Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO CIVIL NO.

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1 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 1 of 16 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO PUERTO RICO COFFE ROASTERS, LLC v. Plaintiff PAN AMERICAN GRAIN MFG. CO., INC. Defendant CIVIL NO. TRADEMARK INFRINGMENT; UNFAIR COMPETITION; DECLARATORY JUDGMENT; PERMANENT INJUNCTION JURY TRIAL DEMANDED COMPLAINT COMES NOW plaintiff PUERTO RICO COFFEE ROASTERS, LLC ( PRCR ), through its undersigned counsel, and respectfully alleges and prays as follows: I. NATURE OF THE ACTION, JURISDICTION AND VENUE 1. This is an action for trademark infringement and unfair competition arising under the Lanham Act of 1946, 15 U.S.C et seq. ( Lanham Act ) and the Puerto Rico Trademark Act, 10 P.R. Laws Ann. 223 et seq. This is also an action for trademark misuse and abuse of monopoly power, sham litigation or malicious prosecution, abuse of commercial speech, misuse of the regulatory process, and tort. Damages, permanent injunctive relief and a declaratory judgment are sought. 2. There is original jurisdiction over the trademark claims asserted pursuant to the Lanham Act, 15 U.S.C and There is supplemental jurisdiction over the state law claims pursuant to 28 U.S.C and 1367.

2 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 2 of Venue is proper in this District Court under 28 U.S.C. 1391(b)(1) and (2) insofar as Defendant is a Puerto Rico resident and a substantial part of the events giving rise to the claims occurred, or are continuing to occur, in Puerto Rico. II. THE PARTIES 4. Plaintiff PRCR is a limited liability company organized under the laws of the Commonwealth of Puerto Rico with principal place of business in Puerto Rico. PRCR is in the business of roasting, packaging and selling Puerto Rico coffee and related products for distribution in Puerto Rico and the United States. PRCR has also invested in the planting and growth of coffee in Puerto Rico. 5. Defendant Pan American Grain Mfg. Co., Inc. ( PAG ) is a corporation organized under the laws of the Commonwealth of Puerto Rico with principal place of business in Puerto Rico. PAG is in the business of importing, packaging and selling rice; roasting, packaging and selling coffee, and other products. PAG is also the parent company or affiliate of: Pan American Properties, Inc. ( PAP ), which imports alcohol and produces the Gasolina brand of alcoholic beverages, Trofima Corporation (Trofima), which also packages and sells rice, and Pan American Fertilizer (PAF), which imports, packages and sells fertilizer. PAG and its affiliates and subsidiaries distribute their products in Puerto Rico and the United States. 6. PAG, PAP, PAF and Trofima are owned, directed and run by their President, Jose González Freyre, a convicted federal felon. 1 III. FACTS COMMON TO ALL CLAIMS 1 See U.S. v. José González Freyre, Case 3:08-CR Case documents are attached as Exhibit 1. 2

3 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 3 of The Café Rico mark is a famous coffee trademark of that has been in continuous use since approximately Through the continuous use of the Café Rico mark in interstate commerce and in connection with coffee goods, the Café Rico mark has acquired a high degree of fame, distinctiveness, international exposure, and goodwill in the Café Rico name, mark, and related forms. 8. The Café Rico mark has been registered in the United States Patent and Trademark Office ( USPTO ) since October 19, 2010 (Cert. Reg. No ). This registration is valid, subsisting, and unrevoked; and is prima facie evidence of PRCR s exclusive right to use the Café Rico mark in commerce in connection with the goods specified in the registration, namely coffee. See Café Rico Certificate of Registration attached hereto as Exhibit The Café Rico mark has been registered in the Puerto Rico Trademark Office ( PRTO ) since December 16, 1992 (Cert. Reg. No. 32,028). This registration is valid, subsisting, and unrevoked; and is prima facie evidence of PRCR s exclusive right to use the Café Rico mark in commerce in connection with all the goods specified in the registration, namely coffee. See Café Rico Certificate of Existence attached hereto as Exhibit Café Rico 50/50 (Cert. Reg. No. 66,709), Café Rico Decaff (Cert. Reg. No. 66,708), and Café Rico Espresso (Cert. Reg. No. 66,707) are related Café Rico trademarks which have contributed to the fame and distinctiveness of the Café Rico trade name. These marks have been used in commerce since 1996 and registered in the Puerto Rico Trademark Office since These registrations are valid, subsisting, and unrevoked; and are prima facie evidence of PRCR s exclusive right to use these Café Rico marks in commerce in connection with all the goods specified in the registrations, namely different types of coffee. 3

4 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 4 of The Café Rico mark has also been filed for registration in the USPTO, Serial No , and in the PRTO, Pres. Nos and , for coffee filters. This product has been used in commerce since PRCR has further secured or requested other registrations for coffee related products under the Rico trademark. See Rico María (Cert. Reg. No. 66,820) and Rico María Gold (Cert. Reg. No. 66,821) cookies; Rico (Pres. No. 67,738) bottled water; Rico (Pres. Nos and , and Serial No ) sugar and sugar substitutes. 13. Prior to June 3, 2008, Café Rico, Inc. was the owner of the Café Rico trademark together with the goodwill of the coffee business symbolized in connection with the goods on which this mark is used. 14. On June 3, 2008, PRCR entered into an Asset Purchase Agreement with Café Rico, Inc., among others. PRCR acquired certain assets of Café Rico, Inc., including all intellectual property and trademarks owned by it. 15. As part of this transaction, on June 30, 2008, Café Rico, Inc. executed an Assignment and transferred all rights, titles and interests in the Café Rico mark to PRCR. 16. Since then, PRCR has continuously used the Café Rico mark in interstate commerce in connection with coffee and coffee-related goods, and has continued to establish a high degree of fame, distinctiveness, and goodwill in the Café Rico name, mark, and related forms. 17. Café Rico is currently sold in Puerto Rico, Florida, New York, New Jersey, and elsewhere through the Internet. 18. The fact of PRCR s ownership over the Café Rico trademark is notorious and known to PAG; particularly given prior litigation between the parties relating to such trademark and in light of current proceedings between the parties before the PRTO. 4

5 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 5 of Despite this knowledge, PAG has been packaging, marketing and pre-selling coffee under the Rico trademark for distribution in Florida. PRCR learned about this in August See Rico Coffee picture attached hereto as Exhibit PAG has been undertaking the introduction of packaged coffee using the brand Rico Coffee in Orlando, Florida, using the same name and color scheme as PRCR s Café Rico, to sell it to the Puerto Rican community in Orlando, who know and have been consuming Café Rico for more than 70 years. 21. Consumer confusion as to the source and quality of the coffee is certain. Indeed, PAG is purposely using PRCR s trademark and trade dress for Café Rico with the intent of deceiving consumers in Florida. 22. This is part of PAG s intent to illegally obtain what PAG has not been able to obtain legally. PAG has been trying to acquire the Café Rico trademark through fraudulent actions in the PRTO and the USPTO ever since it attempted to buy -and failed- the Café Rico mark in 2008 from the Giraud-Piñeiro Group. 23. Indeed, after PAG failed in its efforts to acquire Café Rico and other coffee marks from the Giraud-Piñeiro Group, and PRCR successfully bought the same, PAG then attempted to obtain the Café Rico and the other marks by filing two cases in this Court. 24. The two cases filed by PAG sought to annul and set aside PRCR s purchase of Café Rico and other coffee marks, including Yaucono and Rioja. PAG lost both of the cases, before two different judges of this Court. In other words, PAG struck out in its three attempts to acquire the Café Rico mark through legal proceedings: it lost in its bid to purchase the mark and it 5

6 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 6 of 16 lost in the two cases in which it tried to attack PRCR s purchase of Café Rico so as to attain the mark for itself PAG, as it has repeatedly done in the past in pursuing its commercial interests and in trying to control multiple industries and products in Puerto Rico, then turned to misleading statements, insults, threats, libel and slander, and, finally, trademark infringement and unfair competition, including fraud upon the PRTO and the USPTO, in its attempt to illegally obtain PRCR s Café Rico mark. 3 In particular, in such pursuit, PAG has committed fraud on the PRTO and the USPTO by requesting the registration of the Rico trademark for coffee and other products, misrepresenting it uses the mark for those products when at the time of filing the applications it only used the Rico mark for rice, beans, and tomato sauce. Indeed, PAG has attempted to parlay its use of the trademark Rico for the sale of imported rice -which it illegally controlled- in order to control the use of said mark for coffee and other products. 26. PAG filed Serial No allegedly trying to register the Rico trademark for rice, tomato sauce, and coffee with the USPTO, when it already has the trademark registered for rice and tomato sauce. PAG is trying to employ those uses and particularly the dominant use of its imported rice products, to register Rico for coffee, as if it had a right to the trademark in commerce for that product. 27. PAG did the same in the PRTO with Filing No , which includes a list of products, including coffee, in relation with which PAG affirmed, under penalty of perjury, that it used the Rico trademark. The only products in that list that, at the time of filing the application, PAG actually sold under the Rico trademark are, again, rice and tomato sauce. PAG only 2 See Pan American Grain, Inc. v. Alberto de la Cruz, et al., Civil No ; Giraud et al. v. FDIC et al., Civil No Case documents are attached as Exhibit 5. 3 See Pan American Grain v. Puerto Rico Ports Authority, 295 F.3d 108, (2002); Pan American Grain v. Puerto Rico Ports Authority, 193 F.R.D. 26, (2000); Pan American Grain Co. and Unión de Trabajadores de Muelles Local 1740, 281 N.L.R.B. No. 19, pág. *98 (1986). Case documents are attached as Exhibit 6. 6

7 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 7 of 16 provides evidence of use as to rice, a product in which it developed and exploited market control to exclude others from said market. 28. PAG has used the trademark Arroz Rico in developing its control of over 91% of said market. As a result, PAG gained recognition of the trademark Rico in the rice market through illegal means. 4 In particular, PAG willfully acquired, enhanced, and maintained control over Puerto Rico s rice market by engaging in clearly exclusionary and anticompetitive conduct that includes but is not limited to: (1) denying competitors reasonable access to essential facilities fully controlled by PAG to import, package, and process bulk rice in Puerto Rico; (2) the illegal acquisition of its sole competitor in the import, packaging, and processing of bulk rice market in Puerto Rico -Trofima Corporationwith the intent and result of controlling 100% of said market; (3) using its control of the essential facilities to import, package, and process bulk rice in Puerto Rico to impose exclusive dealing arrangements at the wholesale levels so as to control the supply and price of all rice sold at the retail level in Puerto Rico; (4) extending or attempting to extend its 100% market share of the import, packaging, and processing of rice market to the wholesale and retail rice markets; (5) willfully and illegally limiting without any business justification the amounts of bulk rice exclusively imported, packaged, and processed in PAG s import, packaging, and processing essential facilities by other competitors in the rice market; (5) incurring in price squeezes by charging rates to clients in the retail level for rice finished products that are so low compared to the price it charges for the raw materials PAG sells to competitors that those competitors are unable to compete in the rice market; (6) the use of sham litigation and/or baseless lawsuits or administrative actions against competitors such 4 See Puerto Rico Senate, Consumer and Federal Affairs Commission, Partial Report on R. del S (Rice Monopoly), October 7, 2008, attached as Exhibit 7. 7

8 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 8 of 16 as Trofima Corporation to impede their ability to compete, and (7) reaching agreements with potential competitors in the import, packaging, and processing of rice market to preclude their entrance to the same. 29. PAG aims to dominate the coffee market, as it dominates the rice, grains, animal food, fertilizers and prepared alcoholic beverages industries in Puerto Rico, through diverse companies owned and operated by José González Freyre, including PAG, PAP, and Trofima. PAG is trying to use the power it illegally achieved in the rice market to gain an unfair advantage in other markets, including the coffee market. PAG alleges Rico is its house-mark and, therefore, that it has exclusive rights to the Rico trademark as to each and every market product, even those as to which other real users have previous or senior rights. That is the case of PRCR s Café Rico. 30. The illegal actions to obtain PRCR s Rico mark also include a defamation campaign that PAG, through its president, José González Freyre, is circulating in the press, with media tours of PAG s public relations team, paid by PAG, and through social media to affect the reputation and goodwill of PRCR s coffee trademarks, including Café Rico, Yaucono, Crema, Alto Grande, and Rioja. This campaign includes false statements accusing PRCR of exploiting children in other countries and as to the quality of the PRCR coffee brands. PAG is looking to damage PRCR s coffee trademarks in order to promote its own coffee trademarks, like Café Mami, and to introduce its Rico Coffee mark in the market that PRCR has developed with its Café Rico and other coffee trademarks. 31. Although PAG has developed a public campaign alleging it is protecting locally produced coffee and is promoting that consumers only purchase coffee made with 100% Puertorican coffee, two of the three coffee brands affiliated to PAG, Del Patio produced by Trofima, a 8

9 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 9 of 16 corporation owned by González Freyre- and De Mi Tierra also produced by González Freyre-, use imported coffee. In other words, both brands are completely misleading or ipso facto misleading advertising. This is typical of PAG's unfair competition tactics in all industries in which it participates and controls or attempts to control. Indeed, at a March 30, 2015 meeting of the Asociación de Agricultores, Gonzalez Freyre boasted that he (presumably meaning his companies) were the leaders in all markets in which he participated-except coffee. 32. One example of PAG s use of unfair competition tactics were the threats, insults and unfair competition, including the violation of Law 75, that PAG s affiliate Pan American Properties ( PAP ), which is also owned by Gonzalez Freyre, used in relation with the distribution of its Gasolina alcoholic beverages, which is manufactured with imported alcohol Moreover, PAG s public campaign is completely deceitful; designed by PAG to promote its own agenda and economic interests in the areas PAG controls. The truth is that the coffee growers have and are being distressed by the high costs of fertilizers-another industry controlled by PAG, in which its subsidiary and/or affiliate PAF boasts market control of 95% of fertilizer sales in Puerto Rico. In fact, using its 95% market control, PAG doubled the price of fertilizers in 2005, thereby affecting several industries, including the coffee industry. 34. PAG s campaign against PRCR is deceitful, since it is based on the slogan Salvemos el Café 100% puertorriqueño and the demise of the Puerto Rico coffe industry has been caused 5 In a decision by the Superior Court of Bayamón, in CC1 Beer Distributors, Inc. v. Pan American Properties Corp., D PE , the Court not only concluded (as the NLRB had already concluded in another case) that González Freyre's testimony under oath before said court was not worthy of credibility but also that PAP used CC1 s distribution of Gasolina to create the market for it and then tried to take away the distribution from CC1 to distribute the product on its own, benefiting from CC1 s work and strategies; PAP engaged in the direct distribution of Gasolina and hid it from CC1, that had exclusive distribution rights. It further concluded that González Freyre had threatened one of its distributors and developed a scheme to take away its distribution rights by deceiving the distributor, and then insulting him and even firing and employee that testified against PAP. 9

10 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 10 of 16 in large part by PAG s abusive use of its control of the fertilizer market against the same coffee growers it now claims to defend. IV. CAUSES OF ACTION COUNT I FEDERAL TRADEMARK INFRINGEMENT, 15 U.S.C PRCR incorporates by reference the allegations contained in Paragraphs 1 through 30 of this Verified Complaint. 36. PRCR is the owner of the Café Rico trademark, given its use of the mark, by itself and its predecessors, since the 1930s. 37. PRCR owns registration of the Café Rico trademark in the USPTO and the PRTO. See Café Rico Certificate of Registration attached hereto as Exhibit PRCR also owns the Rico and Café Rico marks with regards to several other products related to coffee. 39. PAG is infringing PRCR s exclusive right to use the trademark Café Rico in connection with coffee by offering for sale a coffee under the mark Rico Coffee. 40. This use is likely to cause confusion because PAG is using the same name of PRCR s coffee, only changing the descriptive part of the name by translating it from Spanish to English and, accordingly with English grammar, moving it from the top to the bottom of the mark. Not only that, but PAG is also using the same color scheme as that used by Café Rico. 41. PAG s Rico Coffee will be marketed to the same type of consumers and through the same type of channels as PRCR s Café Rico and other Rico products that are related to coffee. 10

11 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 11 of Any ordinary consumer may reasonably think Café Rico is introducing a new look for its product. 43. PAG s Rico Coffee trademark is designed to deceive, misleading consumers, including Puerto Ricans living in Orlando, to believe they are buying the same PRCR s Café Rico they have known and enjoyed for the past decades, when in reality, they are buying another product, PAG s confusingly similar package of coffee. 44. The likelihood of confusion is further increased by the fact that both PRCR and PAG are not only selling the same goods, but also using the same channels of trade and publicity, and aiming to attract the same customers. 45. PAG s actions thereby demonstrate an intentional, wrongful, and bad faith attempt to trade on the goodwill associated with the Café Rico mark. 46. Furthermore, PAG s trademark misuse scheme demonstrates its intention to use the Rico trademark in relation to products which are in PRCR s natural zone of expansion and which PRCR is already producing or intends to produce under its Café Rico and Rico trademarks, such as sugar, milk, water, and cookies. 47. PRCR is entitled to permanent injunctive relief, to prevent PAG from using the Rico trademark in connection with coffee and related goods in PRCR s natural zone of expansion, and to recover PRCR s statutory and/or actual damages, profits, costs, and reasonable attorneys fees under 15 U.S.C and COUNT II FEDERAL TRADEMARK INFRINGEMENT AND UNFAIR COMPETITION, 15 U.S.C (a) 48. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 47 of this Verified Complaint. 11

12 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 12 of PRCR is the owner of the Café Rico mark. 50. PAG is using a misleading name and package which is likely to deceive as to the affiliation or origin of its coffee, in violation of 15 U.S.C. 1125(a). By using a name and image confusingly similar to PRCR s Café Rico, PAG is creating the false and misleading impression that its coffee originates with or is affiliated, connected, or associated with PRCR. 51. But PAG s illegitimate tactics don t end there, because, at the same time it takes advantage of Café Rico s goodwill to introduce its Rico Coffee in the market PRCR has created, PAG develops a campaign to actively harm PRCR s position, reputation, and ability to compete on fair terms. PAG intends to benefit from Café Rico s goodwill and, later on, when it has tarnished PRCR s reputation with its defamation campaign, promote its own Rico Coffee. PAG s plans are to intrude on Café Rico s market using Café Rico s name and image; damage PRCR s reputation, and unfairly occupy the market after benefiting from Café Rico s goodwill and then eliminating Café Rico as a competitor. 52. PRCR is entitled to a permanent injunction, to prevent PAG from using the Rico trademark in connection with coffee and to prevent its unfair competition scheme, and to recover damages, actual and/or statutory, profits, costs, and reasonable attorneys fees pursuant to 15 U.S.C and 1125(a). COUNT III TRADEMARK MISUSE 53. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 52 of this Verified Complaint. 12

13 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 13 of PAG is using its registration of the Arroz Rico trademark to unfairly attempt to control the coffee market and to devalue trademark rights over trademarks that contain the word Rico in relation to all kinds of goods. 55. PAG s violation of fair competition boundaries that legitimate trademarks impose on their owners is even more serious, because the unfairly acquired fame that the Arroz Rico mark has in the Puerto Rico rice market is the result of another unfair competition tactic by PAG, as set forth above., through different illegal and unfair tactics and unfair competition schemes. 56. PAG s abuse of its trademark registration merits the cancellation of all of its Rico trademarks. Therefore, PRCR requests this Court to order the cancellation of PAG s Rico trademarks for trademark misuse. COUNT IV PUERTO RICO TRADEMARK INFRINGMENT 57. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 48 of this Verified Complaint. 58. PRCR is the owner of the Café Rico (Cert. Reg. No. 32,028), Café Rico 50/50 (Cert. Reg. No. 66,709), Café Rico Decaff (Cert. Reg. No. 66,708), and Café Rico Espresso (Cert. Reg. No. 66,707) marks for coffee and coffee-related goods registered in the PRTO. See Exhibit 3. These registrations are valid, subsisting, and unrevoked; and are prima facie evidence of PRCR s exclusive right to use the Café Rico mark in commerce in connection with all the goods and services specified in the registrations. 59. PAG has willfully and deliberately used PRCR s registered trademarks or confusingly similar trademarks in violation of the law of Puerto Rico, 10 P.R. Laws Ann. 223w. 13

14 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 14 of PAG began and continues such use with knowledge of PRCR s prior adoption and use of the Café Rico mark, the registration for which covers coffee and coffee-related goods. 61. PRCR is entitled to permanent injunctive relief and to recover damages, actual and/or statutory, profits, costs, and reasonable attorneys fees pursuant to 10 P.R. Laws Ann. 223w. COUNT V DAMAGES UNDER THE PUERTO RICO CIVIL CODE 62. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 53 of this Verified Complaint. 63. By packaging and marketing coffee using a name and image substantially and confusingly similar to PRCR s Café Rico, PAG has caused PRCR damages under Article 1802 of the Puerto Rico Civil Code, 31 P.R. Laws Ann PAG has also caused damages to PRCR s reputation and to the goodwill of its trademarks, including Café Rico, Café Yaucono, Yauco Selecto, Café Crema, Rioja, and Alto Grande, through the false and defamatory campaign it has published and continues to publish in the traditional media and social media, in violation of 31 P.R. Laws Ann and 32 P.R. Laws Ann PRCR is entitled to recover damages, costs, and reasonable attorneys fees pursuant to 31 P.R. Laws Ann and 32 P.R. Laws Ann COUNT VI DECLARATORY JUDGMENT 66. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 57 of this Verified Complaint. 14

15 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 15 of PRCR requests that the Court declare that PRCR is the owner of the Café Rico mark and the Rico marks in connection with coffee and coffee-related goods and, therefore, while PRCR uses its trademarks in commerce, PAG and no other person or entity may use the same or confusingly similar trademarks for the sale, distribution, promotion or marketing of coffee and coffee-related products. V. PRAYER FOR RELIEF WHEREFORE, PRCR demands judgment in its favor and against Defendants and seeks the following relief from this Court: (a) a permanent injunction restraining PAG from packaging, selling, distributing, or otherwise disposing of coffee bearing the Rico mark and from taking any actions that infringe the trademark, and ordering PAG to immediately produce to PRCR an accounting of all goods produced and all profits derived from the use of the Rico mark in relation to coffee; (b) a declaratory judgment that PRCR is the owner of the Café Rico and Rico trademarks for coffee and related products in its natural zone of expansion; (c) an award of statutory damages in the maximum amount allowed pursuant to Puerto Rico and federal trademark laws for bad faith infringement and/or loss profits and damages in an amount to be determined at trial for PAG s bad faith infringement of PRCR s trademark; (d) an award of damages for PRCR s loss of goodwill and harm to reputation, in an amount to be determined at trial; (e) (f) an award of costs and attorney s fees in favor of PRCR; the cancellation of all of PAG s Rico trademarks for trademark misuse, and 15

16 Case 3:15-cv JAF Document 1 Filed 08/12/15 Page 16 of 16 (g) an Order awarding PRCR such other and further relief as the Court may deem just and proper. In San Juan, Puerto Rico, on August 12, PIETRANTONI MÉNDEZ & ALVAREZ LLC Popular Center-19 th Floor 208 Ponce de León Ave. San Juan, P.R Tel Fax /S/ NÉSTOR MÉNDEZ GÓMEZ Néstor M. Méndez-Gómez nmendez@pmalaw.com USCA No. 118,409 /S/ MARÍA D. BERTÓLEZ María D. Bertólez Elvira mbertolez@pmalaw.com USCA No. 217,112 /S/ MARIANA MUÑIZ LARA Mariana Muñiz-Lara mmuniz@pmalaw.com USCA No. 231,706 16