Case 3:06-cv-01645-JAF -JP Document 634

Filed 07/26/11 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO HERBERT W. BROWN III, et al. Plaintiffs v. COLEGIO DE ABOGADOS DE PUERTO RICO Defendant : Civil No. 06-1645(JP)

MOTION INFORMING PARTIAL COMPLIANCE WITH PARTIES MEMORANDUM OF UNDERSTANDING AND DEPOSIT OF FUNDS WITH THE CLERK OF THE COURT

TO THE COURT: COLEGIO DE ABOGADOS, by its undersigned counsel, hereby informs the Court: 1. Pursuant to the Court of Appeals Court Assisted Mediation Program, the parties have reached a Memorandum of Understanding (MOU) (Exhibit 1) pursuant to which Plaintiffs respectfully request the Court take notice of the following acts in compliance therewith on this date: 2. Pursuant to Paragraph 1 of that Memorandum, Colegio de Abogados has filed and Plaintiffs have registered their consent to dismissal of all appeals filed by Colegio in this case. 3. In partial satisfaction of the judgment, pursuant to Paragraph 6 of the MOU, Colegio is depositing the check in the amount of one million dollars ($1,000,000.00), a copy of which accompanies this Motion, representing partial payment of the Judgment to Plaintiffs. See Exhibit 2. 4. As stipulated in Paragraphs 2, 4 and 5 of the Memorandum, in total satisfaction of all

Page 1 of 2

Case 3:06-cv-01645-JAF -JP Document 634

Filed 07/26/11 Page 2 of 2

obligations on the part of Colegio relating to attorneys fees, costs and expenses, Colegio is delivering on this date the remaining checks, copies of which accompany this motion, to the law offices of Indiano & Williams, C. Del Parque #207, 3rd floor. 5. Prior to todays date, the parties agreed that deposit and delivery of these checks on this date would constitute full compliance with these obligations, as the date originally contemplated, July 24, was a Sunday and Monday, July 25, was a holiday. WHEREFORE, it is requested that notice of the Colegios compliance be taken, and the check in the amount of one million dollars be deposited for transmittal to Rust.

RESPECTFULLY SUBMITTED: On July 26, 2011 CERTIFICATION I hereby certify that a copy of the foregoing was electronically filed with the Courts electronic case filing system, which will automatically serve a copy upon the parties of record /s LINDA BACKIEL C. Sierra Morena #267 PMB 597 San Juan, Puerto Rico 00926-5583 787-751-4941 tel & Fax ollb@coqui.net

Page 2 of 2

Case 3:06-cv-01645-JAF -JP Document 634-1

Filed 07/26/11 Page 1 of 5

Case 3:06-cv-01645-JAF -JP Document 634-1

Filed 07/26/11 Page 2 of 5

Case 3:06-cv-01645-JAF -JP Document 634-1

Filed 07/26/11 Page 3 of 5

Case 3:06-cv-01645-JAF -JP Document 634-1

Filed 07/26/11 Page 4 of 5

Case 3:06-cv-01645-JAF -JP Document 634-1

Filed 07/26/11 Page 5 of 5

Case 3:06-cv-01645-JAF -JP Document 634-2

Filed 07/26/11 Page 1 of 2

Case 3:06-cv-01645-JAF -JP Document 634-2

Filed 07/26/11 Page 2 of 2