UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

ADA MERCEDES CONDE VIDAL and
IVONNE LVAREZ VLEZ; MARITZA
LPEZ AVILS and IRIS DELIA RIVERA
RIVERA; JOS A. TORRUELLAS IGLESIAS
and THOMAS J. ROBINSON; ZULMA
OLIVERAS VEGA and YOLANDA ARROYO
PIZARRO; JOHANNE VLEZ GARCA and
FAVIOLA MELNDEZ RODRGUEZ; and
PUERTO RICO PARA TOD@S,

Plaintiffs,

v.

ALEJANDRO J. GARCA PADILLA, in his
official capacity as Governor of the
Commonwealth of Puerto Rico; ANA RIUS
ARMENDARIZ, in her official capacity as
Secretary of the Health Department of the
Commonwealth of Puerto Rico; WANDA
LLOVET DAZ, in her official capacity as
Director of the Commonwealth of Puerto Rico
Registrar of Vital Records; and MELBA ACOSTA
FEBO, in her official capacity as Director of the
Treasury in Puerto Rico,

Defendants.




Civil Action No. 3:14-cv-01253-PG



PLAINTIFFS MEMORANDUM IN OPPOSITION TO
DEFENDANTS MOTION REQUESTING THE COURT DENY OR HOLD
IN ABEYANCE PLAINTIFFS MOTION FOR SUMMARY JUDGMENT



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ii


TABLE OF CONTENTS



INTRODUCTION......................................................................................................................... 1
ARGUMENT ................................................................................................................................. 2
I. Defendants Do Not Satisfy the Requirements of Rule 56(d). ............................ 2
II. Plaintiffs Motion for Summary Judgment Is Not Premature, and
Should Be Decided Simultaneously with Defendants Motion to
Dismiss. .................................................................................................................. 6
III. Delay in Adjudicating Plaintiffs Constitutional Claims Causes
Irreparable Injury. ............................................................................................... 8
CONCLUSION ............................................................................................................................. 9

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TABLE OF AUTHORITIES
Cases
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) ............................................................................6
Asociacin de Periodistas v. Mueller, 680 F. 3d 70 (1st Cir. 2012) ................................................3
Baskin v. Bogan, No. 14-cv-00355, 2014 U.S. Dist. LEXIS 86114 (S.D. Ind. June 25, 2014)...4, 7
Bogan v. Baskin, No. 14-277 (U.S. Oct. 6, 2014) ............................................................................2
Bostic v. Rainey, 970 F. Supp. 2d 456 (E.D. Va. 2014)...................................................................4
Cannon v. District of Columbia, 717 F.3d 200 (D.C. Cir. 2013) ....................................................5
Connolly v. Roche, No. 14-cv-00024 (D. Ariz., filed Mar. 31, 2014) .............................................5
Elrod v. Burns, 427 U.S. 347 (1976) ...............................................................................................8
FDIC v. Arciero, 741 F.3d 1111 (10th Cir. 2013) ...........................................................................5
Geiger v. Kitzhaber, No. 13-cv-01834, 994 F. Supp. 2d 1128 (D. Or. 2014) .............................4, 7
Gettings v. Bldg. Laborers Local 310 Fringe Benefits Fund, 349 F.3d 300 (6th Cir. 2003) ...........5
Hamby v. Parnell, No. 14-cv- 00089, 2014 U.S. Dist. LEXIS 145876 (D. Alaska Oct. 12, 2014) 7
Harrods Ltd. v. Sixty Internet Domain Names, 302 F.3d 214 (4th Cir. 2002) ................................5
Herbert v. Kitchen, No. 14-124 (U.S. Oct. 6, 2014) ........................................................................1
Jones v. Secord, 684 F.3d 1 (1st Cir. 2012) .................................................................................3, 5
Latta v. Otter, No. 13-cv-00482, 2014 U.S. Dist. LEXIS 66417 (D. Idaho May 13, 2014) .......4, 7
Love v. Beshear, 989 F. Supp. 2d 536 (W.D. Ky. 2014) .............................................................3, 4
Majors v. Horne, No. 14-cv-00518 (D. Ariz., filed July 7, 2014) ...................................................4
Mattoon v. City of Pittsfield, 980 F.2d 1 (1st Cir. 1992) .................................................................6
McQuigg v. Bostic, No. 14-251 (U.S. Oct. 6, 2014) ........................................................................1
Mir-Yepez v. Banco Popular de P.R., 560 F.3d 14 (1st Cir. 2009) .................................................3
Nader v. Blair, 549 F.3d 953 (4th Cir. 2008) ..................................................................................5
Paddington Partners v. Bouchard, 34 F.3d 1132 (2d Cir. 1994) ....................................................5
Paterson-Leitch Co. v. Mass. Mun. Wholesale Elec. Co., 840 F.2d 985 (1st Cir. 1998) ................5
Rainey v. Bostic, No. 14-153 (U.S. Oct. 6, 2014) ............................................................................1
Rivera-Torres v. Rey-Hernndez, 502 F.3d 7 (1st Cir. 2007)..........................................................5
Schaefer v. Bostic, No. 14-225 (U.S. Oct. 6, 2014) .........................................................................1
Smith v. Bishop, No. 14-136 (U.S. Oct. 6, 2014) .............................................................................1
Snchez-Rodrguez v. AT&T Mobility P.R., Inc., 673 F.3d 1 (1st Cir. 2012) ..................................2
Taylor v. Brasuell, No. 14-cv-00273 (D. Idaho, filed Aug. 6, 2014) ..............................................5
Vlez v. Awning Windows, Inc., 375 F.3d 35 (1st Cir. 2004) ..........................................................3
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Wal-Mart Stores v. Rodriguez, 238 F. Supp. 2d 395 (D.P.R. 2002) ................................................8
Walker v. Wolf, No. 14-278 (U.S. Oct. 6, 2014) ..............................................................................2
Whitewood v. Wolf, No. 13-cv-01861, 992 F. Supp. 2d 410 (M.D. Pa. 2014) ................................7
Wolf v. Walker, No. 14-cv-00064, 986 F. Supp. 2d 982 (W.D. Wis. Mar. 20, 2014) .................4, 7
Constitutional Provisions
U.S. Const. amend XIV ...............................................................................................................1, 7
Statutes
31 L.P.R.A. 221 ............................................................................................................................4
Rules
Federal Rule of Civil Procedure 56 ....................................................................................... passim
Local Rule 5(e) ................................................................................................................................1
Local Rule 7(b) ................................................................................................................................1



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Pursuant to Local Rules 5(e) and 7(b), Plaintiffs Ada M. Conde Vidal and Ivonne lvarez
Vlez, by and through their attorney; and Plaintiffs Maritza Lpez Avils and Iris Delia Rivera
Rivera, Jos A. Torruellas Iglesias and Thomas J. Robinson, Zulma Oliveras Vega and Yolanda
Arroyo Pizarro, Johanne Vlez Garca and Faviola Melndez Rodrguez, and the organization
Puerto Rico Para Tod@s, by and through their attorneys (collectively Plaintiffs), respectfully
submit the following memorandum of law opposing Defendants Rule 56(d) motion requesting
that this court deny or hold in abeyance Plaintiffs motion for summary judgment.
INTRODUCTION
As of this filing, thirty states
1
and the District of Columbia recognize the constitutional
right of same-sex couples to marry. Indeed, a remarkable and nearly unbroken seismic wave of
federal court rulings across the country has struck down state statutory and constitutional
marriage bans similar to Puerto Ricos ban. Numerous federal courts have held that laws
prohibiting Banned Couples from marrying or having their out-of-state marriages recognized
violate the Fourteenth Amendment of the United States.
2
The overwhelming majority of these
courts have decided these constitutional questions promptly and without the need for discovery.
And the Supreme Court of the United States has allowed these judgments to stand by recently
refusing review of cases from the Fourth, Seventh and Tenth Circuits.
3
This case, these
Plaintiffs, and Puerto Ricos Marriage Ban should be treated no differently.

1
Those states include: Alaska, California, Colorado, Connecticut, Delaware, Hawaii, Idaho, Illinois, Indiana, Iowa,
Maine, Maryland, Massachusetts, Minnesota, Nevada, New Hampshire, New Jersey, New Mexico, New York,
North Carolina, Oklahoma, Oregon, Pennsylvania, Rhode Island, Utah, Vermont, Virginia, Washington, Wisconsin,
and West Virginia. In addition, binding precedent from the Fourth and Tenth Circuits augurs that the right of LGBT
couples to marry will soon be recognized in three more states, Kansas, South Carolina, and Wyoming.
2
Defined terms in the Amended Complaint have the same meaning when used in this opposition. See Dkt. 7.
3
See Herbert v. Kitchen, No. 14-124 (U.S. Oct. 6, 2014); Smith v. Bishop, No. 14-136 (U.S. Oct. 6, 2014); Rainey v.
Bostic, No. 14-153 (U.S. Oct. 6, 2014); Schaefer v. Bostic, No. 14-225 (U.S. Oct. 6, 2014); McQuigg v. Bostic, No.
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Defendants have asked this court to deny or hold in abeyance Plaintiffs motion for
summary judgment on the basis that Defendants have not had the opportunity to conduct
discovery. Dkt. 48. This motion must fail because Defendants have not identified any disputed
material facts that discovery could reveal. Indeed, there are no material facts in dispute, and this
case therefore can and should be decided as a matter of law. Where, as here, the question before
the court is a legal issue, no discovery is necessary for a determination of the claims. For the
same reason, Defendants related argument that Plaintiffs motion was filed prematurely is also
without merit. See Dkt. 48 at 4.
Further, the issues raised in Defendants motion to dismiss and Plaintiffs motion for
summary judgment substantially overlap, and there is no reason to delay adjudication of one
motion while ruling on the other. Lastly, but importantly, Plaintiffs suffer irreparable injury as a
direct result of Defendants enforcement of Puerto Ricos Marriage Ban. Delay in the
adjudication of the claims in this case has very real and ongoing consequences for Plaintiffs and
their families.
Accordingly, because Defendants have failed to meet the standard for a Rule 56(d)
motion and because Plaintiffs motion for summary judgment is ripe for decision, the Court
should deny Defendants motion requesting that this Court deny or hold in abeyance Plaintiffs
motion for summary judgment.
ARGUMENT
I. Defendants Do Not Satisfy the Requirements of Rule 56(d).

Summary judgment is appropriate when there is no genuine issue of material fact and
the moving party is entitled to judgment as a matter of law. Snchez-Rodrguez v. AT&T

14-251 (U.S. Oct. 6, 2014); Bogan v. Baskin, No. 14-277 (U.S. Oct. 6, 2014); Walker v. Wolf, No. 14-278 (U.S. Oct.
6, 2014).
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Mobility P.R., Inc., 673 F.3d 1, 9 (1st Cir. 2012) (internal citations and quotations omitted). And
Federal Rule of Civil Procedure 56(b) is clear that a party may file a motion for summary
judgment at any time. A party seeking to invoke Rule 56(d) to delay consideration of a
summary judgment motion must provide to the court an affidavit or declaration that: (i) explains
his or her current inability to adduce the facts essential to filing an opposition, (ii) provides a
plausible basis for believing that the sought-after facts can be assembled within a reasonable
time, and (iii) indicates how those facts would influence the outcome of the pending summary
judgment motion. Jones v. Secord, 684 F.3d 1, 6 (1st Cir. 2012) (quoting Vlez v. Awning
Windows, Inc., 375 F.3d 35, 40 (1st Cir. 2004)). Defendants do not and cannot meet this
standard.
A basic tenet of Rule 56[(d)] practice is that the party seeking discovery must explain
how the facts, if collected, will suffice to defeat the pending summary judgment motion.
Asociacin de Periodistas v. Mueller, 680 F. 3d 70, 77 (1st Cir. 2012) (quoting Mir-Yepez v.
Banco Popular de P.R., 560 F.3d 14, 16 (1st Cir. 2009)). Defendants motion fails to identify
any facts that, if collected, would suffice to defeat Plaintiffs motion for summary judgment.
There is one very simple explanation for this failure: in this action, as in other challenges to
restrictions on the right to marry, there are no disputable material facts. Cf. Love v. Beshear, 989
F. Supp. 2d 536, 541 (W.D. Ky. 2014) (No one disputes that [the Commonwealths] laws treat
same-sex couples differently than opposite sex couples who wish to marry in [the
Commonwealth]. No one disputes that the equal protection issue before the Court involves
purely questions of law. Therefore, Plaintiffs challenge is properly resolved on summary
judgment.).
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First, Defendants do not and cannot dispute that the Marriage Ban prohibits LGBT
individuals from marrying in Puerto Rico and from having their valid marriages entered into in
other jurisdictions recognized here. 31 L.P.R.A. 221; cf. Bostic v. Rainey, 970 F. Supp. 2d 456,
472 (E.D. Va. 2014) ([T]here is . . . no dispute that under Virginias Marriage Laws, Plaintiffs
and Virginia citizens similar to Plaintiffs are deprived of [the] right to marry.); Love v. Beshear,
989 F. Supp. 2d at 541. Defendants are enforcers of the Marriage Ban and are urging that the
law be upheld. See Am. Compl. 42-46; see also Dkt. 31 (Mot. to Dismiss) at 21 (arguing that
[the Marriage Ban] has a rational basis in law and thus does not violate equal protection.).
Second, it cannot be seriously disputed that Plaintiffs and other Banned Couples suffer
ongoing economic, health-care-related and other harms as a result the Marriage Ban. Much of
that harm occurs as a matter of law, as Banned Couples are deprived of legal rights available to
Accepted Couples. Defendants do not assert that they need discovery to dispute the existence of
harm to Banned Couples from the enforcement of the Marriage Ban.
Third, this case involves solely the constitutionality of the Marriage Ban. This legal
questionwhether the Marriage Ban violates the constitutional guarantees of equal protection or
due processcan be answered based on the record already before the Court. There is no need
for discovery to uncover any other facts, as none would affect the pending summary judgment
motion. Plaintiffs claims can be decided as a matter of law, and therefore this action should
proceed to summary judgment without discovery, as have other similar cases.
4


4
See, e.g., Baskin v. Bogan, No. 14-cv-00355, 2014 U.S. Dist. LEXIS 86114 (S.D. Ind. June 25, 2014) (granting
summary judgment motion that was filed within a month of the amended complaint); Geiger v. Kitzhaber, No. 13-
cv-01834, 994 F. Supp. 2d 1128 (D. Or. 2014) (same); Latta v. Otter, No. 13-cv-00482, 2014 U.S. Dist. LEXIS
66417 (D. Idaho May 13, 2014) (same); Bostic v. Rainey, No. 13-cv-00395, 970 F. Supp. 2d 456 (E.D. Va. Feb. 13,
2014 ) (same); see also Transcript of Pretrial Conference, Wolf v. Walker, No. 14-cv-00064, 986 F. Supp. 2d 982
(W.D. Wis. Mar. 20, 2014), ECF 65 at 6 (At this point its hard to see or at least its difficult to see what sort of
discovery actually would be necessary here.) (Crocker, Mag. J.); Joint Initial Case Status Report and Scheduling &
Planning Conference Report, Majors v. Horne, No. 14-cv-00518 (D. Ariz., filed July 7, 2014), ECF 25 (The parties
. . . plan to submit cross-motions for summary judgment without conducting discovery.); Scheduling Conference
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Defendants also fail to meet the express requirements of a Rule 56(d) motion. As an
initial matter, they have not proffered the required affidavit or declaration specifying any reasons
for their request. See Jones, 684 F.3d at 6.
5
Even if the court were to overlook this deficiency,
Defendants motion also fails to identify any specified reasons that they cannot present facts
essential to justify [their] opposition. Fed. R. Civ. P. 56(d). Defendants cannot specify any
missing facts because discovery is not necessary for adjudication of Plaintiffs claims.
A Rule 56(d) moving party must provide a plausible basis for believing that additional
facts probably exist and can be retrieved within a reasonable time. Rivera-Torres v. Rey-
Hernndez, 502 F.3d 7, 10 (1st Cir. 2007). As noted above, Defendants do not even try to
identify the facts they would seek in discovery. Instead, they refer vaguely to the discovery that
they deem necessary. Dkt. 48 at 4. But [s]peculative conclusions, unanchored in facts, are not
sufficient to ground a Rule [56(d)] motion. Rivera-Torres, 502 F.3d at 12. See also Paterson-
Leitch Co. v. Mass. Mun. Wholesale Elec. Co., 840 F.2d 985, 989 (1st Cir. 1998) ([C]ryptic
allusions [that] fail[] to set out any basis for believing that some discoverable material facts . . .

Form, Taylor v. Brasuell, No. 14-cv-00273 (D. Idaho, filed Aug. 6, 2014), ECF 10 (indicating that the case involves
legal issues and that the parties will not undertake discovery); Joint Initial Case Status Report and Scheduling &
Planning Conference Report, Connolly v. Roche, No. 14-cv-00024 (D. Ariz., filed Mar. 31, 2014), ECF 25 (The
parties plan to submit cross-motions for summary judgment without conducting discovery.).
5
Defendants cite to two cases in the Fourth Circuit for the proposition that a Rule 56(d) motion need not be
accompanied by an affidavit. Dkt. 48 at 3. In one of those cases, the Rule 56(d) motion was denied, and the denial
was affirmed because an affidavit would have made no difference. See Nader v. Blair, 549 F.3d 953, 961 (4th Cir.
2008). The other involved a claim that turned on a fact-specific issue, and the moving partys failure to submit an
affidavit was excused only because the party repeatedly had indicated to the district court that it required discovery
and explained the type of discovery it required. Harrods Ltd. v. Sixty Internet Domain Names, 302 F.3d 214, 246
(4th Cir. 2002). Here, Defendants have failed to identify any issue of fact in any of their moving papers.
Moreover, the First Circuit is not alone in demanding strict adherence with the requirement that a Rule 56(d) motion
be accompanied by an affidavit. Other circuits, including the Second, Sixth, Tenth, and District of Columbia Circuit
Courts of Appeals, also demand such strict adherence to the affidavit requirement. See Paddington Partners v.
Bouchard, 34 F.3d 1132, 1137 (2d Cir. 1994) ([T]he failure to file an affidavit under Rule 56(f) is itself sufficient
grounds to reject a claim that the opportunity for discovery was inadequate.); see also Gettings v. Bldg. Laborers
Local 310 Fringe Benefits Fund, 349 F.3d 300, 305 (6th Cir. 2003); FDIC v. Arciero, 741 F.3d 1111, 1116 (10th
Cir. 2013); Cannon v. District of Columbia, 717 F.3d 200, 208 (D.C. Cir. 2013).
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exist are entirely inadequate to extract the balm of Rule 56(f).). This Court should deny a
Rule 56(d) motion that merely conjectures that something might be discovered but provides no
realistic basis for believing that further discovery would disclose evidence that would generate
genuine and material disputes of fact. Mattoon v. City of Pittsfield, 980 F.2d 1, 8 (1st Cir. 1992).
Here, Defendants have failed to provide a plausible basisor any basis at allfor believing that
additional facts relevant to their defense exist and can be identified.
Defendants have failed to meet any of Rule 56(d)s requirements, and their motion should
be denied.
II. Plaintiffs Motion for Summary Judgment Is Not Premature, and Should Be
Decided Simultaneously with Defendants Motion to Dismiss.

Defendants also argue that postponement of summary judgment is appropriate even
without a Rule 56(d) affidavit or declaration where the party adequately notifies the court that
the motion is premature and that additional, specified discovery is necessary. Dkt. 48 at 3.
Defendants cite to no First Circuit case law supporting this argument, nor do the cases to which
they cite support their position.
6
Anderson v. Liberty Lobby, cited by Defendants for the
proposition that an early summary judgment motion should be refused as a matter of course,
Dkt. 48 at 3, says only that summary judgment may be refused where the nonmoving party has
not had the opportunity to discover information that is essential to his opposition. Anderson,
477 U.S. 242, 250 n.5 (1986) (emphasis added). Defendants have pointed to no factual
information essential to their opposition because, as previously stated, there is none.
As noted, Federal Rule of Civil Procedure 56(b) permits a party to file a motion for
summary judgment at any time. In fact, numerous other cases challenging laws barring
marriages of same-sex couples have been decided directly on summary judgment motions filed

6
See note 5, supra.
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within months of the filing of a complaint or amended complaint. See, e.g., Hamby v. Parnell,
No. 14-cv- 00089, 2014 U.S. Dist. LEXIS 145876 (D. Alaska Oct. 12, 2014) (summary
judgment decision within five months after filing of the complaint); Wolf v. Walker, 986 F. Supp.
2d 982 (W.D. Wis. 2014) (summary judgment decision approximately three months after filing
of amended complaint); Baskin, 2014 U.S. Dist. LEXIS 86114 (same); Fujii v. Pence, No. 14-cv-
00404, 2014 U.S. Dist. LEXIS 86114 (S.D. Ind., June 25, 2014) (same); Geiger, 994 F. Supp. 2d
1128 (summary judgment decision within five months after filing of amended complaint); Latta,
2014 U.S. Dist. LEXIS 66417 (same).
Moreover, Plaintiffs motion for summary judgment and Defendants motion to dismiss
are largely two sides of the same coin. They raise many of the same points, including the key
issues of whether Puerto Ricos Marriage Ban violates the Equal Protection and Due Process
Clauses of the Fourteenth Amendment. Compare Dkt. 31 at 18-22 (arguing that Puerto Ricos
Marriage Ban is subject to rational basis analysis and should be presumed valid), and Dkt. 53-1
at 3-4 (same), with Dkt. 44 at 4-25 (arguing that the Marriage Ban is subject to heightened
scrutiny, violates Plaintiffs fundamental right to marry, and denies them equal protection of the
laws), and Dkt. 45 at 20-25 (same). Given the substantial overlap of issues between these
pleadings, addressing Defendants motion to dismiss and Plaintiffs motion for summary
judgment simultaneously would promote judicial efficiency and allow this Court to address the
substantive issues in this case in a logical and effective manner, as other courts in similar
situations have done. See, e.g., Whitewood v. Wolf, No. 13-cv-01861, 992 F. Supp. 2d 410
(M.D. Pa. 2014); Latta, 2014 U.S. Dist. LEXIS.


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III. Delay in Adjudicating Plaintiffs Constitutional Claims Causes Irreparable
Injury.

Lastly, and no less importantly, constitutional violations constitute per se irreparable
harm. See Elrod v. Burns, 427 U.S. 347, 373 (1976) (the loss of constitutional freedoms, for
even minimal periods of time, unquestionably constitutes irreparable injury). See also Wal-
Mart Stores v. Rodriguez, 238 F. Supp. 2d 395, 421 (D.P.R. 2002) (A presumption of
irreparable harm flows from and is triggered by an alleged deprivation of constitutional rights.).
Thus, any delay in adjudicating Plaintiffs claims causes irreparable injury. Each passing day is
one in which Plaintiffs are deprived of their fundamental right to marry the person of their
choice. Am. Compl. 25, 35, 48, 72-81. It is also a day in which Plaintiffs are denied the
important rights, benefits and protections attendant to marriage. For example, each day the
Marriage Ban remains in place is a day in which Iriss family receives less Veterans Disability
Compensation because she cannot marry Maritza, Am. Compl. 23; and Johanne and Faviola
cannot jointly adopt to grow their family, Am. Compl. 39. Indeed, every day that Defendants
enforce the Marriage Ban means that should any of the Plaintiffs barred from marriage become
incapacitated or die, their families could be deprived for all time of these marital protections.
Defendants unsupported assertion that they need discovery to find some unspecified facts
relevant to summary judgment provides no basis to delay the adjudication of Plaintiffs claims,
thereby prolonging the harms that they endure.
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CONCLUSION
For the foregoing reasons, this Court should deny Defendants Rule 56(d) motion and
should direct Defendants to file their opposition to Plaintiffs motion for summary judgment
promptly, and no later than fourteen (14) days, as set forth in Local Rule 7(b), after said denial.
7

Dated: October 15, 2014
Respectfully submitted,
/s/ Omar Gonzalez-Pagan
Omar Gonzalez-Pagan*
Hayley Gorenberg*
Jael Humphrey-Skomer*
LAMBDA LEGAL DEFENSE &
EDUCATION FUND, INC.
120 Wall Street, 19
th
Floor
New York, New York 10005-3904
T: (212) 809-8585 | F: (212) 809-0055
ogonzalez-pagan@lambdalegal.org
hgorenberg@lambdalegal.org
jhumphrey@lambdalegal.org

Gary W. Kubek*
Harriet M. Antczak*
Jing Kang*
DEBEVOISE & PLIMPTON LLP
919 Third Avenue
New York, NY 10022
T: (212) 909-6000 | F: (212) 909-6836
gwkubek@debevoise.com
hmantcza@debevoise.com
jkang@debevoise.com

Ryan M. Kusmin*
DEBEVOISE & PLIMPTON LLP
555 13th Street N.W.
Washington, DC 20004
T: (202) 383-8000 | F: (202) 383-8118
rmkusmin@debevoise.com

7
Should the Court grant Defendants Rule 56(d) motion, Plaintiffs request that the Court only hold Plaintiffs
motion for summary judgment in abeyance pending a decision on the motion to dismiss rather than denying the
motion for summary judgment and requiring refiling at a later date.
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Celina Romany-Siaca (USDCPR 121811)
Celina Romany Law Offices
268 Munoz Rivera Avenue, Suite 1500
San Juan, PR 00918
T: (787) 754-9304 | F: (787) 754-9324
bufetecelinaromany@gmail.com

Attorneys for Plaintiffs Maritza Lpez Avils
and Iris Delia Rivera Rivera; Jos A.
Torruellas Iglesias and Thomas J.
Robinson; Zulma Oliveras Vega and
Yolanda Arroyo Pizarro; Johanne Vlez
Garca and Faviola Melndez Rodrguez;
and Puerto Rico Para Tod@s.

AND

/s/ Ada M. Conde Vidal
Ada M. Conde Vidal (USDCPR 206209)
Conde Attorney at Law, PSC
P.O. Box 13268
San Juan, PR 00908-3268
T: (787) 721-0401 | F: (787) 977-8072
condelawpr@gmail.com

Attorney for Plaintiffs Ada Mercedes Conde
Vidal and Ivonne lvarez Vlez

* Admitted pro hac vice
Case 3:14-cv-01253-PG Document 54 Filed 10/15/14 Page 14 of 15


CERTIFICATE OF SERVICE
I, Omar Gonzalez-Pagan, an attorney, certify that on October 15, 2014, I served upon
counsel for all parties by electronically filing the foregoing with the Clerk of the Court using the
CM/ECF system.

/s/ Omar Gonzalez-Pagan



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