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1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO JOSE SUAREZ, HIS WIFE NILDA ACEVEDO AND SUAREZ-ACEVEDO CONJUGAL PARTNERSHIP; VINOS SELECCION INC.; ORLANDO CORDOVA;INDIVIDUALLY AND ON BEHALF AND ALL OTHER SIMILARLY SITUATED Plaintiffs v. CARIBBEAN PETROLEUM CORPORATION and MAPFRE INSURANCE COMPANY Defendants TO THE HONORABLE COURT: Civil No.: CLASS ACTION COMPLAINT Class Action Complaint Plaintiff Demands jury Trial COME NOW, Plaintiffs individually and for all others similarly situated, by their undersigned counsel, and hereby respectfully allege, state and request as follows: NATURE OF THE CASE 1. Plaintiffs bring this class action, pursuant to Rule 23 of the Federal Rules of Civil Procedure, on their own and on behalf of several classes similarly Class Member persons and entities that have sustained personal and/or economic injuries and damages Courthouse News Service as a result of the explosion of a large number of fuel storage tanks that occurred on October 23, 2009, at about 12:30 a.m. at the Caribbean Petroleum Company, Inc. ( CPC ) located near the San Juan, Puerto Rico suburbs of Bayamon, Cataño and Toa Baja, causing a severe blasts and a long lasting thick dark cloud of smoke and hazardous substances to spread into the air and cover large parts of the city and adjacent

2 municipalities, including the homes and business of the Plaintiffs and the class Members, and causing personal and/or economic injuries and damages to them. 2. Plaintiffs bring this action pursuant to recover compensatory damages, equitable relief, and attorneys fees. JURISDICTION AND VENUE 3. The Court has federal question jurisdiction under 28 U.S.C. 1332(d)(2), and the Class Action Fairness because the matter in controversy exceeds the sum or value of Five Million Dollars $5,000,000.00, exclusive of interest and costs, and it is a class action brought by the citizens of a State (Commonwealth) that is different from the State where at least one of the Defendants is incorporated or does business. 4. Venue is proper in this Court because Plaintiffs resides within, one or more of the Defendants regularly conducts business in, and because all the events or omissions giving rise to the claims asserted herein occurred in this judicial District. PARTIES 5. The Plaintiffs are Jose Suarez, his wife Nilda Acevedo and Suarez- Acevedo Conjugal Partnership; Vinos Seleccion Inc.; and Orlando Cordova. 6. Plaintiffs Jose Suarez, his wife Nilda Acevedo and Suarez-Acevedo Conjugal Partnership are residents and domiciliaries of Puente Blanco, Cataño, Puerto Rico. 7. The Plaintiff Vinos Seleccion Inc., is a corporation organized under the laws of the Commonwealth of Puerto Rico, and with principal place of business located at Luis Garraton Building, Lucchetti Industrial Zone, Road 28, Central Juanita End Avenue, Bayamon PR

3 8. Plaintiff Orlando Cordova is a resident and domiciliary of Puerto Rico, who works in the Guaynabo area. 9. The Defendants are: Caribbean Petroleum Corporation ( CPC ), a Delaware corporation doing business in this district, with its domestic principal place of business located Lucchetti Industrial Zone, Road No.28, k. 2.2, Bayamon, Puerto Rico 00961; MAPFRE Insurance Company ( MAPFRE ), a domestic insurer with its principal place of business at Tres Monjitas Industrial Zone, 297 Carlos Chardon Avenue, San Juan, Puerto Rico At the time of the explosion MAPFRE provided insurance coverage to CPC for the incident that forms the basis of this suit and is directly liable to Plaintiffs and the Class Members for their damages. FACTUAL ALLEGATIONS 11. On October 23, 2009, at approximately 12:30 a.m., an explosion occurred at the CPC, causing a large number of fuel storage tanks containing gasoline, diesel and petroleum to explode causing an enormous fire, thereby releasing toxic gases. 12. The fire has caused an enormous smoke plume full of hazardous contaminants to which thousands of residents have been exposed. The blasts also caused severe property damage to the residents and the fire continuous to cause serious bodily harm to the residents of the above mentioned municipalities. 13. The fire is expected to cause more tanks with volatile fuels, such as airplane fuel to explode due to the gross negligence of CPC. The fire continued to run until October 25, 2009, but the hazardous smoke and hazardous substances released to 3

4 the air continues and is expected to encompass a larger area of Puerto Rico causing severe physical and emotional damages to thousands of residents. 14. The smoke is extremely toxic, said Jose Bartolomei, a state epidemiologist who monitors asthma. An asthmatic patient will definitely hyper-react to this. 15. Adding to the danger is the presence of invisible gases such as carbon monoxide and sulfur, said Luis Antonio Ocasio, spokesman for the island s Environmental Quality Board. 16. At the time the explosions occurred CPC operated the facility. 17. The Gulf Oil Facility was at all times under the control of CPC. 18. The explosion blasts registered 2.8 in the Richter scale and was felt in Culebra, Vieques, and even the Virgin Islands. 19. As a result of the prevailing winds, toxic gases from the burned fuel have spread from the site of the explosion to several areas of San Juan and adjacent municipalities, including, without limitation, Cataño, Levittown, Toa Baja and Bayamon, and Plaintiffs and the Class Members have been exposed thereto. 20. As a result of the explosion, toxic gases from the burning of fuel and other chemicals and substances stored in approximately thirty storage tanks were released into the atmosphere. As a result of the explosion, the toxic gases have caused serious and dangerous environmental contamination. 21. Plaintiffs Jose Suarez and his wife Nilda Acevedo were at their home at the time of the explosion. At the time of the explosion, Plaintiffs heard and felt the explosion all over their house. The explosion blasts was so loud and strong that it caused 4

5 the house property walls, windows and doors to tremble, windows and doors to open or shattered. 22. As a direct result of the explosion blasts, the Suarez-Acevedo Conjugal Partnership s property sustained structural damages, and windows, doors and other house furniture and/or equipment were shattered, broken and/or damaged. As a direct result thereof, the Suarez-Acevedo Conjugal Partnership has sustained economic damages. 23. Moreover, as a direct result of the explosion blasts, Plaintiffs Jose Suarez and Nilda Acevedo experienced and felt how their property sustained structural damages, and windows, doors and other house furniture and/or equipment were shattered, broken and/or damaged. Unknown of what had caused the blasts, Plaintiffs experienced a life threatening situation that lasted for an extended period of time during they felt terrorized while they analyzed the probable causes of the explosion, and until they could learn that the blasts had been caused by the blasts at the CPC fuel storage tanks. 24. Thereafter, Plaintiffs Jose Suarez and Nilda Acevedo continued to experience a life threatening situation for several days to the continuing tanks explosions, and the threats caused to their health and property by the toxic fumes that emanated from the same. 25. As a result thereof, the Plaintiffs Jose Suarez and Nilda Acevedo have sustained continuous states of high anxiety, and fears of imminent injury to health and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their property. 26. Due to the great magnitude of the explosion blasts, there are hundreds of thousands of similarly situated individuals that have sustained: economic losses cause by 5

6 the physical damages to their houses structures, windows, doors and other house furniture and/or equipment; and states of high anxiety, and fears of imminent injury to health and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. 27. Plaintiffs Jose Suarez, Nilda Acevedo and the Suarez-Acevedo Conjugal Partnership bring this action on their own and on behalf of a Class consisting of: all other similarly situated persons or individuals that have sustained economic losses cause by the physical damages to their houses structures, windows, doors and other house furniture and/or equipment; and/or all other similarly situated persons or individuals that had to be evacuated from their homes; and/or all other similarly situated persons or individuals that have sustained states of high anxiety, and fears of imminent injury to health and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. 28. As a direct result of the explosion, Plaintiff Vinos Seleccion Inc. s business operations have come to a halt due to the lack of access to its business offices, and the lack of electric power within the Offices Building. As a direct result, Plaintiff Vinos Seleccion Inc., has sustained economic losses due to its business interruption. 29. Due to the great extension of the damages caused by the explosion there are hundreds of other similarly situated businesses that have sustained economic losses due to their business interruption. 30. Plaintiff Vinos Seleccion Inc., brings this action on its own and on behalf of a Class consisting of all other similarly situated businesses that have sustained economic losses due to their businesses interruption. 6

7 31. As a result of the explosion, Plaintiff Orlando Cordova has inhaled toxic fumes, which has caused him to sustain respiratory illnesses, all which have caused him to suffer severe physical injuries and damages. 32. Due to the great extension of the toxic fumes, there are hundreds of thousands of other similarly situated individuals that have sustained respiratory illnesses, all which have caused them to suffer severe physical injuries and damages. 33. Plaintiff Orlando Cordova brings this action on his own and on behalf of a Class consisting of all other similarly situated individuals that have sustained respiratory illnesses due to their exposure to the toxic fumes, which have caused them to suffer physical injuries and damages. 34. There are many other potential effects from the explosion that have not yet come known, and Plaintiffs will amend this Complaint to include them once additional information becomes available. CLASS DEFINITION 35. Plaintiffs brings this action pursuant to Federal Rules of Civil Procedure Rule 23 on behalf of themselves, and all others similarly situated, including the Classes and/or Subclasses defined as follows: A. Plaintiffs Jose Suarez, Nilda Acevedo and the Suarez-Acevedo Conjugal Partnership bring this action on their own and on behalf of a Class consisting of all other similarly situated persons or individuals who reside in the Bayamon, Puerto Rico, and adjacent municipalities, including Cataño, Levittown, and Toa Baja, and that have: either sustained economic losses cause by the physical 7

8 damages to their houses structures, windows, doors and other house furniture and/or equipment; and/or had to be evacuated from their homes; and/or sustained states of high anxiety, and fears of imminent injury to health and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. B. Plaintiff Vinos Seleccion Inc., brings this action on its own and on behalf of a Class consisting of all other similarly situated which or whom, have their business locations or offices in are the Bayamon, Puerto Rico, and adjacent municipalities, including Cataño, Levittown, and Toa Baja, which have suffered any economic damages and/or losses from the explosion of the Gulf Oil Facility on October 23, C. Plaintiff Orlando Cordova brings this action on his own and on behalf of a Class consisting of all other similarly situated individuals who worked or reside in the Bayamon, Puerto Rico, and adjacent municipalities, including Cataño, Levittown, and Toa Baja, that have sustained respiratory illnesses due to their exposure to the toxic fumes, which have caused them to suffer physical injuries and damages. 36. Excluded from the Class, Classes and/or Subclasses are: Defendants officers and directors; any judge or judicial official assigned to this matter and his or her 8

9 immediate family; and any legal representative, successor, or assign of any excluded persons or entities. 37. The subject of the Class, Classes and/or Subclasses definition and certification briefing will be filed as soon as practical. CLASS ACTION ALLEGATIONS Numerosity of the Class 38. The explosion blasts registered 2.8 in the Richter scale and was felt in Culebra, Vieques, and even the Virgin Islands. As a result of the prevailing winds, toxic gases from the burned fuel have spread from the site of the explosion to several areas of San Juan and adjacent municipalities, including, without limitation, Cataño, Levittown, Toa Baja and Bayamon, and Plaintiffs and the Class Members have been exposed thereto. 39. Due to the magnitude and extension of the damages caused by both the explosion blasts and its toxic fumes there are: hundreds of other similarly situated businesses that such as Plaintiff Vinos Seleccion Inc. have sustained economic losses due to their business interruption; hundreds of thousands of other similarly situated individuals that such as Plaintiff Orlando Cordova have sustained respiratory illnesses, all which have caused them to suffer severe physical injuries and damages; and hundreds of thousands of similarly situated individuals that such as Plaintiffs Jose Suarez, Nilda Acevedo and the Suarez-Acevedo Conjugal Partnership have sustained economic losses cause by the physical damages to their houses structures, windows, doors and other house furniture and/or equipment; and the similarly situated individuals that have suffered house evacuations, and/or states of high anxiety, and fears of imminent injury to health 9

10 and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. 40. Therefore, the Members of the proposed Class, Classes and/or Subclasses are so numerous that joinder is impractical. The disposition of these claims through this class action will be more efficient and will benefit the parties and the Court. Predominance of Common Questions of Fact and Law 41. A well-defined community of interest in the questions of law and fact common to the Class, Classes and/or Subclasses predominate over questions affecting only individual Class Members including, but not limited to, the following: A. Defendant s fault and/or negligent conduct that caused and/or contributed to the explosion and release of toxic gases. B. The economic damages caused to the Plaintiffs and the Class Members as a result of the explosion blasts, fires and release of toxic gases. C. The physical, mental and/or emotional damages caused to the Plaintiffs and the Class Members as a result of the explosion blasts, fires and release of toxic gases. D. The adequate causes of the explosion blasts, fires and release of toxic gases. E. The environmental damages caused by the explosion blasts, fires band release of toxic gases. F. The duties breached by the Defendant, which would have the explosion blasts, fires and release of toxic gases. 10

11 G. The Plaintiffs and the Class Members entitlement to recover compensatory, and/or other damages as a result of Defendants unlawful conduct. H. The proper mechanism for assessing and awarding damages and administering other relief to the Class Members, including relief to monitor the threat of future harm to Class Members. I. Defendant s defective design, manufacture, and/or maintenance of the fuel tanks and of their security mechanisms. J. The safety defects in the Defendant s fuel tanks and their security mechanisms that constitute a design defect for purposes of strict products liability. Typicality 42. Having been victims of the explosion blasts, fire and toxic fumes, Plaintiffs and the Members of the Class, Classes and/or Subclasses have suffered similar harm arising from Defendant s fault and negligent conduct. Plaintiffs damages are typical of the Class Members whom they seek to represent. Adequacy of Representation 43. Plaintiffs are adequate representatives of the Plaintiff Class, Classes and/or Subclasses because they are Members of the Plaintiff Class and their interests do not conflict with the interests of the Members of the Plaintiff Class they seek to represent. Further, Plaintiffs are represented by experienced and able counsels who have litigated numerous other mass torts and class actions, and they intend to prosecute this action 11

12 vigorously for the benefit of the entire Plaintiff Class. Plaintiffs and their counsel will fairly and adequately protect the interests of the Members of the Plaintiff Class. Superiority 44. A class action is superior to other available methods for the efficient adjudication of this litigation since individual litigation of each Class Members claims is impracticable. It would be unduly burdensome to the courts in which individual litigations would proceed. Further, individual litigations present a potential for inconsistent and/or contradictory judgments and further increases the delay and expense to all parties and the courts. 45. By contrast, the class action device presents far fewer management difficulties and provides the benefit of a single adjudication, economies of scale, and comprehensive supervision by a single court. 46. Additionally, notice of the pendency and/or resolution of this class action can be provided to Class Members by the Local News Media. 47. This action is also properly certified under the provisions of Federal Rule of Civil Procedure Rule 23 because: A. The prosecution of separate actions by individual Members of the Class would create a risk of inconsistency of varying adjudications with respect to individual Class Members, thus establishing incompatible standards of conduct for Defendant s financing activities; and B. Defendants have acted or refused to act on grounds generally applicable to the entire Class, thereby making appropriate final 12

13 declaratory and injunctive relief with respect to the Class as a whole appropriate. FIRST CAUSE OF ACTION (FAULT AND/OR NEGLIGENCE) 48. Plaintiffs repeat, reiterate and re-allege each and every allegation of this Complaint in each of the foregoing paragraphs inclusive; with the same force and effect as if more fully set forth herein. 49. Upon information and belief, Plaintiffs aver that the explosion and resultant toxic release was caused by the negligence and fault of the CPC in the following non-exclusive particulars: A. Failing to properly operate the Gulf Oil Facility so as to prevent the explosion and failing to prevent actions that either caused or contributed to the explosion; B. Operating the Gulf Oil Facility in such a manner that allowed actions that caused the explosion, including failing to provide adequate security; C. Failing to properly inspect the Gulf facility to assure that the tanks, equipment and personnel were fit for their intended purpose; D. Acting in a careless and negligent manner without due regard for the safety of others; E. Failing to promulgate, implement and enforce rules and regulations pertaining to the safe operations of the Gulf Oil Facility at the time of the explosion which, if they had been so promulgated, implemented and enforced, would have averted said explosion; 13

14 F. Operating the Gulf Oil Facility with untrained and unlicensed personnel; G. Inadequate and negligent training and hiring; H. Failing to take appropriate action to avoid or mitigate the explosion; I. Negligent implementation of policies and procedures to safely store the fuel and failing to follow regulations for fuel storage; J. Employing untrained or poorly trained employees and failing to properly train their employees; K. Failing to ascertain that the tanks and equipment were free from defects and/or in proper working order; L. Failure to timely warn; M. Failure to timely bring the release under control; N. Failure to provide appropriate accident prevent equipment; O. Failure to observe and read gauges; P. Failure to react to danger signs; Q. Failure to take adequate security measures to prevent foreseeable third party intentional conduct that could cause the fuel tanks explosions; R. And, any such other acts of negligence and omissions as will be shown at the trial of this matter; all of which acts are in violation of the laws of Puerto Rico and the United States of America. 14

15 50. In addition, and in the alternative, the explosion and resultant toxic release was caused by defective equipment, which was in the care, custody, and control of the Defendant. Defendant knew or should have known of these defects and Defendant is therefore, liable for them. 51. Plaintiffs and Class Members damages claimed herein were adequately caused by the afore stated Defendant s fault and/or negligence. 52. Therefore, Plaintiffs and Class Members are entitled to receive monetary compensation for: A. The economic losses sustained by the physical damages caused to their houses structures, windows, doors and other house furniture and/or equipment; and/or had to be evacuated from their homes; and/or sustained states of high anxiety, and fears of imminent injury to health and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. B. Their businesses interruption of operations, economic losses and any other economic damages and/or losses caused by the explosion blasts, fire and toxic gases. C. The respiratory illnesses sustained due to the exposure to the toxic fumes, which have caused them to suffer physical injuries and damages. 53. The Plaintiffs and Class Members are entitled to receive adequate monetary compensation for these damages. In the aggregate the monetary amount of 15

16 Plaintiffs and Class Members to be proven at trial is reasonable estimated to be in no less than HUNDREDS OF MILLIONS OF DOLLARS. SECOND CAUSE OF ACTION (TRESPASS) 54. Plaintiffs repeat, reiterate and re-allege each and every allegation of this Complaint in each of the foregoing paragraphs inclusive; with the same force and effect as if more fully set forth herein. 55. Defendant s negligent acts and omissions have resulted and continue to result in the direct and physical invasion of Plaintiffs and Class Members properties by toxic and/or harmful substances contaminating their persons, properties and the surrounding surface and subsurface areas. 56. As a direct and proximate result of the acts and omissions of Defendant, Plaintiffs and Class Members have suffered losses in the form of, but not limited to, personal injury, emotional distress, loss of income, the creation of conditions that harmful to human health and the environment, and loss of the beneficial use, enjoyment, and exclusive possession of their property. 57. Plaintiffs and Class Members damages claimed herein were adequately caused by the afore stated Defendant s fault and/or negligence. 58. Therefore, Plaintiffs and Class Members are entitled to receive monetary compensation for: A. The economic losses sustained by the physical damages caused to their houses structures, windows, doors and other house furniture and/or equipment; and/or had to be evacuated from their homes; and/or sustained states of high anxiety, and fears of imminent 16

17 injury to health and life, all which has caused them to suffer, severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. B. Their businesses interruption of operations, economic losses and any other economic damages and/or losses caused by the explosion blasts, fire and toxic gases. C. The respiratory illnesses sustained due to the exposure to the toxic fumes, which have caused them to suffer physical injuries and damages. 59. The Plaintiffs and Class Members are entitled to receive adequate monetary compensation for these damages. In the aggregate the monetary amount of Plaintiffs and Class Members to be proven at trial is reasonable estimated to be in no less than HUNDREDS OF MILLIONS OF DOLLARS. THIRD CAUSE OF ACTION (NUISANCE) 60. Plaintiffs repeat, reiterate and re-allege each and every allegation of this Complaint in each of the foregoing paragraphs inclusive, with the same force and effect as if more fully set forth herein. 61. Defendant s acts and omissions with respect to the release of toxic an/or harmful substance have caused and continue to cause a material, substantial, and unreasonable interference with Plaintiffs and other Class Members use and enjoyment of their properties and has materially diminished and continues to diminish the value of such properties. 17

18 62. Defendant s material, substantial, and unreasonable interference with the use and enjoyment of Plaintiffs and other Class Members properties and continuing material, substantial and unreasonable interference with such use and enjoyment constitutes a continuing private nuisance. 63. Defendants creation and continuing creation of private nuisance proximately caused and continues to proximately cause damage to Plaintiffs and other Class Members in the form of personal injury, emotional distress, and property damage of a type special and common to Members of the Class. 64. As a direct and proximate result of the acts and omissions of Defendant, Plaintiffs and Class Members have suffered losses in the form of, but not limited to, personal injury, emotional distress, loss of income the creation of conditions that are harmful to human health and the environment, and loss of the beneficial use, enjoyment, and exclusive possession of their property. 65. Plaintiffs and Class Members damages claimed herein were adequately caused by the afore stated Defendant s fault and/or negligence. 66. Therefore, Plaintiffs and Class Members are entitled to receive monetary compensation for: A. The economic losses sustained by the physical damages caused to their houses structures, windows, doors and other house furniture and/or equipment; and/or had to be evacuated from their homes; and/or sustained states of high anxiety, and fears of imminent injury to health and life, all which has caused them to suffer, 18

19 severe mental and emotional, pains, suffering, anguish and distress, and a loss of their capacity to enjoy their properties. B. Their businesses interruption of operations, economic losses and any other economic damages and/or losses caused by the explosion blasts, fire and toxic gases. C. The respiratory illnesses sustained due to the exposure to the toxic fumes, which have caused them to suffer physical injuries and damages. 67. The Plaintiffs and Class Members are entitled to receive adequate monetary compensation for these damages. In the aggregate the monetary amount of Plaintiffs and Class Members to be proven at trial is reasonable estimated to be in no less than HUNDREDS OF MILLIONS OF DOLLARS. FOURTH CAUSE OF ACTION (MEDICAL MONITORING) 67. Plaintiffs repeat, reiterate and re-allege each and every allegation of this Complaint in each of the foregoing paragraphs inclusive, with the same force and effect as if more fully set forth herein. 68. As a direct result of Defendant s actions and omissions, Plaintiffs and Class Members have sustained and are at serious risk of continuing to sustain severe respiratory and other health illnesses due to their exposure to the toxic fumes and substances released into the air by the explosion. 69. These risks require frequent diagnostic medical examinations and ongoing treatment to prevent the high likelihood of future injury if left untreated or unmonitored. 19

20 70. Accordingly, the Defendant should be required to cover all the costs related to the medical monitoring of the Plaintiffs and Class Member health. October, PRAYER FOR RELIEF WHEREFORE, Plaintiffs request and demand against Defendants as follows: A. That an Order is entered certifying the Class, Classes and/or Subclasses for the purpose of going forward with any one or all of the causes of action alleged herein. B. That an Order entered appointing Plaintiffs as Class Representatives; and appointing undersigned counsel as counsel for the Class, Classes and/or Subclasses. C. Economic and compensatory damages in amounts reasonably estimated in no less than HUNDREDS OF MILLIONS OF DOLLARS, the exact amount to be determined at trial, but not less than the FIVE MILLION DOLLARS $5,000, required by the Class Action Fairness Act which establishes this Court s jurisdiction to hear this case. D. Attorney s fees due to Defendants obstinate conduct in the event they deny liability and/or for damages. E. Pre-judgment and post-judgment interest at the maximum rate allowable by law; and costs of the litigation. F. Such other and further relief available under all applicable state and federal laws and any relief the Court deems just and appropriate, including medical monitoring pursuant to Court order. G. A trial by jury as to all Defendants. H. An award of monetary damages in an amount to be determined at trial. RESPECTFULLY SUBMITTED in San Juan, Puerto Rico, this 26th day of 20

21 s/eric M. QUETGLAS-JORDAN USDCPR # JOSE F. QUETGLAS JORDAN USDCPR # QUETGLAS LAW OFFICE P.O. Box San Juan, PR, Tel.: Fax : Quetglaslaw@hotmail.com; Quetglaslaw@gmail.com; Kirk Wood ekirkwood1@cs.com Wood Law Firm, LLC st Avenue South, Suite A Birmingham, Alabama Tel: (205) ATTORNES FOR PLAINTIFFS 21