes.
On October 28, 2011, plaintiffs filed a class action and
derivative suit based on those allegations in the Commonwealth of
Puerto Rico Court of First Instance, Superior Part of San Juan,
against numerous defendants, including: the Fund itself; Amaury
Luis Rivera, Pedro Rivera Casiano, and Eyck Lugo-Rivera,
individual directors of the Fund (the “individual directors”);2

2

Plaintiffs also sued Félix González, another director of
the Fund. As discussed below, González did not enter an
appearance in this action.
3

San Juan Asset Management, Inc. (“SJAM”), the Fund’s investment
adviser; José Vizcarrondo Ramérez de Arellano,3 the Secretary of
the Fund and President of the Investment Adviser; BBVA Securities
Puerto Rico, Inc. (“BBVA Securities”), the Fund’s sales agent;
Rafael Colón-Ascar, President of both the Fund and BBVA
Securities; PwC, the Fund’s outside auditor; and various John
Does and unnamed companies.

PwC removed the case to federal

court on December 7, 2011, pursuant to the removal provisions of
SLUSA.4

As noted earlier, a motion to remand was denied by

order, dated September 24, 2012 (Cerezo, J.) (the “September 24
order”).

Discussion
The defendants move to dismiss all claims.

Plaintiffs have

not opposed the motions to dismiss, but instead move for
interlocutory appeal of the September 24 order under the
provisions of 28 U.S.C. § 1292(b).5

PwC objects.

3

In their complaint, plaintiffs alternatively refer to
this defendant as “Vizcarrondo Ramérez de Arellano” and
“Vizcarrondo Ramirez de Arellano.” In his motion to dismiss, the
defendant refers to himself as “José A. Vizcarrondo.” The court
will refer to the defendant as “Vizcarrondo.”
4

BBVA Securities joined PwC’s notice of removal.

5

Although plaintiffs move to certify the order for
interlocutory appeal, the background section of the motion
suggests that they also move for reconsideration. See Mot. for
Cert. (document no. 77) at 3 (“With the utmost respect we submit
that this Court must humbly accept that it does not have
4

I.

Interlocutory Appeal
“Interlocutory appeals under § 1292(b) require an order (1)

‘involv[ing] a controlling question of law,’ (2) ‘as to which
there is substantial ground for difference of opinion,’ and (3)
for which ‘an immediate appeal from the order may materially
advance the ultimate termination of the litigation.’”

Caraballo-

Seda v. Municipality of Hormingueros, 395 F.3d 7, 9 (1st Cir.
2005) (quoting § 1292(b)).

The court of appeals has “repeatedly

emphasized that ‘interlocutory certification under 28 U.S.C.
§ 1292(b) should be used sparingly and only in exceptional
circumstances, and where the proposed intermediate appeal
presents one or more difficult and pivotal questions of law not
settled by controlling authority.’”

Id. (quoting Palandjian v.

Pahlavi, 782 F.2d 313, 314 (1st Cir. 1986)).

Thus, “the

instances where section 1292(b) may appropriately be utilized
will, realistically, be few and far between.”

In re San Juan

Dupont Plaza Hotel Fire Litig., 859 F.2d 1007, 1010 n.1 (1st Cir.
1988); see also Camacho v. P.R. Ports Auth., 369 F.3d 570, 573
(1st Cir. 2004) (“appeals under [§ 1292(b)] are, accordingly,

jurisdiction to entertain further this case and must . . . remand
this action to . . . where it was originally brought and where it
properly belongs.”). Assuming that the plaintiffs alternatively
move for reconsideration, they have not shown “an ‘intervening
change’ in the controlling law, a clear legal error, or newlydiscovered evidence.” Soto-Padró v. Pub. Bldgs. Auth., 675 F.3d
1, 9 (1st Cir. 2012); see also Latin Am. Music Co. v. ASCAP, 642
F.3d 87, 91 (1st Cir. 2011).
5

hen’s-teeth rare”).

“The party seeking such appellate review has

the burden of convincing . . . the district court . . . that the
motion satisfies the three factors under section 1292(b).”

Colón

v. Blades, 2009 WL 3347627, at *5 (D.P.R. Oct. 14, 2009)
(internal quotation marks and citations omitted).
In her September 24 order, Judge Cerezo held that SLUSA
applied to the case and, therefore, removal to federal court was
proper.

As the court noted, “[r]emoval is proper under SLUSA

when the suit: (1) is a covered class action, (2) based on state
statutory or common law that (3) alleges that defendants made a
misrepresentation or omission of a material fact or used or
employed any manipulative device or contrivance in connection
with the purchase or sale of a covered security.”

September 24

order at 2 (internal quotation marks and citation omitted); see
also Merrill Lynch, Pierce, Fenner & Smith Inc. v. Dabit, 547
U.S. 71, 82-83 (2006).

The court held that all three prongs were

met.
In support of their motion for an interlocutory appeal,
plaintiffs argue that the court erred in finding that the third
prong necessary for removal was present, because that prong
requires that the Fund’s common stock be a covered security,
which it is not.6

PwC agrees that the Fund’s stock does not

6

Under SLUSA, a covered security is any security “(A)
listed, or authorized for listing, on the New York Stock
Exchange[,] . . . the American Stock Exchange, or . . . the
6

qualify as a covered security, but argues that the court
correctly held that “SLUSA applies to cases brought by investors
of a fund that invests, or represents that it will invest, in a
covered security, even when the shares of the fund in which the
class invested are not covered securities.”
at 4.

September 24 order

Pwc argues, as the court held, that because the Fund’s

prospectus listed various covered securities as anticipated
investments, and because the Fund actually held covered
securities, the third prong for SLUSA removal was met.

A.

Controlling Question of Law

A controlling question of law under § 1292(b) “is one that
would require reversal if decided incorrectly or that could
materially affect the course of litigation with resulting savings
of the court’s or the parties’ resources.”

Feinman v. FBI, 2010

WL 962188, at *1 (D.D.C. Mar. 15, 2010); see also Skinner v.
Salem School Dist., 718 F. Supp. 2d 186, 194 (D.N.H. 2010).

PwC

National Market System of the NASDAQ Stock Market (or any
successor to such entities; (B) listed, or authorized for
listing, on a national securities exchange (or tier or segment
thereof) that has listing standards that the Commission
determines by rule (on its own initiative or on the basis of a
petition) are substantially similar to the listing standards
applicable to securities described in subparagraph (A); or (C) a
security of the same issuer that is equal in seniority or that is
a senior security to a security described in subparagraph (A) or
(B).” 15 U.S.C. § 77r(b)(1). A covered security also includes
any security issued by an investment company that is registered
under the Investment Company Act of 1940. Id. at (b)(2).
7

does not dispute that the court’s order involved a controlling
question of law.

Had the court interpreted SLUSA to require that

the common stock of the Fund itself be a covered security, then
the case would have been remanded to the Commonwealth court and
the federal court litigation would have been terminated.

See

United States v. Lahey Clinic Hosp., Inc., 399 F.3d 1, 7 (1st
Cir. 2005) (questions concerning whether a court has subject
matter jurisdiction are controlling questions of law for
§ 1292(b) purposes).

In addition, as discussed below, if removal

was proper and SLUSA applies, as the court has held, then the
case will be dismissed, making that determination a “controlling
question of law.”

Therefore, the first prong necessary for

interlocutory appeal is met.7

B.

Substantial Ground for Difference of Opinion

“Courts traditionally will find that a substantial ground
for difference of opinion exists where ‘the circuits are in
dispute on the question and the court of appeals of the circuit
has not spoken on the point, if complicated questions arise under
foreign law, or if novel and difficult questions of first

7

Although the parties formulate the question of law at
issue in the September 24 order differently, the controlling
question is whether the “covered security” prong of SLUSA is met
where a defendant allegedly makes material misrepresentations or
omissions in connection with a fund’s investments in covered
securities, even when the fund’s stock itself is not a covered
security.
8

impression are presented.’”

Couch v. Telescope Inc., 611 F.3d

629, 633 (9th Cir. 2010) (quoting 3 Federal Procedure, Lawyers
Edition § 3:212 (2010)).

When numerous other courts “have

arrived at a similar holding regarding” the question of law,
however, “no substantial ground for difference of opinion
exists.”

Caraballo-Seda, 395 F.3d at 9 (internal quotation marks

and citation omitted).

“[T]he touchstone of the ‘substantial

ground’ prong is the likelihood of success on appeal.”

United

States ex rel. LaValley v. First Nat’l Bank of Bos., 1990 WL
112285, at *5 (D. Mass. July 30, 1990).

Thus, for there to be a

substantial ground for difference of opinion, “there must be
‘substantial doubt’ that the district court’s order was correct.”
N.F.L. Ins. Ltd. v. B&B Holdings, Inc., 1993 WL 255101, at *2
(S.D.N.Y. July 1, 1993) (quoting S. Rep. No. 85-2434, at 3
(1958), reprinted in 1958 U.S.C.C.A.N. 5255, 5257).
SLUSA provides that no covered class action based on state
law may be maintained in a federal court by a private party
alleging “a misrepresentation or omission of a material fact in
connection with the purchase or sale of a covered security.”
§ 78bb(f)(1) (emphasis added).

The Supreme Court noted that

Congress intended the phrase “in connection with” to mean the
same thing in SLUSA as it does in § 10(b) of the Securities
Exchange Act of 1934.

Dabit, 547 U.S. at 85.

Therefore, the

Supreme Court held that the phrase should be interpreted broadly

9

and “it is enough that the fraud alleged ‘coincide’ with a
securities transaction.”

Id.

Plaintiffs argue that a substantial ground for a difference
of opinion exists as to whether the “in connection with” standard
requires that shares purchased by the plaintiffs be covered
securities.

In support, they cite a single case: Pension Comm.

of the Univ. of Montreal Pension Plan v. Banc of Am. Sec., 750 F.
Supp. 2d 450 (S.D.N.Y. 2010).

There, the court held that SLUSA

did not apply where the plaintiffs purchased shares, which were
not covered securities, in hedge funds that maintained portfolios
that included covered securities.

Id. at 455.

The court

reasoned that “[t]o hold otherwise would extend the reach of
SLUSA to any investment vehicle with covered securities in its
portfolio.”

Id.

Plaintiffs analogize the Fund to a hedge fund

and argue that under Montreal Pension, SLUSA would not apply to
this case.
In Montreal Pension, the court held that the plaintiffs’
claims were not preempted by SLUSA because the alleged
misrepresentations were made in connection with the valuation of
certain hedge funds, rather than in connection with the sale or
purchase of covered securities within the hedge fund portfolios.
750 F. Supp. 2d at 454-55.

The court noted that SLUSA does not

apply to alleged frauds which relate to hedge funds just because
the funds’ portfolios happen to hold covered securities.

10

See id.

at 455.

The court appeared to acknowledge, however, that SLUSA

could apply to funds which held covered securities when the
covered securities were “at the heart” of the case.

Id.

After

Montreal Pension was decided, the Second Circuit held that
plaintiffs need not necessarily purchase or sell covered
securities for SLUSA to apply, so long as the purchase or sale of
covered securities is an integral part of “the misconduct
complained of[] and the harm incurred.”

Romano v. Kazacos, 609

F.3d 512, 524 (2d Cir. 2010); see also Backus v. Conn. Comm.
Bank, N.A., 789 F. Supp. 2d 292, 307 (D. Conn. 2011) (“By
misleading Plaintiffs into believing that it would safeguard
their assets, WNB induced Plaintiffs to invest their assets with
BLMIS, which purported to buy and sell covered securities with
those assets but was in fact stealing them.

BLMIS’ buying and

selling of covered securities is one of a string of events that
were all intertwined.”) (internal quotation marks and citation
omitted); In re Kingate Mgmt. Ltd. Litig., 2011 WL 1362106, at
*8-*9 (S.D.N.Y. Mar. 30, 2011).
In this case, the court noted in its September 24 order that
the “[p]laintiffs do not deny having alleged in their complaint
that defendants misrepresented and omitted material information
about the Fund’s investment objectives, level of diversification
and anticipated investments.”

September 24 order at 3.

The

court further noted that these misrepresentations related to

11

“various covered securities.”

Id. at 4.

Plaintiffs do not

contest the court’s holding in that regard, nor do they argue
that the defendants’ alleged misrepresentations did not
sufficiently “coincide” with covered securities.

Nor do the

plaintiffs deny that the Fund actually purchased and held various
covered securities, the decline in value of which contributed to
their claim for damages.

Their only argument is that SLUSA does

not apply because the Fund’s common stock is not itself a covered
security.

As discussed, Montreal Pension does not support that

principle.
Even if Montreal Pension lent some support to the
plaintiffs’ view, one potentially conflicting opinion does not
create a “substantial ground for a difference of opinion” for
purposes of § 1292(b).

See Head v. Farm Bureau Gen. Ins. Co. of

Mich., 2005 WL 2173568, at *5 n.1 (E.D. Mich. Sept. 6, 2005)
(“the Court does not believe that one case . . . satisfies the
requirement that there be ‘substantial grounds’ for a difference
of opinion”); Oyster v. Johns-Manville Corp., 568 F. Supp. 83, 88
(D.C. Pa. 1983) (“[a] single case demonstrates that while there
may be grounds for differences of opinion, they are not, however,
substantial”); see also Pac. Emp’rs Ins. Co. v. Global
Reinsurance Corp. of Am., 2010 WL 2376131, at *9 (E.D. Pa. June
9, 2010); SPL Shipping Ltd. v. Gujarat Cheminex Ltd., 2007 WL
1119753, at *2 (S.D.N.Y. Apr. 12, 2007); Yeager’s Fuel, Inc. v.

12

Penn. Power & Light Co., 162 F.R.D. 482, 489 (E.D. Pa. 1995).
Therefore, Montreal Pension alone, if, indeed, it were contrary
to the decision here, does not establish the substantial ground
for difference of opinion prong of § 1292(b).
In determining whether an interlocutory appeal is warranted,
the critical issue is whether there is a substantial ground for a
difference of opinion with respect to issues of law raised by the
parties; it is not whether the plaintiffs disagree with the
court’s ruling.

See Couch, 611 F.3d at 633 (“a party’s strong

disagreement with the Court’s ruling is not sufficient for there
to be a ‘substantial ground for difference’”); Am. Soc. for
Prevention of Cruelty to Animals v. Ringling Bros. and Barnum &
Bailey Circus, 246 F.R.D. 39, 43 (D.D.C. 2007).

While plaintiffs

disagree with the court’s decision, they have not pointed to any
authority suggesting that there is a substantial difference among
the courts with respect to resolution of any issue addressed in
the September 24 order.

Therefore, they have not shown that a

substantial ground for a difference of opinion exists.

C.

Materially Advance Termination of Litigation

Even if a substantial ground for a difference of opinion
existed, certification of an interlocutory appeal would not
materially advance the termination of the litigation.

“Whether

interlocutory review of this question would materially advance

13

the resolution of this case depends in large part on
considerations of judicial economy and the need to avoid
unnecessary delay and expense and piecemeal litigation.”

Coast

Fed. Bank, FSB v. United States, 49 Fed. Cl. 11, 14 (Fed. Cl.
2001) (internal quotation marks and citation omitted); see also
In re Watson, 309 B.R. 652, 660 (1st Cir. BAP 2004) (analyzing
appeal under 28 U.S.C. § 158(a)(3) under the 1292(b) standard and
noting that an “interlocutory appeal materially advances the
ultimate termination of the litigation where resolution of the
issue on appeal ‘greatly assist[s]’ in resolving the underlying
matter, and does not unnecessarily delay resolution of the
underlying matter”).

“Even when there is a right of

interlocutory appeal, a party can wait [until] the case is over
and then appeal, bringing before [the Court of Appeals] all
nonmoot interlocutory rulings adverse to him.”

Pearson v. Ramos,

237 F.3d 881, 883 (7th Cir. 2001).
Here, the applicability of SLUSA mandates the exercise of
federal jurisdiction and, as plaintiffs concede, and as discussed
below, application of SLUSA requires dismissal of the action.
Therefore, an interlocutory appeal would neither serve the
interests of judicial economy nor avoid delay, as the plaintiffs
may immediately appeal from the dismissal of the case.

In

addition, given the unlikelihood of success on appeal,
“certification of an interlocutory appeal seems more likely to

14

delay the ultimate resolution of this case than to materially
advance it.”

See Skinner, 718 F. Supp. 2d at 194.

Plaintiffs have not met their “heavy burden of convincing
the court that exceptional circumstances justify a departure from
the basic policy of postponing appellate review until after the
entry of final judgment.”

United Air Lines, Inc. v. Gregory, 716

F. Supp. 2d 79, 89 (D. Mass. 2010) (internal citations omitted).
Accordingly, plaintiffs’ motion to certify the September 24 order
for interlocutory appeal is denied.

II.

Motion to Dismiss
The defendants filed numerous motions to dismiss the

complaint prior to the September 24 order.8

The motions asserted

various grounds for dismissal, including the applicability of
SLUSA.
dismiss.

Plaintiffs did not respond to any of the motions to
Certain defendants filed motions requesting that their

motions to dismiss be deemed unopposed and granted.9

Plaintiffs

did not respond to those motions.10

8

The motions to dismiss were filed by PwC (document no.
40), Colón-Ascar (document no. 43), the independent directors
(document no. 45), SJAM and Vizcarrondo (document no. 47), and
BBVA Securities (document no. 48).
9

These motions were filed by Colón-Ascar (document no.
57), BBVA Securities(document no. 58) the independent directors
(document no. 59), and PwC (document no. 60).
10

While the motion to remand was pending, plaintiffs filed
notices of voluntary dismissal as to their claims against BBVA
15

After the court issued its September 24 order and the case
was reassigned, PwC and the independent directors renewed their
motions to dismiss, focusing primarily on the court’s holding
that SLUSA is applicable to the case.

Plaintiffs again did not

respond, but instead filed the motion for certification of an
interlocutory appeal.
“If removal is proper under SLUSA’s general removal
provision, any state-law claims must be dismissed . . . .”
Weitman v. Tutor, 588 F. Supp. 2d 133, 137 (D. Mass. 2008); see
also § 78bb(f)(1).

Indeed, “[o]nce a SLUSA-covered action is

removed and a plaintiff moves to remand, a motion to dismiss
[based on SLUSA] becomes unnecessary.”

Atkinson v. Morgan Asset

Mgmt., Inc., 658 F.3d 549, 556 (6th Cir. 2011).
As mentioned, plaintiffs did not oppose the defendants’
motions to dismiss or subsequent filings concerning those
motions.

The plaintiffs also concede in their motion for

Securities and judgment was entered dismissing the action against
BBVA Securities without prejudice. The complaint, however,
states that the suit is brought “on behalf of all those
shareholders in a similar situation and derivatively on behalf
of” the Fund. Neither the Fund nor the additional shareholders
voluntarily dismissed the action against BBVA Securities.
Because a class has not been certified, however, the plaintiffs
may voluntarily dismiss the action without providing class
members with notice of the dismissal and an opportunity to be
heard. See In re Genzyme Corp. S’holder Litig., 2011 WL 4572540,
at *1 n.2 (D. Mass. Sept. 1, 2011); Fed. R. Civ. P. 41. To the
extent the Fund, as a derivative plaintiff, did not join in the
notices of voluntary dismissal, BBVA Securities’ motion to
dismiss is granted for the reasons discussed below.
16

certification that the applicability of “SLUSA mandates the
dismissal of this action.”11

Because SLUSA does apply to this

action,12 the case is dismissed.

Conclusion
For the foregoing reasons, plaintiffs’ motion for
certification of the court’s September 24, 2012, order for
interlocutory appeal (document no. 77) is denied.

The

defendants’ motions to dismiss (document nos. 40, 43, 45, 47, and
48) are granted.

The case is dismissed as to all defendants.

All other pending motions are terminated as moot.

The clerk of

court shall enter judgment accordingly and close the case.

11

Although neither the Fund nor González (who did not file
an appearance) moved to dismiss, still, “this action will be
dismissed as to all defendants because the ground for dismissal
applies equally to all defendants.” Smalley v. Shapiro & Burson,
LLP, 2012 WL 253986, at *1 (D. Md. Jan. 26, 2012); see also
Wachtler v. Cnty. of Herkimer, 35 F.3d 77, 82 (2d Cir. 1994).
12

As the court stated in its September 24 order, “SLUSA
precludes actions; not just claims.” September 24 order at 5.
Plaintiffs do not suggest that any claim survives dismissal under
SLUSA. See Coons v. Industrial Knife Co., Inc., 620 F.3d 38, 44
(1st Cir. 2010) (“judges are not obligated to do a party's work
for him, ‘searching sua sponte for issues that may be lurking in
the penumbra of the motion papers’”) (quoting United States v.
Slade, 980 F.2d 27, 31 (1st Cir. 1992)); United States v.
Zannino, 895 F.2d 1, 17 (1st Cir. 1990).
17

SO ORDERED.

____________________________
Steven J. McAuliffe
United States District Judge
(Sitting by Designation)
March 15, 2013
cc:

Jorge M. Izquierdo-San-Miguel, Esq.
Eric Perez-Ochoa, Esq.
Mauricio O. Muniz-Luciano, Esq.
Salvador J. Antonetti-Stutts, Esq.
Vanessa Badillo-Abasolo, Esq.
Francisco G. Bruno-Rovira, Esq.
Alicia L. Chang, Esq.
Michael S. Flynn, Esq.
Leslie Y. Flores-Rodriguez, Esq.
Sara L. Velez-Santiago, Esq.
Oreste R. Ramos-Pruetzel, Esq.
Carlos A. Rodriguez-Vidal, Esq.
Anette Cortes-Arcelay, Esq.
Jaime E. Toro-Monserrate, Esq.
Linette Figueroa-Torres, Esq.

18