# Opposition Brief — Bunker Group, Inc. v. United States

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Opposition Brief
- **Published:** January 1, 1998
- **Citation:** 524 U.S. 952

## Text

No. 97-1610 F Rapmme Cort, us. |

FILED
: In The
re - a | 29 1998
Supreme Court of the Hnithd Stites
5 QFECE OF ING GLEAK
y~ ,
October Term, 1997
IN THE MATTER OF BUNKER GROUP INC.
BUNKER GROUP PUERTO RICO, INC..
NEW ENGLAND MARINE SERVICES, INC..
Petitioners,
VS.
UNITED STATES OF AMERICA, et al.
COMMONWEALTH OF PUERTO RICO, er al.,
Respondents.

On Petition for Writ of Certiorari to the
United States Court of Appeals for the First Circuit

BRIEF IN OPPOSITION FOR RESPONDENTS
COMMONWEALTH OF PUERTO RICO, et al.

ANTONIO J. RODRIGUEZ JOSE A. FUENTES AGOSTINI
Counsel of Record ATTORNEY GENERAL
ALANSON T. CHENAULT, IV COMMONWEALTH OF
RICE FOWLER PUERTO RICO
201 St. Charles Avenue P.O. Box 192
36th Floor San Juan, Puerto Rico 00902

New Orleans, Louisiana 70170 (787) 721-7700
(504) 523-2600
JOHN F. NEVARES
SMITH & NEVARES
P.O. Box 13667
Santurce Station
San Juan, Puerto Rico 00908-3667
(787) 722-9333

Attorneys for the Commonwealth of Puerto Rico, on its own behalf,
and as Public Trustee and as parens patriae for the Citizens of the
Commonwealth, the Board on Environmental Quality of the
Commonwealth of Puerto Rico, the Department of Natural Resources
of the Commonwealth of Puerto Rico and the
Puerto Rico Tourism Company

Gar ton ro ee eee wornenige Ce UTE nares em sats CORAL Aner a

i

PARTIES TO THE PROCEEDING

The petition also should have included the Commonwealth
of Puerto Rico as a party. The Commonwealth of Puerto Rico
appears on its own behalf, and as Public Trustee and as parens
patriae for the Citizens of the Commonwealth, the Board on
Environmental Quality of the Commonwealth of Puerto Rico,
the Department of Natural Resources of the Commonwealth of
Puerto Rico and the Puerto Rico Tourism Company.

il

TABLE OF CONTENTS

Page
PEE WH TG FINS on. kn sé Kev knees ceneaeeuens i
ee Ae GI bi 6a ov eke vide hewkincvenieennera ii
Une OE SI a v.a vs a boa 5 kno bee eae hain ill
> Reasons for Denying the Writ ..... 25.00 cccccccasce l
I. Certiorari should not be granted because neither
the court of appeals nor the district court has “so
far departed from the accepted and usual course
of judicial proceedings” as to warrant a grant of
NTS i sic hi ches a cae ees l
A. Bunker Group has failed to explain why a
writ of certiorari should be granted. ..... l
B. Bunker Group cannot show that the courts
below departed from the accepted and usual
course of judicial proceedings in this case of
Statutory interpretation. ............... 2
C. No other compelling reasons warrant a grant
OF CNG. ice inccd ess senate 4
II. Applying the accepted and usual course of judicial
proceedings, the courts below correctly concluded
that OPA implicitly repealed the limitation act as to s
claims for oil spill removal costs and damages. . 6

eects

ili

Contents

Page

III. The courts below correctly held that Rule F is

inapplicable to claims for oil spill removal
costs and damages. .........--++--eeeeeeee 9
ES LEIP IPP TOE TICE CEE EERE 10

TABLE OF CITATIONS
Cases Cited:

Braxton v. United States, 500 U.S. 344 (1991) ...... 4
Connor v. Coleman, 440 U.S. 612 (1979) .......... 3
Hanna v. Plumer, 380 U.S. 460 (1965) ............ 4
Hickman y. Taylor, 329 U.S. 495 (1947) .........5. 4

In re Hokkaido Fisheries Co., Ltd., 506 F. Supp. 631 (D.
Sos ii a hae a ee MOMS AS Re es 7,8

In re JAHRE SPRAY II, 1997 A.M.C. 845, 1996 WL
Co re er errr 4

In re MetLife Capital Corp., 132 F.3d 818 (lst Cir. 1997)
CEL TEAS, PEL ELT Oe Pe Tee ae Seer ee Pe eee 7, 8,9

In re Odin Marine Corp., No. 96-5438 (S.D.N.Y. Aug.
ae eS Aea AS Ree ED EL EK ORO oN 5

In re Oswego Barge Corp., 664 F.2d 327 (2d Cir. 1981)

iv

Contents
Page
Lake Tankers Corp. v. Henn, 354 U.S. 147, reh’g. denied,
Foe Sei AMID. eve ook oe eens ere iG 2
New York City Transit Auth. v. Beazer, 440 U.S. 568
BS oy; RS Ree ng Un Seer yr ol SPE eae Rn 4
Posadas v. National City Bank, 296 U.S. 497 (1936) . 7
Radzanower v. Touche Ross & Co., 426 U.S. 148 (1976)
EP ag ee re PU ME Cy yee a eT 7
Thermtron Products, Inc. v. Hermansdorfer, 423 U.S. 336
fag! Se ee marys Oe aAP Laan Sheen wr ooe eRe 3
Tug Capt. Fred Bouchard Corp. v. M/V BALSA 37, No.
93-1321-CN-T-23B (M.D. Fla. Oct. 22, 1996) ... 5
Valley Forge Christian College v. Americans United for
Separation of Church and State, Inc., 454 U.S. 464
CEGRE hive ea vce 4 ek ee os knees 4
Zahn v. International Paper Co., 414 U.S. 291 (1973) 4
Statutes Cited:
SS Net Aees REF SSE 6 kei ir beh os Re SHE eS 7
SP Tice OO AEE 5 Kika CRG eo ee CEOs 2, ©

De: Wiis OD kos CA SNR TG ee ee ‘Ae

Vv

Contents
Page
33 USC. S ZIAD oc oc oo ein ds ondseiens 7
Ae ES PER 6 ck PRG Ta Bob eee Rea S ee 9
SS UE SZ sho 55 et hee een’ beie anes 7
i BES Toe te ys! 2S rp eee roe Freee ee 7
pS 8 alt Te so) ye 2 SA e rer ream yee erg en 7
gtk fede Riis eee ree ree ee ee 4
Rules Cited:
Rule F of the Supplemental Rules for Certain Admiralty
and Maritime Claims of the Federal Rules of Civil
PRONE 5s SS 65 Bh nh eee eee aS > 3
Supreme Court Rule 10 ..... 2... cece ewer eee eeees 2
Supreme Court Rule 10(a) ............-.-- sees. 3
Supreme Court Rule 35(5) ...........- eee eee eeee 3

Supreme Court Rule 35(5)(b) ..........-2+-e eee 3

Contents
Page
Other Authorities Cited:
Felix Frankfurter and Henry M. Hart, Jr., The Business
of the Supreme Court at October Term, 1933, 48 Harv.
i EE oko he eke NCE aeeeh ARES eres 2, 3, 6
2 Thomas J. Schoenbaum, Admiralty and Maritime Law
oo Oe | Sn ee ren eS peo 8
23 James W. Moore, et al., Moore’s Fed. Practice (3d ed.
Pk a CASPER EEN SACK Es EO ae ER EEE ce 42
William Howard Taft, The Jurisdiction of the Supreme
Court under the Act of February 13, 1925, 35 Yale L.
BR Re.) RR ener Mime roy OD pina a ani we ey 6
H.R. Conf. Rep. No. 653, 101lst Cong., 2d Sess. 101
(1990), reprinted in 1990 U.S.C.C.A.N. (10: Stat.)
Sees Cha R eS ARTO OTE ee ed ee ee 8

l
REASONS FOR DENYING THE WRIT
I.

CERTIORARI SHOULD NOT BE GRANTED
BECAUSE NEITHER THE COURT OF APPEALS NOR
THE DISTRICT COURT HAS “SO FAR DEPARTED
FROM THE ACCEPTED AND USUAL COURSE OF
JUDICIAL PROCEEDINGS” AS TO WARRANT A
GRANT OF CERTIORARI.

Petitioners Bunker Group Inc., Bunker Group Puerto Rico,
Inc., and New England Marine Services, Inc. (collectively
“Bunker Group”) urge this Court to grant a writ of certiorari
under Supreme Court Rule 10(a) (Rule 10(a)) because

a United States court of appeals has so far departed
from the accepted and usual course of judicial
proceedings, or sanctioned such a departure by a
lower court, as to call for an exercise of this court's
supervisory power.

Pet. for Writ of Cert. at 3 (Pet. 3). Rule 10(a) does not provide
suitable grounds for granting certiorari in this case. The courts
have not misused the rules of procedure and practice, and there
is no reason for this Court to exercise its supervisory powers.
Historically, this Court has been reluctant to intervene in all but
the most egregious violations where a court clearly exceeds the
scope of its authority. See generally 23 James W. Moore, et al.,
Moore’s Fed. Practice, § 510.24 (3d ed. 1998). Bunker Group’s
petition fails to establish sufficient grounds for granting certiorari.

A. Bunker Group has failed to explain why a writ of
certiorari should be granted.

Bunker Group focuses solely on the merits of its argument
and never attempts to show any departure from the accepted

2 :

and usual course of judicial proceedings requiring this Court’s ;
supervision. Because Bunker Group has completely failed to i
show why this is one of the few cases which this Court should

consider, the Court should summarily deny certiorari without
considering the merits of Bunker Group’s argument. Simply

stated, Bunker Group does not allege any violation of major

concern to the integrity of the federal judicial process. Thus,

Supreme Court review is not warranted.

Years ago, Justice Frankfurter warned petitioners against
arguing their case on the merits and failing to explain why '
certiorari was proper. .

The major recurrent vice of petitions. . . is the failure
to perceive the elementary distinction between an
extended argument on the merits (obviously
inappropriate until the merits are before the Court)
and an argument on the issue whether certiorari
should or should not be granted. Only in exceptional
cases is any but cursory discussion of the merits
appropriate in the petition at all....

Felix Frankfurter and Henry M. Hart, Jr., The Business of the
Supreme Court at October Term, 1933, 48 Harv. L. Rev. 238,
265 (1934). Justice Frankfurter explained that the brief must be
“confined to argument upon the reasons relied on for allowance
of the writ.” Jd. at 266.

B. Bunker Group cannot show that the courts below
departed from the accepted and usual course of judicial
proceedings in this case of statutory interpretation.

Bunker Group seeks to invoke the least likely basis for
certiorari under the Rule 10 alternatives. The Court seldom
invokes its supervisory powers as a basis for granting a writ.
Justice Frankfurter’s initial guidance on application of former

iia ial

3

Rule 35(5)(b), the predecessor of current Rule 10(a),' explained
the limited basis for granting certiorari under these conditions:

The ratio of successful to attempted invocations for
this reason is smaller than that of any other. To scores
of petitions each year, any asserted error in the
decision of a case, however minute and of whatever
character, is such a departure “from the accepted and
usual course of judicial proceedings” as to call for
an exercise of the Supreme Court’s power of
supervision. Of course, the reason refers neither to
errors of law nor to minor departures from customary
practice. It refers to matters of major concern to the
integrity of the federal judicial process. How rarely
the Supreme Court regards as necessary any
intervention on this ground appears from the fact
that no single grant of certiorari last term was
attributable to it....

48 Harv. L. Rev. at 274. Certiorari should be denied because
Bunker Group has not shown the manner in which the courts
below have so far departed from the accepted and usual course
of judicial proceedings as to create an issue of major concern to
the integrity of the federal judicial process.

Historically, this Court has invoked its supervisory powers
reluctantly, reserving them for only the most egregious instances
of abuse or ignorance of clear directives. See, e.g., Thermtron
Products, Inc. v. Hermansdorfer, 423 U.S. 336, 344 (1976)
(certiorari granted after appellate court improperly remanded a
case after removal in order to reduce overburdened federal
docket); Connor v. Coleman, 440 U.S. 612, 622 (1979)
(Marshall, J., dissenting) (three-judge panel ignored Court

1. See 23 James W. Moore, et al., Moore’s Fed. Practice, § 510
App. 01 (3d ed. 1998) (text of Supreme Court Rule 35(5) of the 1925
Rules).

4

directive on implementing apportionment plan) Hickman v.
Taylor, 329 U.S. 495, 514 (1947) (certiorari granted to define
the scope of the attorney work product exception to discovery);
Zahn v. International Paper Co., 414 U.S. 291, 292 (1973)
(certiorari granted to address the application of jurisdictional
amounts in controversy under class action suits); Hanna v.
Plumer, 380 U.S. 460, 463 (1965) (certiorari granted to
determine whether federal service of process rules are replaced
by state law); New York City Transit Auth. v. Beazer, 440 U.S.
568, 570 (1979) (court incorrectly decided a constitutional issue
before a statutory issue); Valley Forge Christian College v.
Americans United for Separation of Church and State, Inc.,
454 U.S. 464, 470 (1982) (certiorari granted to correct a broad
and novel view of standing).

Bunker Group has not met its burden of showing the
presence of any issues of a magnitude requiring the Court to
exercise its supervisory powers over a lower court. Accordingly,
certiorari should be denied.

C. No other compelling reasons warrant a grant of
certiorari.

The principal purpose for which this Court uses certiorari
jurisdiction is to resolve conflicts among circuit courts of appeals
and state courts concerning the meaning of provisions of federal
law. Braxton v. United States, 500 U.S. 344, 348 (1991). No
such reason exists in this case. Because the First Circuit is the
only court of appeals which has considered the arguments raised
by Bunker Group, there is no conflict among the federal circuits.
In addition to the Puerto Rico district court, every district court
which has considered the issue has reached the same result —
that the Limitation of Shipowners Liability Act, 46 U.S.C.
§§ 181-89 (Limitation Act) does not apply to claims for oil
spill removal costs and damages. See In re JAHRE SPRAY II,
1997 A.M.C. 845, 855, 1996 WL 451315, *4 (D.N.J. 1996);

5

In re Odin Marine Corp., No. 96-5438, slip op. at 6 (S.D.N-Y.
Aug. 7, 1997);? Tug Capt. Fred Bouchard Corp. v. M/V BALSA
37, No. 93-1321-CN-T-23B, slip op. at 2 (M.D. Fla. Oct. 22,
1996)°. Further, there are no important federal questions which
have been decided by a state court of last resort.

Bunker Group’s concerns about the lack of a concursus
procedure‘ for oil pollution claims does not present an important
question of federal law which has not been, but should be,

2. This case is on appeal to the Second Circuit.

3. This case is on appeal to the Eleventh Circuit, but as noted
in the Memorandum of Amicus Curiae filed by Bouchard
Transportation Co., Inc., it may be procedurally different from the
instant case. Memorandum of Amicus Curiae at 2.

4. The “concursus” is a procedural device established by the
Limitation Act and Rule F of the Supplemental Rules for Certain
Admiralty and Maritime Claims of the Federal Rules of Civil
Procedure (Rule F). It is somewhat like an interpleader procedure,
but is unique to vessel owners. Its only purpose is to marshal the
vessel owner's assets (the limitation fund) in a single court
proceeding for pro rata distribution among multiple claimants. Its
purpose is not to marshal the claimants. A concursus is not available
if the limitation fund is adequate to pay all claims in full. Lake
Tankers Corp. v. Henn, 354 U.S. 147, 151-52, reh’g. denied, 354 U.S.
945 (1957).

In contrast, Congress intended for full compensation of all
allowable claims under the Oil Pollution Act of 1990, 33 U.S.C.
§§ 2701-61 (OPA), from either those responsible for the spill or from
the National Pollution Funds Center (the Fund). No fund is deposited
with any court for distribution. OPA claims not paid by the
responsible party may be presented to the Fund for payment. Because
no court is required to marshal and distribute a fund, concursus is
inapplicable. Also, concursus is never available for responsible
parties who are not vessel owners. e.g. owners and operators of
facilities such as pipeline and terminals.

6

settled by this Court. Congress, not the judiciary branch, should
address Bunker Group’s concerns. In August 1996, Senator Breaux
of Louisiana proposed an amendment to the Oil Pollution Act of
1990, 33 U.S.C. §§ 2701-61 (OPA), creating a concursus procedure
for an OPA claim. See S. 2009, 104th Cong., Ist Sess. § 106
(1996) (proposed OPA amendment to create concursus). The
proposal was not enacted.

Bunker Group’s issues with OPA do not rise to the high level
of importance required for granting certiorari. The importance of a
question presented is measured by matters of “genuine, intrinsic
public significance,” or where the law requires uniformity. See
generally 42 Harv. L. Rev. at 271-272. See also William Howard
Taft, The Jurisdiction of the Supreme Court under the Act of
February 13, 1925, 35 Yale L. J. 1, 2 (1925) (“The function of the
Supreme Court is conceived to be, not the remedying of a particular
litigant’s wrong, but the consideration of cases whose decision
involves principles, the application of which are of wide public or
governmental interest, and which should be authoritatively declared
by the final court.”). Bunker Group simply fails to address either a
need for uniformity or a question of widespread public concern.

For these reasons, Bunker Group’s petition for certiorari should
be denied.

Il.

APPLYING THE ACCEPTED AND USUAL COURSE
OF JUDICIAL PROCEEDINGS, THE COURTS BELOW
CORRECTLY CONCLUDED THAT OPA IMPLICITLY
REPEALED THE LIMITATION ACT AS TO CLAIMS FOR
OIL SPILL REMOVAL COSTS AND DAMAGES.

In its de novo review of OPA, the court of appeals concluded
that OPA repealed the Limitation Act as to oil spill pollution claims in

7 =

the instant case. In re MetLife Capital Corp., 132 F.3d 818, 822
(ist Cir. 1997); Pet. App. Al-A13, A-9. It found five OPA
provisions which explicitly repealed the Limitation Act as to
oil spill claims, as well as other provisions which irreconcilably
conflicted with the Limitation Act. Jd. The court recognized
that where the provisions of two acts cannot be reconciled, the
later act, to the extent of the conflict, constitutes an implied
repeal of the earlier one. Jd. (quoting Radzanower v. Touche
Ross & Co., 426 U.S. 148, 154 (1976) (quoting Posadas v.
National City Bank, 296 U.S. 497, 503 (1936))).

The five OPA provisions recognized by the court of appeals
as conflicting with the Limitation Act are codified at 33 U.S.C.
§ 2702(a) (section’s “notwithstanding” clause suggests that OPA
repealed the Limitation Act with respect to oil spill removal
costs and damages), 33 U.S.C. § 2702(d)(1)(A) (repealing the
Limitation Act as to third parties solely responsible for a spill),
33 U.S.C. § 2718(a) (repealing the Limitation Act as to state
and local statutory remedies), 33 U.S.C. § 2718(c)(1) (repealing
the Limitation Act as to additional liability imposed by the
United States, any state, or political subdivision), and 33 U.S.C.
§ 2718(c)(2) (repealing the Limitation Act as to fines and
penalties). In re MetLife, 132 F.3d at 821; Pet. App. A-8.

When it evaluated OPA’s § 2702(a) requirement that the
responsible party is liable for oil spill removal costs and damages
“notwithstanding any other provision or rule of law,” the court
of appeals followed the reasoning used by other courts
interpreting similar language in the Federal Water Pollution
Control Act, 33 U.S.C. §§ 1251-1387 (FWPCA). Those courts
held that the FWPCA’s “notwithstanding” phrase precluded
application of the Limitation Act to claims for FWPCA pollution
removal costs. See In re MetLife, 132 F.3d at 821; Pet. App. A-
8, (citing In re Oswego Barge Corp., 664 F.2d 327, 340 (2d
Cir. 1981); In re Hokkaido Fisheries Co., Ltd., 506 F. Supp.

8

631, 634 (D. Alaska 1981))°. The court found those cases
persuasive because neither OPA’s language nor its legislative
history suggests that OPA should be construed contrary to the
settled law applicable to the FWPCA when OPA was enacted.
Id.

While the court of appeals recognized that repeal of statutes
by implication is disfavored, it found that several key provisions
of the two statutes are plainly inconsistent. /d. at 822; Pet. App.
A-9. Further, the court found OPA’s legislative history consistent
with its interpretation. /d. The court cited a provision expressly
demonstrating Congress’s intent for OPA to supersede the
Limitation Act for oil spill removal costs and damages:

Liability under this Act is_ established
notwithstanding any other provision or rule of law.
This means that the liability provisions of this Act
would govern compensation for removal costs and
damages notwithstanding any limitations under
existing statutes such as the act of March 3,
Sar

In re MetLife, 132 F.3d at 822; Pet. App. A-10, (citing H.R.
Conf. Rep. No. 653, 101st Cong., 2d Sess. 101 (1990),
reprinted in 1990 U.S.C.C.A.N. (101 Stat.) 779, 781 (Joint
Explanatory Statement of the Conference Committee explaining
§ 2702(a))).

While concluding that OPA repealed the Limitation Act as
to claims for oil spill removal costs and damages arising under

5. The court of appeals also cited 2 Thomas J. Schoenbaum,
Admiralty and Maritime Law, 376 (2d ed. 1994) (“OPA broadly
supersedes the Limitation of Liability Act with respect to damages
and removal costs under both federal and state law, including
common law”). /d.

9

OPA, the court of appeals correctly recognized that some of the
claims arising from an incident in which oil pollution occurs
may remain within the scope of the Limitation Act. Jn re MetLife,
132 F.3d at 822; Pet. App. A-10. For example, maritime tort
actions for injury or damages to persons or vessels remain subject
to the Limitation Act. Jd. The district court correctly reserved
the limitation plaintiffs’ right to seek limitation of liability for
those claims subject to reduction under the Limitation Act. Jn
re MetLife, 132 F.3d at 822-23; Pet. App. A-10 through A-11.

Certiorari should not be granted because the court’s analysis
of these issues simply has not departed from the accepted and
usual course of judicial proceedings.

Il.

THE COURTS BELOW CORRECTLY HELD THAT
RULE F IS INAPPLICABLE TO CLAIMS FOR OIL
SPILL REMOVAL COSTS AND DAMAGES.

The court of appeals also considered de novo Bunker
Group’s argument that even if OPA supersedes the Limitation
Act, the concursus provisions of Rule F apply to actions under
OPA independently from the Limitation Act. in re MetLife, 132
F.3d at 823-24; Pet. App. A-11 through A-13. The court
concluded that Rule F’s venue and limitation of liability
requirements cannot be reconciled with OPA. Jn re MetLife,
132 F.3d at 823; Pet. App. A-11 through A-12. Similarly, the
court concluded that Rule F’s deadline for filing claims is also
inconsistent with OPA’s statute of limitations. Jn re MetLife,
132 F.3d at 823; Pet. App. A-12. The court noted that contrary
to Bunker Group’s contentions, OPA establishes a claims
procedure. Jn re MetLife 132 F.3d at 824; Pet. App. A-13.
(outlining OPA’s claim procedure in 33 U.S.C. § 2713 and
contrasting it with Rule F). After comparing OPA’s requirements

10

with those of Rule F, the court concluded that the inconsistencies
between the two procedures rendered Rule F inapplicable to
OPA claims, even if Rule F applies in situations separate from
the Limitation Act. Jd.

Bunker Group has not shown, and cannot show, the manner
in which the court’s thorough analysis of the applicability of
Rule F to OPA claims has departed from the accepted and usual
course of judicial proceedings.

CONCLUSION

The petitioners have not shown that either the court of
appeals or the district court has “so far departed from the
accepted and usual course of judicial proceedings” as to warrant
exercise of this Court’s supervisory powers. Because they cannot
do so, they have presented only their argument on the merits.
The courts’ interpretation of OPA does not create a conflict
among Circuit courts of appeals or state courts concerning the
meaning of provisions of federal law, or any other basis for
granting certiorari. If the petitioners seek to have OPA changed,
they should petition Congress for relief. Certiorari should not
be granted.

1]
Respectfully submitted,

JOSE A. FUENTES AGOSTINI
ATTORNEY GENERAL
COMMONWEALTH OF
PUERTO RICO

P.O. Box 192

San Juan, Puerto Rico 00902
(787) 721-7700

ANTONIO J. RODRIGUEZ
Counsel of Record

ALANSON T. CHENAULT, IV
RICE FOWLER

201 St. Charles Avenue

36th Floor

New Orleans, Louisiana 70170
(504) 523-2600

JOHN F. NEVARES

SMITH & NEVARES

P.O. Box 13667

Santurce Station

San Juan, Puerto Rico 00908-3667
(787) 722-9333

Attorneys for the Commonwealth of
Puerto Rico, on its own behalf, and as
Public Trustee and as parens patriae for
the Citizens of the Commonwealth, the
Board on Environmental Quality of the
Commonwealth of Puerto Rico, the
Department of Natural Resources of the
Commonwealth of Puerto Rico and the
Puerto Rico Tourism Company

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386006_1324%3A2. Public record. Not legal advice.