Estimated Hearing Date: November 2, 2022 at 9:30 a.m. AST

Objection Deadline: October 24, 2022 at 4:00 p.m. AST

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

PROMESA

Title III

 No. 17-BK-03283 (LTS) 

(Jointly Administered)

SUMMARY COVER SHEET FOR FIFTEENTH INTERIM APPLICATION OF

LUSKIN, STERN & EISLER LLP, AS SPECIAL COUNSEL TO THE

FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO 

FOR PROFESSIONAL COMPENSATION AND REIMBURSEMENT OF EXPENSES,

FOR THE PERIOD FROM FEBRUARY 1, 2022 THROUGH MARCH 15, 2022 

ALL FEES AND SERVICES IN THIS INTERIM APPLICATION

WERE INCURRED OUTSIDE OF PUERTO RICO

1 The Debtors in these jointly-administered Title III Cases, along with each Debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor’s federal 

tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 

3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17 BK 

3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation Authority 

(“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) Last Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico 

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 

3747).

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.

1

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2 

Summary Sheet

Name of Applicant: Luskin, Stern & Eisler LLP (“LS&E”)

Authorized to Provide Professional Services as: Special Counsel to The Financial Oversight 

and Management Board for Puerto Rico 

Name of Client: The Financial Oversight and 

Management Board for Puerto Rico 

Petition Date: May 3, 20172

Retention Date: October 4, 2016 

Compensation Period: February 1, 2022 to March 15, 2022 

(the “Compensation Period”)

Total Compensation Sought excluding 

the Fifteenth Interim Gross-Up Amount: $10,096.50 

Fourteenth Interim Gross-Up Amount:3 $13,521.60 

Expense Reimbursement Sought: $0.00 

Total Compensation and Expense 

Reimbursement Sought including 

Fifteenth Interim Gross-Up Amount: 

$23,618.10 

2 The petition date for the Commonwealth under Title III was May 3, 2017. The petition date for COFINA under 

Title III was May 5, 2017. The petition date for ERS and HTA under Title III was May 21, 2017. The petition date 

for PREPA under Title III was July 2, 2017.

3 LS&E requests approval now, as part of its fees and expenses, of the amount required to gross up the taxes 

withheld during the fourteenth Interim Fee Period (as defined in this Application) (the “Fifteenth Interim Gross-Up 

Amount”) on account of any tax withholding pursuant to Act 257 amending the Puerto Rico Internal Revenue Code 

of 2011 (the “PR Tax Code”) and any provisions of the PR Tax Code (the “Tax Withholding”). LS&E has not 

previously sought interim allowance of the Fifteenth Interim Gross-Up Amount (but has always reserved the right to 

do so). LS&E will only request payment of the Fifteenth Interim Gross-Up Amount from the Debtors if it is 

determined that the Tax Withholding does not result in federal and state tax credits offsetting the Fifteenth Interim 

Gross-Up Amount.

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3 

Prior Applications Filed: First Interim Application [ECF No. 2077]; 

Second Interim Application [ECF No. 2729]; 

Third Interim Application [ECF No. 3530]; 

Fourth Interim Application [ECF No. 4336]; 

Fifth Interim Application [ECF No. 5778]; 

Sixth Interim Application [ECF No. 7968]; 

Seventh Interim Application [ECF No. 9199]; 

Eighth Interim Application [ECF No. 12356]; 

Ninth Interim Application [ECF No. 13714]; 

Tenth Interim Application [ECF No. 15147]; 

Eleventh Interim Application [ECF No. 16080]; 

Twelfth Interim Application [ECF No. 17396]; 

Thirteenth Interim Application [ECF No. 19215]; 

Fourteenth Interim Application [ECF No. 21125] 

This is an: ___ monthly X interim ___ final application

This is Luskin, Stern & Eisler LLP’s fifteenth interim application in these cases (this “Application”). 

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Additional Information required pursuant to the United States Trustee Guidelines for Reviewing 

Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by 

Attorneys in Larger Chapter 11 Cases effective as of November 1, 2013:

Total Compensation Approved by Interim Order to 

Date: $[1,522,940.24]

Total Expense Reimbursement Approved by Interim 

Order to Date:

$7,014.97

Total Allowed Compensation Paid to Date: $[1,326,014.14]

Total Allowed Expense Reimbursement Paid to Date: $7,014.97

Total Compensation Sought in this Application Already 

Paid Pursuant to Monthly Compensation Statements but 

not yet Allowed:

$0.00

Total Expense Reimbursement Sought in this 

Application Already Paid Pursuant to Monthly 

Compensation Statements but not yet Allowed:

$0.00

Blended Hourly Rate in this Application for all 

Attorneys:

$892.19

Blended Hourly Rate in this Application for all 

Timekeepers:

$400.65

Number of Professionals in this Application: 3

Number of Professionals Billing Fewer than 15 hours in 

this Application:

2

Difference Between Fees Budgeted and Compensation 

Requested for this Period:

N/A4

Rate Increases Since Date of Retention: 7

Disclosure of Compensation Sought in this Application

Using Rates Disclosed at Retention:

$8,992.50

4 Because LS&E performs work for the Oversight Board on an ad hoc basis, the amount of time it bills in any given 

month or Compensation Period can fluctuate substantially. Accordingly, there have been significant variations in 

budgeted and actual fees billed. Based on discussions with the Fee Examiner (as defined in this Application), LS&E 

is no longer subject to the budgeting requirement with respect to the work it performs on an ad hoc basis. In the 

event LS&E begins project assignments with more predictable work, LS&E will submit monthly budgets for such 

work to the Fee Examiner.

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Summary of Prior Interim Fee Applications Filed

File Date/

ECF No.

Period Covered Fees 

Requested

Expenses 

Requested

Fees 

Approved

Expenses 

Approved Fees Paid Expenses Paid

12/15/2017

[No. 2077]

May 3, 2017 to 

September 30, 2017 $324,975.50 $2,172.59 $308,347.07 $2,100.64 $308,347.07 $2,100.64

3/19/2018

[No. 2729]

October 1, 2017 to 

January 31, 2018 $91,237.50 $1,329.64 $88,869.67 $1,329.64 $88,869.67 $1,329.64

7/16/2018

[No. 3530]

February 1, 2018 to 

May 31, 208 $125,126.00 $471.42 $123,126.00 $471.42 $123,126.00 $471.42

11/19/2019

[No. 4336]

June 1, 2018 to 

September 30, 2018 $74,708.00 $313.63 $71,708.00 $313.63 $71,708.00 $313.63

3/18/2019

[No. 5778]

October 1, 2018 to 

January 31, 2019 $547,219.50 $1,314.13 $546,614.00 $1,311.51 $464,624.575 $1,311.51

7/15/2019

[No. 7968]

February 1, 2019 to 

May 31, 2019 $152,665.50 $900.41 $152,165.50 $743.70 $106,354.826 $743.70

11/15/2019

[No. 9199]

June 1, 2019 to 

September 30, 2019 $54,602.00 $0.00 $54,602.00 $0.00 $38,767.417 $0.00

3/16/2020

[No. 12356]

October 1, 2019 to 

January 31, 2020 $30,633.00 $66.91 $30,633.00 $66.91 $19,719.498 $66.91

7/17/2020

[No. 13714]

February 1, 2020 to 

May 31, 2020 $54,879.00 $5.52 $54,879.00 $5.52 $38,140.919 $5.52

11/16/2020

[No. 15147]

June 1, 2020 to 

September 30, 2020 $35,231.00 $672.00 $35,903.00 $672.00 $24,485.5410 $672.00

3/16/2021

[No. 16080]

October 1, 2020 to 

January 31, 2021 $11,909.00 $0.00 $11,795.00 $0.00 $8,342.5311 $0.00

7/16/2021

[No. 17396]

February 1, 2021 to 

May 31, 2021 $29,630.00 $0.00 $29,630.00 $0.00 $20,592.8412 $0.00

11/15/2021

[No. 19215]

June 1, 2021 to 

September 30, 2021 $15,340.00 $0.00 $15,340.00 $0.00 $10,806.3013 $0.00

6/7/2022

[No. 21125]

October 1, 2021 to 

January 31, 2022 $30,811.50 $0.00 $0.00 $19,272.5914 $0.00

TOTAL $1,589,064.00 $7,246.25 $1,522,940.24 $7,014.97 $1,352,301.70 $7,014.97

5 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $81,989.43.

6 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $45,810.68.

7 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $15,834.59.

8 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $7,850.21.

9 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $16,738.09.

10 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $10,745.46.

11 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $3,452.47.

12 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $9,037.16.

13 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $4,533.70.

14 LS&E understands the amount paid is net of Tax Withholding in the aggregate amount of $8,457.76. 

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Summary of Prior Monthly Fee Statements for the Compensation Period

from February 1, 2022 through March 15, 202215

Date Period Covered Total Fees

Fees 

Requested 

(90%)

Holdback 

(10%) 

Expenses 

Requested Fees Paid Expenses Paid

PR Tax 

Withheld 

4/19/2022 February 1, 2022 to 

March 15, 2022 $10,096.50 $9,086.85 $1,009.65 $0.00 $0.00 $0.00 $0.00

TOTAL $10,096.50 $9,086.85 $1,009.65 $0.00 $0.00 $0.00 $0.00

15 The fees requested in LS&E’s monthly fee statements during this Compensation Period reflect voluntary 

reductions in the aggregate amount of $1,228.50. Such reductions are reflected in the net amounts sought in this 

Application.

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Estimated Hearing Date: November 2, 2022 at 9:30 a.m. AST

Objection Deadline: October 24, 2022 at 4:00 p.m. AST

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

PROMESA

Title III

 No. 17-BK-03283 (LTS) 

(Jointly Administered)

FIFTEENTH INTERIM APPLICATION OF

LUSKIN, STERN & EISLER LLP, AS SPECIAL COUNSEL TO THE 

FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO,

FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES 

FOR THE PERIOD FROM FEBRUARY 1, 2022 THROUGH MARCH 15, 2022 

TO THE HONORABLE LAURA TAYLOR SWAIN

UNITED STATES DISTRICT COURT JUDGE:

Luskin, Stern & Eisler LLP (“LS&E”), special counsel to the Financial Oversight 

and Management Board for Puerto Rico (the “Oversight Board”) as representative of the 

Commonwealth of Puerto Rico, the Puerto Rico Sales Tax Financing Corporation, the Puerto 

Rico Highways and Transportation Authority, the Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico, and the Puerto Rico Electric Power Authority 

(collectively, the “Debtors”) in the above-captioned title III cases (the “Title III Cases”) pursuant 

1 The Debtors in these jointly-administered Title III Cases, along with each Debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor’s federal 

tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 

3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17 BK 

3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation Authority 

(“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) Last Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico 

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 

3747).

In re

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

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to section 315(b) of the Puerto Rico Oversight, Management, and Economic Stability Act

(“PROMESA”),

2

 hereby submits this fifteenth interim fee application (the “Fifteenth Interim

Application” or “Application”),3 pursuant to PROMESA sections 316 and 317, Rule 2016 of the 

Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”),4 Rule 2016-1 of the Local 

Bankruptcy Rules for the United States Bankruptcy Court for the District of Puerto Rico (the 

“Local Bankruptcy Rules”), Appendix B of the United States Trustee Guidelines for Reviewing 

Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by 

Attorneys in Large Chapter 11 Cases effective as of November 1, 2013 (the “U.S. Trustee 

Guidelines,” and together with the aforementioned statutes, rules and guidelines, the 

“Guidelines”), and in accordance with the Third Amended Order Setting Procedures for Interim 

Compensation and Reimbursement of Expenses of Professionals entered by this Court on 

April 12, 2022 [ECF No. 20546] (as amended, the “Interim Compensation Order”), seeking entry 

of an order granting (I)(a) the allowance of interim compensation in the aggregate amount of 

$10,096.50 in fees for reasonable and necessary professional services rendered and 

(b) reimbursement of actual and necessary expenses in the aggregate amount of $0.00 incurred 

during the period commencing February 1, 2022 through and including March 15, 2022 

(the “Compensation Period”), and (II) the allowance of the amount required to gross up the taxes 

withheld on account of the tax withholding pursuant the Puerto Rico Internal Revenue Code of 

2011 (the “Tax Withholding”) in the fourteenth Interim Fee Period (as defined herein) in the 

2 PROMESA has been codified in 48 U.S.C. §§ 2101-2241.

3 The Application solely pertains to fees and expenses incurred with respect to the Debtors’ Title III Cases and does 

not address fees or expenses incurred with respect to other services performed for the Oversight Board outside the 

Title III process.

4 The Bankruptcy Rules are made applicable to the Debtors’ Title III Cases pursuant to PROMESA section 310.

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aggregate amount of $13,521.60 (the “Fifteenth Interim Gross-Up Amount”).

5

 In support of this 

Application, LS&E respectfully states the following:

Jurisdiction and Venue

1. The Court has subject matter jurisdiction to consider and determine this 

Second Interim Application pursuant to PROMESA section 306(a). Venue is proper before this 

Court pursuant to PROMESA section 307(a). The statutory predicates for the relief requested 

herein are PROMESA sections 316 and 317, Bankruptcy Rule 2016 and Local Rule 2016-1. 

2. This Application has been prepared in accordance with the Guidelines and 

the Interim Compensation Order. Attached hereto as Exhibit A is a certification regarding 

compliance with the Local Guidelines.

Background and Case Status 

A. The Debtors’ Title III Cases

3. On June 30, 2016, the Oversight Board was established under PROMESA 

section 101(b). 

4. On August 31, 2016, President Obama appointed the Oversight Board’s 

seven voting members. 

5. Pursuant to PROMESA section 315, “[t]he Oversight Board in a case 

under this title is the representative of the debtor[s]” and “may take any action necessary on 

behalf of the debtor[s] to prosecute the case[s] of the debtor[s], including filing a petition under 

section 304 of [PROMESA] . . . or otherwise generally submitting filings in relation to the 

case[s] with the court.”

5

 LS&E has not previously sought interim allowance of the Fifteenth Interim Gross-Up Amount (but has always 

reserved the right to do so). LS&E will only request payment of the Fifteenth Interim Gross-Up Amount from the 

Debtors if it is determined that the Tax Withholding does not result in federal and state tax credits offsetting the 

Fifteenth Interim Gross-Up Amount.

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6. On September 30, 2016, the Oversight Board designated the Debtors as 

“covered entit[ies]” under PROMESA section 101(d). 

7. On May 3, 2017, the Oversight Board issued a restructuring certification 

pursuant to PROMESA sections 104(j) and 206 and filed a voluntary petition for relief for the 

Commonwealth of Puerto Rico (the “Commonwealth”) pursuant to section 304(a) of 

PROMESA, commencing a case under title III thereof.

8. On May 5, 2017, the Oversight Board filed a voluntary petition for relief 

for the Puerto Rico Sales Tax Financing Corporation (“COFINA”) pursuant to section 304(a) of 

PROMESA, commencing a case under title III thereof.

9. On May 21, 2017, the Oversight Board filed a voluntary petition for relief 

for each of the Employees Retirement System of the Government of the Commonwealth of 

Puerto Rico (“ERS”) and the Puerto Rico Highways and Transportation Authority (“HTA”)

pursuant to section 304(a) of PROMESA, commencing cases under title III thereof.

10. On July 2, 2017, the Oversight Board filed a voluntary petition for the 

Puerto Rico Electric Power Authority (“PREPA”) pursuant to section 304(a) of PROMESA, 

commencing a case under title III thereof.

11. Through orders issued on June 1, June 29 and October 6, 2017, the Court 

ordered the joint administration of the Title III Cases for the Debtors, for procedural purposes 

only [ECF Nos. 242, 537 and 1417].

12. Background information regarding the Commonwealth and its 

instrumentalities, and the commencement of the instant Title III Cases, is contained in the Notice 

of Statement of Oversight Board in Connection with PROMESA Title III Petition [ECF No. 1] 

attached to the Commonwealth’s Title III petition.

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B. Retention of LS&E

13. LS&E is a law firm with its offices located in New York. LS&E has 

significant experience representing parties in bankruptcy actions and litigations in many large, 

complex cases. It has represented clients in numerous cases in the Southern District of New 

York, the Eastern District of New York, and in the United States District Courts and Courts of 

Appeals throughout the United States. 

14. As set forth in the engagement letter dated October 4, 2016 

(the “Engagement Letter”),6

 LS&E was retained by and authorized to represent the Oversight 

Board in connection with litigation in this Court seeking to lift the automatic stay imposed by 

PROMESA, seven months before these Title III Cases were commenced.7 Since the 

commencement of these Title III Cases, LS&E has continued to provide services to the 

Oversight Board and assists Proskauer Rose LLP (“Proskauer”), as lead counsel for the 

Oversight Board, in connection with the ongoing Title III actions given LS&E’s institutional 

knowledge of the pre-Title III litigation and its experience in bankruptcy litigation.

C. Interim Compensation and Fee Examiner Orders

15. On August 23, 2017, the Court entered the Order Setting Procedures for 

Interim Compensation and Reimbursement of Expenses of Professionals [ECF No. 1150]. 

16. On October 6, 2017, the Court appointed a Fee Examiner in these Title III 

Cases (the “Fee Examiner”) pursuant to the Order Pursuant to PROMESA Sections 316 and 317 

6 A copy of the Engagement Letter is available on the Oversight Board’s website at 

http://oversightboard.pr.gov/documents. 

7 Unlike in cases commenced under the Bankruptcy Code, professionals retained by the Debtors and the Oversight 

Board do not require court authorization for retention. See PROMESA § 301(a) (omitting Bankruptcy Code sections 

327 and 328 from incorporation into PROMESA).

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and Bankruptcy Code Section 105(a) Appointing a Fee Examiner and Related Relief

[ECF No. 1416] (the “Fee Examiner Order”).

17. On October 31, 2017, the Fee Examiner filed the Urgent Motion of the 

Fee Examiner to Amend the Interim Compensation Order, Including the Due Date and Hearing 

Date for Interim Compensation [ECF No. 1594].

18. On November 8, 2017, the Court entered the First Amended Order Setting 

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals

[ECF No. 1715].

19. On November 10, 2017, the Fee Examiner issued a memorandum, and on 

January 3, 2018 and February 22, 2019, the Fee Examiner issued supplemental memoranda 

(together, the “Fee Examiner Guidelines”) to all retained professionals in these Title III Cases 

providing additional guidelines in connection with the Interim Compensation Order.

20. On May 8, 2018, the Fee Examiner filed the Motion of the Fee Examiner 

to Amend the Fee Examiner Order with Respect to the Scope of the Fee Examiner’s Authority in 

the Interest of Administrative Efficiency [ECF No. 3032] (the “Motion to Amend the Fee 

Examiner Order”).

21. On May 23, 2018, the Oversight Board and the Puerto Rico Fiscal Agency 

and Financial Authority (the “AAFAF”) filed a Joint Motion for Entry of an Order Further 

Amending the Interim Compensation Order [ECF No. 3133].

22. On June 6, 2018, the Court entered the Second Amended Order Setting 

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals 

[ECF No. 3269].

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23. On June 20, 2018, the Court entered the First Amended Order Pursuant to 

PROMESA Sections 316 and 317 and Bankruptcy Code Section 105(A) Appointing a Fee 

Examiner and Related Relief [ECF No. 3324] (the “Amended Fee Examiner Order”). Pursuant 

to the Amended Fee Examiner Order, the Court directed the Fee Examiner, “in consultation with 

the relevant professionals and counsel for the Oversight Board, AAFAF, and the official 

committees, to develop and present a proposal to the Court to resolve the concerns the Fee 

Examiner has noted at paragraphs 9 through 22 of the Motion [to Amend the Fee Examiner 

Order], addressing the fee applications of McKinsey & Company, Andrew Wolfe, and other de 

minimis and flat fee professionals and reiterating and amending the provisions of the [Fee 

Examiner Order].”

24. On August 20, 2018, the Fee Examiner filed the Fee Examiner’s Motion to 

Impose Presumptive Standards and Timeliness Requirements for Professional Fee Applications

[ECF No. 3790] (the “Presumptive Standards Motion”), articulating presumptive standards of 

reasonableness and necessity for specific categories of professional services and recommending 

timely application requirements.

25. On September 13, 2018, the Court entered the Order on Fee Examiner’s 

Motion to Impose Presumptive Standards and Timeliness Requirements for Professional Fee 

Applications [ECF No. 3932], granting the Presumptive Standards Motion.

26. On June 6, 2019, the Fee Examiner filed the Informative Motion of the Fee 

Examiner Submitting Uncontested Revised Proposed Order Imposing Additional Presumptive 

Standards [ECF No. 7214], incorporating concerns raised by the Court and other parties with 

respect to additional presumptive standards of reasonableness and necessity for specific 

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categories of professional services, including the requirement of prior client approval of rate 

increases.

27. On June 26, 2019, the Court entered the Order Imposing Additional 

Presumptive Standards: Rate Increases and the Retention of Expert Witnesses or Other SubRetained Professionals [ECF No. 7678] (the “Additional Presumptive Standards Order”).

28. On March 1, 2022, the Oversight Board and the Fee Examiner filed a Joint 

Motion of the Oversight Board and the Fee Examiner for Entry of Order Further Amending 

Procedures for Submitting and Considering Compensation and Reimbursement of Expenses of 

Professionals [ECF No. 20245].

29. On April 12, 2022, the Court entered the Interim Compensation Order and 

in accordance therewith, LS&E and other professionals retained in these Title III Cases are 

authorized to serve upon the parties identified therein (the “Notice Parties”) monthly fee 

statements (the “Monthly Fee Statements”).

30. Pursuant to the Interim Compensation Order, the Notice Parties have ten 

days from the date of service of the Monthly Fee Statement to object to the amounts requested. 

If no objection is filed prior to expiration of the objection period, the Commonwealth is 

authorized to pay the respective professionals 90% of the fees and 100% of the expenses sought 

in each Monthly Fee Statement.

D. Applications for Interim Compensation

31. In addition to the Monthly Fee Statements, the Interim Compensation 

Order directed professionals to seek interim allowance and payment of compensation (including 

the 10% held back from Monthly Fee Statements) and expense reimbursement at 120-day 

intervals (each an “Interim Fee Period”) by filing with the Court and serving on the Notice 

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Parties an application for approval and allowance of all compensation and reimbursement of 

expenses relating to services rendered and expenses incurred during the preceding Interim Fee 

Period (see Interim Compensation Order at ¶2(f)).

32. On December 15, 2017, LS&E filed its First Interim Application of 

Luskin, Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management 

Board for Puerto Rico for Professional Compensation and Reimbursement of Expenses for the 

Period from May 3, 2017 through September 30, 2017 [ECF No. 2077], for interim 

compensation for the period of May 3, 2017 through September 30, 2017 (the “First Interim 

Application”) in these Title III Cases seeking interim allowance of $324,975.50 in compensation 

for professional services rendered and $2,172.59 in reimbursement for expenses incurred.

33. On February 21, 2018, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the First Interim Application. Based on multiple conversations 

LS&E had with the Fee Examiner’s professionals, the parties agreed that LS&E would reduce 

the amounts sought in the First Interim Application by $16,628.43 in fees and $71.95 in expenses 

(together, the “First Interim Adjustments”).

34. On March 1, 2018, the Fee Examiner filed the Fee Examiner’s Initial 

Report [ECF No. 2645] with respect to LS&E’s First Interim Application, recommending that 

the Court approve the First Interim Application, net of the First Interim Adjustments. 

35. On March 7, 2018, the Court entered its Omnibus Order Awarding Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the First Interim Compensation Period from May 3 through September 30, 2017

[ECF No. 2685], approving the First Interim Application, net of the First Interim Adjustments. 

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36. On March 19, 2018, LS&E filed its Second Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico for Professional Compensation and Reimbursement of Expenses for the Period from 

October 1, 2017 through January 31, 2018 [ECF No. 2729], for interim compensation for the 

period of October 1, 2017 through January 31, 2018 (the “Second Interim Application”) in these 

Title III Cases seeking interim allowance of $91,237.50 in compensation for professional 

services rendered and $1,329.64 in reimbursement for expenses incurred. 

37. On May 30, 2018, the Fee Examiner filed the Fee Examiner’s Second 

Report on Professional Fees and Expenses [ECF No. 3193], recommending that the Court 

adjourn LS&E’s Second Interim Application for consideration at the July 25, 2018 omnibus 

hearing. 

38. On July 16, 2018, LS&E filed its Third Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from February 1, 2018 through May 31, 2018 [ECF No. 3530] for interim compensation for the 

period from February 1, 2018 through May 31, 2018 (the “Third Interim Application”) in these 

Title III Cases seeking interim allowance of $125,126.00 in compensation for professional 

services rendered and $471.42 in reimbursement of expenses incurred. 

39. On July 25, 2018, the Fee Examiner provided his confidential letter report 

to LS&E with respect to the Second Interim Application. Based on multiple conversations 

LS&E had with the Fee Examiner’s professionals, the parties agreed that LS&E would reduce 

the amounts sought in the Second Interim Application by $2,367.83 in fees (the “Second Interim 

Adjustments”). 

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40. On September 6, 2018, the Court entered its Second Supplemental 

Omnibus Order Awarding Interim Allowance of Compensation for Professional Services 

Rendered and Reimbursement of Expenses for the First and Second Interim Compensation 

Period from May 3 through September 30, 3017 and from October 1, 2017 through 

January 31, 2018 [ECF No. 3874], approving the Second Interim Application, net of the Second 

Interim Adjustments. 

41. On September 20, 2018, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Third Interim Application. Based on multiple conversations 

LS&E had with the Fee Examiner’s professionals, the parties agreed that LS&E would reduce 

the amounts sought in the Third Interim Application by $2,000.00 in fees (the “Third Interim 

Adjustments”).

42. On October 31, 2018, the Fee Examiner filed the Fee Examiner’s Third 

Report on Professional Fees and Expenses [ECF No. 4126] (with respect to LS&E’s Third 

Interim Application, recommending that the Court approve the Third Interim Application, net of 

the Third Interim Adjustments.

43. On November 6, 2018, the Court entered its Omnibus Order Awarding 

Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Third Interim Compensation Period from February 1, 2018 through 

May 31, 2018 [ECF No. 4200], approving the Third Interim Application, net of the Third Interim 

Adjustments. 

44. On November 19, 2018, LS&E filed its Fourth Interim Application of 

Luskin, Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management 

Board for Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the 

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Period from June 1, 2018 through September 30, 2018 [ECF No. 4336] for interim compensation 

for the period from June 1, 2018 through September 30, 2018 (the “Fourth Interim Application”) 

in these Title III Cases seeking interim allowance of $74,708.00 in compensation for 

professional services rendered and $313.63 in reimbursement of expenses incurred. 

45. On February 26, 2019, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Fourth Interim Application. Based on multiple conversations 

LS&E had with the Fee Examiner’s professionals, the parties agreed that LS&E would reduce 

the amounts sought in the Fourth Interim Application by $3,000.00 in fees (the “Fourth Interim 

Adjustments”).

46. On March 6, 2019, the Fee Examiner filed the Fee Examiner’s Fourth 

Report on Presumptive Standards Motion and on Professional Fees and Expenses

[ECF No. 5409] with respect to LS&E’s Fourth Interim Application, recommending that the 

Court approve the Fourth Interim Application, net of the Fourth Interim Adjustments. 

47. On March 14, 2019, the Court entered its Omnibus Order Awarding 

Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Fourth Compensation Period from June 1, 2018 through September 30, 2018

[ECF No. 5654], approving the Fourth Interim Application, net of the Fourth Interim 

Adjustments.

48. On March 18, 2019, LS&E filed its Fifth Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from October 1, 2018 through January 31, 2019 [ECF No. 5778] for interim compensation for 

the period from October 1, 2018 through January 31, 2019 (the “Fifth Interim Application”) in 

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these Title III Cases seeking interim allowance of $547,219.50 in compensation for professional 

services rendered and $1,314.13 in reimbursement of expenses incurred. 

49. On May 9, 2019, the Fee Examiner provided his confidential letter report 

to LS&E with respect to the Fifth Interim Application. Based on conversations LS&E had with 

the Fee Examiner’s professionals, the parties agreed that LS&E would reduce the amounts 

sought in the Fifth Interim Application by $605.50 in fees and $2.62 in expenses (together, the 

“Fifth Interim Adjustments”).

50. On June 5, 2019, the Fee Examiner filed the Fee Examiner’s Fifth Interim 

Report on Professional Fees and Expenses [ECF No. 7233] (the “Fee Examiner’s Fifth Report”) 

with respect to LS&E’s Fifth Interim Application, recommending that the Court approve the 

Fifth Interim Application, net of the Fifth Interim Adjustments.

51. On June 26, 2019, the Court entered its Omnibus Order Awarding Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Fifth Compensation Period from October 1, 2018 through January 31, 2019

[ECF No. 7670], approving the Fifth Interim Application, net of the Fifth Interim Adjustments. 

52. On July 15, 2019, LS&E filed its Sixth Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from February 1, 2019 through May 31, 2019 [ECF No. 7968] for interim compensation for the 

period from February 1, 2019 through May 31, 2019 (the “Sixth Interim Application”) in these 

Title III Cases seeking interim allowance of $152,665.50 in compensation for professional 

services rendered and $900.41 in reimbursement of expenses incurred. 

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53. On September 5, 2019, pursuant to the Additional Presumptive Standards 

Order, LS&E filed its Notice of Proposed Hourly Rate Adjustment of Luskin, Stern & Eisler LLP, 

as Special Counsel to the Financial Oversight and Management Board for Puerto Rico, nunc pro 

tunc to August 1, 2019 [ECF No. 8621] (the “Notice of Hourly Rate Adjustment”).

54. On October 18, 2019, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Sixth Interim Application. Based on conversations LS&E 

had with the Fee Examiner’s professionals, the parties agreed that LS&E would reduce the 

amounts sought in the Sixth Interim Application by $500.00 in fees and $156.71 in expenses 

(together, the “Sixth Interim Adjustments”). 

55. On November 15, 2019, LS&E filed its Seventh Interim Application of 

Luskin, Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management 

Board for Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the 

Period from June 1, 2019 through September 30, 2019 [ECF No. 9199] (the “Seventh Interim 

Application”) for interim compensation for the period from June 1, 2019 through September 30, 

2019 in these Title III Cases seeking interim allowance of $54,602.00 in compensation for 

professional services rendered, $0.00 in reimbursement of expenses incurred, and $205,060.98 in 

amounts required to gross up taxes withheld during the fifth, sixth and seventh Interim Fee 

Periods (the “Seventh Interim Gross-Up Amount”) on account of the Tax Withholding. 

56. On December 4, 2019, the Fee Examiner filed the Fee Examiner’s

Supplemental Report on Uncontested Interim and Final Fee Applications Recommended for 

Court Approval [ECF No. 9428] with respect to LS&E’s Sixth Interim Application,

recommending that the Court approve the Sixth Interim Application, net of the Sixth Interim 

Adjustments. 

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57. On December 6, 2019, the Court entered its Supplemental Omnibus Order 

Awarding Interim Allowance of Compensation for Professional Services Rendered and 

Reimbursement of Expenses for the Fifth and Sixth Compensation Periods [ECF No. 9488], 

approving LS&E’s Sixth Interim Application, net of the Sixth Interim Adjustments.

58. On February 25, 2020, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Seventh Interim Application. The Fee Examiner did not 

recommend any reductions with respect to the fees and expenses requested by LS&E. However, 

based on conversations LS&E had with the Fee Examiner’s professionals, the parties agreed that 

LS&E would not seek interim allowance of the Seventh Interim Gross-Up Amount in connection 

with the Court’s consideration of LS&E’s Seventh Interim Application and consideration of the 

Seventh Interim Gross-Up Amount would be deferred to a later date.

59. On February 26, 2020, the Fee Examiner filed the Fee Examiner’s Report 

on Uncontested Professional Fee Matters for Consideration in Connection with the 

March 4, 2020 Omnibus Hearing [ECF No. 11785] with respect to LS&E’s Seventh Interim 

Application, recommending that the Court approve the Seventh Interim Application.

60. On March 6, 2020, the Court entered its Omnibus Order Awarding: 

I. Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Seventh Interim (June 1 – September 30, 2019) and Prior Compensation 

Periods; II. Final Allowance of Compensation for Professional Services Rendered and 

Reimbursement of Expenses for the Final Fee Period [ECF No. 12157], approving LS&E’s 

Seventh Interim Fee Application.8

8 The order did not address the Seventh Interim Gross-Up Amount and LS&E continues to reserve its rights to seek 

the Seventh Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109).

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61. On March 16, 2020, LS&E filed its Eighth Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from October 1, 2019 through January 31, 2020 [ECF No. 12356] (the “Eighth Interim 

Application”) for interim compensation for the period for the period from October 1, 2019 

through January 31, 2020 in these Title III Cases seeking interim allowance of $30,633.00 in 

compensation for professional services rendered, $66.91 in reimbursement of expenses incurred, 

and $12,307.84 in amounts required to gross up taxes withheld during the eighth Interim Fee 

Period (the “Eighth Interim Gross-Up Amount”) on account of the Tax Withholding. 

62. On May 8, 2020, the Fee Examiner provided his confidential letter report 

to LS&E with respect to the Eighth Interim Application. The Fee Examiner did not recommend 

any reductions with respect to the fees and expenses requested by LS&E. However, based on 

conversations LS&E had with the Fee Examiner’s professionals, the parties agreed that LS&E 

would not seek interim allowance of the Eighth Interim Gross-Up Amount in connection with the 

Court’s consideration of LS&E’s Eighth Interim Application and consideration of the Eighth 

Interim Gross-Up Amount would be deferred to a later date. 

63. On July 17, 2020, LS&E filed its Ninth Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from February 1, 2020 through May 31, 2020 [ECF No. 13714] (the “Ninth Interim 

Application”) for interim compensation for the period for the period from February 1, 2020 

through May 31, 2020 in these Title III Cases seeking interim allowance of $54,879.00 in 

compensation for professional services rendered, $5.52 in reimbursement of expenses incurred, 

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and $4,293.91 in amounts required to gross up taxes withheld during the ninth Interim Fee 

Period, from February 1, 2020 through February 29, 2020 (the “Ninth Interim Gross-Up 

Amount”) on account of the Tax Withholding. 

64. On July 22, 2020, the Fee Examiner filed the Fee Examiner’s Report on 

Uncontested Professional Fee Matters for Consideration in Connection with the July 29, 2020 

Omnibus Hearing [ECF No. 13810] with respect to LS&E’s Eighth Interim Application, 

recommending that the Court approve the Eighth Interim Application. 

65. On July 24, 2020, the Court entered its Omnibus Order Awarding: 

I. Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Eighth Interim (October 1, 2019 – January 31, 2020) and Prior Compensation 

Periods; II. Final Allowance of Compensation for Professional Services Rendered and 

Reimbursement of Expenses for the Final Fee Period [ECF No. 13824], approving LS&E’s 

Eighth Interim Fee Application.9

66. On August 10, 2020, pursuant to the Additional Presumptive Standards 

Order, LS&E filed its Notice of Proposed Hourly Rate Adjustment of Luskin, Stern & Eisler LLP, 

as Special Counsel to the Financial Oversight and Management Board for Puerto Rico, nunc pro 

tunc to August 1, 2020 [ECF No. 14006] (the “Second Notice of Hourly Rate Adjustment”).10

67. On September 23, 2020, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Ninth Interim Application. The Fee Examiner did not 

recommend any reductions with respect to the fees and expenses requested by LS&E. However, 

9 The order did not address the Eighth Interim Gross-Up Amount and LS&E continues to reserve its rights to seek 

the Eighth Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109).

10 Based on discussions with the Oversight Board, LS&E agreed that the adjusted hourly rates proposed in its 

Second Notice of Hourly Rate Adjustment would be effective as of September 1, 2020.

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based on conversations LS&E had with the Fee Examiner’s professionals, the parties agreed that 

LS&E would not seek interim allowance of the Ninth Interim Gross-Up Amount in connection 

with the Court’s consideration of LS&E’s Ninth Interim Application and consideration of the 

Ninth Interim Gross-Up Amount would be deferred to a later date. 

68. On October 21, 2020, the Fee Examiner filed the Fee Examiner’s Report 

on Uncontested Professional Fee Matters for Consideration in Connection with the 

October 28, 2020 Omnibus Hearing [ECF No. 14756] with respect to LS&E’s Ninth Interim 

Application, recommending that the Court approve the Ninth Interim Application. 

69. On October 26, 2020, the Court entered its Omnibus Order Awarding: 

(I) Interim Allowance of Compensation for Professional Services Rendered and Reimbursement 

of Expenses for the Ninth Interim (February 1, 2020 – May 31, 2020) and Prior Compensation 

Periods; (II) Final Allowance of Compensation for Professional Services Rendered and 

Reimbursement of Expenses for the Final Fee Period [ECF No. 14925], approving LS&E’s 

Ninth Interim Fee Application.11

70. On November 16, 2020, LS&E filed its Tenth Interim Application of 

Luskin, Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management 

Board for Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the 

Period from June 1, 2020 through September 30, 2020 [ECF No. 15147] (the “Tenth Interim 

Application”) for interim compensation for the period for the period from June 1, 2020 through 

September 30, 2020 in these Title III Cases seeking interim allowance of $35,231.00 in 

compensation for professional services rendered, $672.00 in reimbursement of expenses 

incurred, and $19,789.68 in amounts required to gross up the remaining taxes withheld during 

11 The order did not address the Ninth Interim Gross-Up Amount and LS&E continues to reserve its rights to seek 

the Ninth Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109).

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the ninth Interim Fee Period, from March 1, 2020 through May 31, 2020 (the “Tenth Interim 

Gross-Up Amount”) on account of the Tax Withholding. 

71. On January 21, 2021, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Tenth Interim Application. The Fee Examiner did not 

recommend any reductions with respect to the fees and expenses requested by LS&E. However, 

based on conversations LS&E had with the Fee Examiner’s professionals, the parties agreed that 

LS&E would not seek interim allowance of the Tenth Interim Gross-Up Amount in connection 

with the Court’s consideration of LS&E’s Tenth Interim Application and consideration of the 

Tenth Interim Gross-Up Amount would be deferred to a later date.

72. On March 4, 2021, the Fee Examiner filed the Fee Examiner’s Report on 

Uncontested Professional Fee Matters for Consideration in Connection with the March 10, 2021 

Omnibus Hearing [ECF No. 15932] with respect to LS&E’s Tenth Interim Application, 

recommending that the Court approve the Tenth Interim Application.

73. On March 8, 2021, the Court entered its Omnibus Order Awarding: 

(I) Interim Allowance of Compensation for Professional Services Rendered and Reimbursement 

of Expenses for the Tenth Interim (June 1, 2020 – September 30, 2020) and Prior Compensation 

Periods; (II) Final Allowance of Compensation for Professional Services Rendered and 

Reimbursement of Expenses for the Final Fee Period [ECF No. 15971], approving LS&E’s 

Tenth Interim Fee Application.12

74. On March 16, 2021, LS&E filed its Eleventh Interim Application of 

Luskin, Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management 

Board for Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the 

12 The order did not address the Tenth Interim Gross-Up Amount and LS&E continues to reserve its rights to seek 

the Tenth Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109).

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Period from October 1, 2020 through January 31, 2021 [ECF No. 16080] (the “Eleventh Interim 

Application”) for interim compensation for the period for the period from October 1, 2020 

through January 31, 2021 in these Title III Cases seeking interim allowance of $11,909.00 in 

compensation for professional services rendered, $0.00 in reimbursement of expenses incurred, 

and $15,461.09 in amounts required to gross up the remaining taxes withheld during the tenth

Interim Fee Period, from June 1, 2020 through September 30, 2020 (the “Eleventh Interim 

Gross-Up Amount”) on account of the Tax Withholding. 

75. On May 14, 2021, the Fee Examiner provided his confidential letter report 

to LS&E with respect to the Eleventh Interim Application. Based on conversations LS&E had 

with the Fee Examiner’s professionals, the parties agreed that LS&E would reduce the amounts 

sought in the Eleventh Interim Application by $114.00 in fees and $0.00 in expenses (together, 

the “Eleventh Interim Adjustments”). In addition, the parties agreed that LS&E would not seek 

interim allowance of the Eleventh Interim Gross-Up Amount in connection with the Court’s 

consideration of LS&E’s Eleventh Interim Application and consideration of the Eleventh Interim 

Gross-Up Amount would be deferred to a later date. 

76. On July 16, 2021, LS&E filed its Twelfth Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from February 1, 2021 through May 31, 2021 [ECF No. 17396] (the “Twelfth Interim 

Application”) for interim compensation for the period for the period from February 1, 2021 

through May 31, 2021 in these Title III Cases seeking interim allowance of $29,630.00 in 

compensation for professional services rendered, $0.00 in reimbursement of expenses incurred, 

and $5,175.43 in amounts required to gross up the taxes withheld during the eleventh Interim Fee 

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Period, from October 1, 2020 through January 31, 2021 (the “Twelfth Interim Gross-Up 

Amount”) on account of the Tax Withholding. 

77. On July 30, 2021, the Fee Examiner filed the Fee Examiner’s Revised 

Report on Uncontested Professional Fee Matters for Consideration in Connection with the 

August 4, 2021 Omnibus Hearing [ECF No. 17622] with respect to LS&E’s Eleventh Interim 

Application, recommending that the Court approve the Eleventh Interim Application. 

78. On August 3, 2021, the Court entered its Omnibus Order Awarding: 

Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Eleventh Interim (October 1, 2020 – January 31, 2021) and Prior 

Compensation Periods [ECF No. 17646], approving LS&E’s Eleventh Interim Fee 

Application.13

79. On August 3, 2021, pursuant to the Additional Presumptive Standards 

Order, LS&E filed its Third Notice of Proposed Hourly Rate Adjustment of Luskin, Stern & 

Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for Puerto 

Rico, effective as of September 1, 2021 [ECF No. 17656] (the “Third Notice of Hourly Rate 

Adjustment”).

80. On September 22, 2021, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Twelfth Interim Application. The Fee Examiner did not 

recommend any reductions with respect to the fees and expenses requested by LS&E. However, 

based on conversations LS&E had with the Fee Examiner’s professionals, the parties agreed that 

LS&E would not seek interim allowance of the Twelfth Interim Gross-Up Amount in connection 

13 The order did not address the Eleventh Interim Gross-Up Amount and LS&E continues to reserve its rights to seek 

the Eleventh Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109). 

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with the Court’s consideration of LS&E’s Twelfth Interim Application and consideration of the 

Twelfth Interim Gross-Up Amount would be deferred to a later date. 

81. On September 29, 2021, the Fee Examiner filed the Fee Examiner’s 

Report on Uncontested Professional Fee Matters for Consideration in Connection with the 

October 6, 2021 Omnibus Hearing [ECF No. 18308] with respect to LS&E’s Twelfth Interim 

Application, recommending that the Court approve the Twelfth Interim Application. 

82. On October 4, 2021, the Court entered its Omnibus Order Awarding: 

Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Twelfth Interim (February 1, 2021 – May 31, 2021) and Prior Compensation 

Periods [ECF No. 18371], approving LS&E’s Twelfth Interim Fee Application.14

83. On November 15, 2021, LS&E filed its Thirteenth Interim Application of 

Luskin, Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management 

Board for Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the 

Period from June 1, 2021 through September 30, 2021 [ECF No. 19215] (the “Thirteenth Interim 

Application”) for interim compensation for the period for the period from June 1, 2021 through 

September 30, 2021 in these Title III Cases seeking interim allowance of $15,340.00 in 

compensation for professional services rendered, $0.00 in reimbursement of expenses incurred, 

and $13,003.09 in amounts required to gross up the remaining taxes withheld during the twelfth 

Interim Fee Period, from February 1, 2021 through May 31, 2021 (the “Thirteenth Interim 

Gross-Up Amount”) on account of the Tax Withholding. 

84. On January 13, 2022, the Fee Examiner provided his confidential letter 

report to LS&E with respect to the Thirteenth Interim Application. The Fee Examiner did not 

14 The order did not address the Twelfth Interim Gross-Up Amount and LS&E continues to reserve its rights to seek 

the Twelfth Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109).

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recommend any reductions with respect to the fees and expenses requested by LS&E. However, 

based on conversations LS&E had with the Fee Examiner’s professionals, the parties agreed that 

LS&E would not seek interim allowance of the Thirteenth Interim Gross-Up Amount in 

connection with the Court’s consideration of LS&E’s Thirteenth Interim Application and 

consideration of the Thirteenth Interim Gross-Up Amount would be deferred to a later date.

85. On January 26, 2022, the Fee Examiner filed the Fee Examiner’s Report 

on Anticipated Final Fee Application Process and on Uncontested Professional Fee Matters for 

Consideration in Connection with the February 2, 2022 Omnibus Hearing [ECF No. 19911] 

with respect to LS&E’s Thirteenth Interim Application, recommending that the Court approve 

the Thirteenth Interim Application.

86. On January 28, 2022, the Court entered its Omnibus Order Awarding: 

Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Thirteenth Interim (June 1, 2021 – September 30, 2021) and Prior 

Compensation Periods [ECF No. 19937], approving LS&E’s Thirteenth Interim Fee 

Application.15

87. On June 7, 2022, LS&E filed its Fourteenth Interim Application of Luskin, 

Stern & Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for 

Puerto Rico, for Professional Compensation and Reimbursement of Expenses for the Period 

from October 1, 2021 through January 31, 2022 [ECF No. 21125] (the “Fourteenth Interim 

Application”) for interim compensation for the period for the period from October 1, 2021 

through January 31, 2022 in these Title III Cases seeking interim allowance of $30,811.50 in 

compensation for professional services rendered, $0.00 in reimbursement of expenses incurred, 

15 The order did not address the Thirteenth Interim Gross-Up Amount and LS&E continues to reserve its rights to 

seek the Thirteenth Interim Gross-Up Amount on account of Tax Withholding (see ¶ 109).

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and $6,488.28 in amounts required to gross up the remaining taxes withheld during the thirteenth

Interim Fee Period, from June 1, 2021 through September 30, 2021 (the “Fourteenth Interim 

Gross-Up Amount”) on account of the Tax Withholding. 

88. On September 26, 2022, the Court entered its Omnibus Order Awarding: 

Interim Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Fifteenth Interim (February 1, 2022 – May 31, 2022) and Prior Compensation 

Periods [ECF No. 22393]. Pursuant to the order, the hearing on LS&E’s Fourteenth Interim 

Application [ECF No. 21125], was adjourned to a later hearing date. On September 29, 2022, 

LS&E received the Fee Examiner’s confidential report indicating that the Fee Examiner was not 

recommending any adjustments to LS&E’s Fourteenth Interim Application. 

Relief Requested

89. By this Application, LS&E seeks an order authorizing (a) allowance of 

interim compensation for the professional services rendered during the Compensation Period in 

the aggregate amount of $10,096.50, (b) allowance of reimbursement of actual and necessary 

expenses incurred by LS&E during this Compensation Period in the aggregate amount of $0.00, 

(c) allowance of the Fifteenth Interim Gross-Up Amount in connection with Tax Withholding 

during the fourteenth Interim Fee Period in the aggregate amount of $13,521.60,16 and 

(d) payment of the outstanding fees and expense reimbursement in the aggregate amount of 

$10,096.50, inclusive of any amounts previously held back. 

90. During the Compensation Period, LS&E attorneys and paraprofessionals 

expended a total of 25.20 hours for which compensation is requested. All services rendered and 

16 LS&E has not previously sought interim allowance of the Fifteenth Interim Gross-Up Amount (but has always 

reserved the right to do so). LS&E will only request payment of the Fifteenth Interim Gross-Up Amount from the 

Debtors if it is determined that the Tax Withholding does not result in federal and state tax credits offsetting the 

Fifteenth Interim Gross-Up Amount.

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expenses incurred for which compensation or reimbursement is requested were performed or 

incurred for or on behalf of the Oversight Board. 

91. During the Compensation Period, LS&E submitted one Monthly Fee 

Statement (the fifty-fourth such statement submitted by LS&E). 

92. On April 19, 2022, LS&E served its consolidated fifty-fourth Monthly Fee 

Statement covering the period from February 1, 2022 through March 15, 2022 (the “Fifty-fourth

Monthly Fee Statement”), a copy of which is attached hereto as Exhibit E.

17 LS&E received no 

objection to the Fifty-fourth Monthly Fee Statement. On August 1, 2022, LS&E submitted a 

statement of no objection to the AAFAF with respect to the Fifty-fourth Monthly Fee Statement. 

As of the filing of this Application, LS&E has received no payments in connection with its Fiftyfourth Monthly Fee Statement. 

93. Other than the Fifty-fourth Monthly Fee Statement, no payments have 

been made to LS&E, and LS&E has received no promises of payment from any source for 

services rendered or to be rendered in any capacity whatsoever in connection with the matters 

covered during the Compensation Period and addressed by this Fifteenth Interim Application. 

There is no agreement or understanding between LS&E and any other person, other than the 

members of LS&E, for the sharing of compensation to be received for services rendered in these 

cases.

94. The fees charged by LS&E in these cases are billed in accordance with 

LS&E’s existing billing rates and procedures in effect during the Compensation Period. The 

rates set forth in the Engagement Letter which LS&E charges for the services rendered by its 

professionals and paraprofessionals in these Title III Cases are the same rates LS&E generally 

17 The fees requested in LS&E’s Fifty-fourth Monthly Fee Statement reflect voluntary reductions in the amount of 

$1,228.50 which are reflected in the net amounts sought in this Application.

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charges for professionals and paraprofessional services rendered in comparable non-bankruptcy 

related matters. Such fees are reasonable based on the customary compensation charged by 

comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national 

legal market. 

95. LS&E maintains computerized records of all time spent by LS&E 

attorneys and paraprofessionals in connection with its representation of the Oversight Board. 

Applicant has provided itemized time records for professionals and paraprofessionals performing 

services during the Compensation Period to this Court, the Debtors, the Fee Examiner, all notice 

parties pursuant to the Interim Compensation Order, and the U.S. Trustee. All entries itemized 

in Applicant’s time records comply with the requirements set forth in the Guidelines, including 

the use of separate matter numbers for different project types, as described in this Application. 

Applicant’s itemized time records also detail expenses incurred during the Compensation Period. 

All entries itemized in Applicant’s expense records comply with the requirements set forth in the 

Guidelines. 

96. Pursuant to, and consistent with, the relevant requirements of the 

Guidelines, as applicable, the following exhibits are attached hereto and incorporated herein by 

reference: 

i. Exhibit A contains a certification by Michael Luskin regarding LS&E’s 

compliance with the Local Guidelines. 

ii. Exhibit B contains a summary of hours and fees billed by each LS&E 

attorney and paraprofessional in services rendered to the Oversight Board 

during the Compensation Period, including respective titles, hourly rates, 

year of bar admission for attorneys and any applicable rate increases.

iii. Exhibit C contains a summary of compensation requested by matter 

during the Compensation Period. 

iv. Exhibit D contains a summary and comparison of the aggregate blended 

hourly rates. 

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v. Exhibit E contains a copy of LS&E’s Monthly Fee Statement during the 

Compensation Period, which includes detailed time records and out-ofpocket expenses. 

Summary of Services Performed by LS&E During the Compensation Period

97. Set forth below is a description of significant professional services, broken 

down by project category, rendered by LS&E during the Compensation Period. The following 

services described are not intended to be a comprehensive summary of the work performed by 

LS&E; a detailed description of all services rendered by LS&E can be found in the detailed time 

records reflecting the services performed by LS&E’s professionals, the time expended by each 

professional, and the hourly rate of each professional, annexed to the Monthly Fee Statement 

attached hereto as Exhibit E, and such descriptions are incorporated herein by reference. 

A. Fee Applications

Fees: $7,216.50; Hours: 22.00. 

98. During the Compensation Period, LS&E spent time under this project 

category on the following: (a) review of the docket and filings in these Title III Cases in 

connection with fee and compensation matters, (b) review of the Guidelines and Fee Examiner 

Guidelines in connection with LS&E’s Fourteenth Interim Application and future interim and 

final applications, (c) preparation of its Fourteenth Interim Application, including analysis of the 

Tax Withholding and Fourteenth Interim Gross-Up Amount, and (d) review and coordination 

with the Oversight Board’s professionals in connection with the foregoing. 

99. LS&E has voluntarily written off 2.8 hours in time expended and 

$1,228.50 of fees incurred under this project category in connection with the following: 

(a) preparation of its Monthly Fee Statement during this Compensation Period, (b) reviewing and 

revising invoices in connection with its Monthly Fee Statement during this Compensation 

Period, (c) preparation of the principal certification with respect to its Monthly Fee Statement

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during this Compensation Period, and (d) preparation of a no objection statement with respect to 

its Monthly Fee Statement during this Compensation Period. 

B. Conflicts and Disclosure Issues18

Fees: $2,880.00; Hours: 3.20. 

100. Prior to the eighth Interim Fee Period, LS&E’s time in this project 

category was attributable to work done related to its examination of the facts, consequences, and 

implications concerning potential conflict of interest issues regarding the Oversight Board’s 

retention of McKinsey & Company, Inc. Washington D.C. (“McKinsey”), including the 

circumstances surrounding McKinsey’s and its affiliates’ holdings of Puerto Rico public debt. 

As part of the investigation, LS&E reviewed McKinsey’s disclosure obligations under current 

law and pursuant to its contractual arrangements with the Oversight Board and prepared a 95-

page written report (the “McKinsey Report”) detailing LS&E’s findings and conclusions and 

making recommendations regarding the Oversight Board’s practices and policies with respect to 

the disclosures that it requires of its vendors.19 Since the filing of the McKinsey Report, LS&E 

has continued to provide advice to the Oversight Board related to the Oversight Board’s vendors, 

including vendor contracts and vendor conflict disclosures. 

101. During the Compensation Period, LS&E spent the bulk of its time in this 

project category evaluating disclosure documentation, including a review of court and other 

filings regarding McKinsey disclosures and other issues, potential conflict issues, and proposed 

contractual changes of the Oversight Board’s vendors on a case by case basis, including 

18 Following LS&E’s filing of the McKinsey Report on February 18, 2019 [ECF No. 5154], the Oversight Board 

requested that LS&E review and advise on various conflicts and disclosure issues related to the Oversight Board’ 

vendors. LS&E has changed the name of this project category on its billing system from “McKinsey Report” to 

“Conflicts and Disclosure Issues.”

19 See ECF No. 5154.

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numerous meetings, telephone calls, and email exchanges with the Oversight Board and certain 

of its vendors in connection with the foregoing. 

Actual and Necessary Disbursements

102. As set forth in the Summary Cover Sheet filed contemporaneously with 

this Application, LS&E disbursed $0.00 as expenses incurred in providing professional services 

during the Compensation Period. LS&E passes through all out-of-pocket expenses at actual cost. 

Other reimbursable expenses (whether the service is performed by LS&E in-house or through a 

third-party vendor) include, but are not limited to, deliveries, court costs, transcript fees, travel, 

teleconferencing, and clerk fees, and are passed through at cost. LS&E does not bill for fax and 

phone charges (other than fees for conference calls), secretarial overtime or other administrative 

costs.

Voluntary Reductions and Adjustments

103. In the exercise of billing discretion, LS&E voluntarily wrote off $1,228.50 

in fees during the Compensation Period in connection with time billed to the Fee Application 

project category and in accordance with the Fee Examiner Guidelines. Such reductions are 

reflected in the amounts requested in LS&E’s Monthly Fee Statements during the Compensation 

Period and the net amounts sought in this Application. 

The Application Should be Granted

104. Section 317 of PROMESA provides for interim compensation of 

professionals and incorporates the substantive standards of Section 316 of PROMESA to govern 

the Court’s award of such compensation. 48 U.S.C. § 2177. Section 316 provides that a court 

may award a professional employed under section 1103 of title 11 of the United States Code 

“reasonable compensation for actual, necessary services rendered . . . and reimbursement for 

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actual, necessary expenses.” Id. § 2176(a)(1) and (2). Section 316(c) sets forth criteria for the 

award of such compensation and reimbursement:

In determining the amount of reasonable compensation to be awarded to a 

professional person, the court shall consider the nature, the extent, and the value 

of such services, taking into account all relevant factors, including—

(1) the time spent on such services;

(2) the rates charged for such services;

(3) whether the services were necessary to the administration of, or 

beneficial at the time at which the service was rendered toward the 

completion of, a case under this chapter;

(4) whether the services were performed within a reasonable amount of time 

commensurate with the complexity, importance, and nature of the 

problem, issue, or task addressed;

(5) with respect to a professional person, whether the person is board

certified or otherwise has demonstrated skill and experience in the 

restructuring field; and

(6) whether the compensation is reasonable based on the customary 

compensation charged by comparably skilled practitioners in cases other 

than cases under this title or title 11, United States Code.

Id. § 2176(c). 

105. LS&E respectfully submits that the services for which it seeks 

compensation and the expenditures for which it seeks reimbursement in this Application were 

necessary and beneficial to the Oversight Board. In light of the nature, extent and value of such 

services, LS&E submits that the compensation requested herein is reasonable.

106. The compensation for LS&E’s services as requested is commensurate with 

the complexity, importance and nature of the problems, issues or tasks involved. The 

professional services were performed with expedition and in an efficient manner. In addition, 

the assignments given to LS&E by the Oversight Board and Proskauer required the attention of 

senior-level attorneys. Virtually all of the legal work was done by one senior partner and there

was no time expended by associates during the Compensation Period.

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107. In sum, the services rendered by LS&E were necessary and beneficial to 

the Oversight Board, were reasonable in light of the value of such services to the Oversight 

Board and were performed with skill and expertise. Accordingly, LS&E submits that approval 

of the compensation for professional services and reimbursement of expenses requested in this 

Fifteenth Interim Fee Application is warranted. 

Location of Services Provided 

108. All fees and services during this Compensation Period were rendered and 

incurred outside of Puerto Rico. 

Gross-Up Amount with Respect to Tax Withholding

109. On December 10, 2018, Puerto Rico enacted Act 257 amending the Puerto 

Rico Internal Revenue Code of 2011. Under Act 257, LS&E’s fees incurred on or after 

January 1, 2019 are assessed with a 29% income tax on professional fees at the time of payment.

110. LS&E received federal tax credits offsetting Tax Withholding in the 

aggregate amount of $139,919.43 for the fiscal year ending on December 31, 2019 (the “2019 

Tax Withholding”), $38,905.00 for the fiscal year ending on December 31, 2020 (the “2020 Tax 

Withholding”), and $34,526.65 for the fiscal year ending on December 31, 2021 (the “2021 Tax 

Withholding”)].20 The 2019 Tax Withholding included an error resulting in excess taxes 

withheld on the Debtors’ payment of LS&E’s fees held back during the fifth Interim Fee Period 

(the “Excess Tax Withholding”). On February 7, 2020, the Puerto Rico Department of Treasury 

issued a refund to LS&E in the amount of $8,357.10 on account of the Excess Tax Withholding. 

LS&E did not receive New York State tax credits on account of the 2019 Tax Withholding or the 

20 NTD: Insert total federal (and state) tax credits received for the fiscal year ending December 31, 2021 (amount 

provided by LS&E firm accountant).

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2020 Tax Withholding. LS&E continues to reserve its rights to seek amounts required to gross 

up the 2019 Tax Withholding, net of the Excess Tax Withholding, the 2020 Tax Withholding, 

and the 2021 Tax Withholding, and will only request payment of such amounts, including the 

Seventh Interim Gross-Up Amount, Eighth Interim Gross-Up Amount, Ninth Interim Gross-Up 

Amount, Tenth Interim Gross-Up Amount, Eleventh Interim Gross-Up Amount, Twelfth Interim 

Gross-Up Amount, Thirteenth Interim Gross-Up Amount, and Fourteenth Interim Gross-Up 

Amount, as applicable, from the Debtors if it is determined that LS&E is not entitled to New 

York State tax credits offsetting such gross-up amounts. In addition, LS&E continues to reserve 

its rights to seek amounts required to gross up the Tax Withholding during the fiscal year ending 

on December 31, 2022, and any future Tax Withholding. 

111. LS&E requests approval now, as part of its fees and expenses, of the 

Fifteenth Interim Gross-Up Amount of $13,521.60 on account of the Tax Withholding during the 

fourteenth Interim Fee Period. LS&E has not previously sought interim allowance of the 

Fifteenth Interim Gross-Up Amount (but has always reserved the right to do so). LS&E will 

only request payment of the Fifteenth Interim Gross-Up Amount from the Debtors if it is 

determined that the Tax Withholding does not result in federal and state tax credits offsetting the 

Fifteenth Interim Gross-Up Amount. 

Statements Pursuant to Appendix B of the U.S. Trustee Guidelines

112. The following statements address information pursuant to Section C.5 of 

the U.S. Trustee Guidelines: 

a. Question: Did you agree to any variations from, or alternatives to, your 

standard or customary billing rates, fees or terms for services pertaining to this 

engagement that were provided during the application period? If so, please 

explain. 

Answer: No. 

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b. Question: If the fees sought in this fee application as compared to the fees 

budgeted for the time period covered by this fee application are higher by 

10% or more, did you discuss the reasons for the variation with the client? 

Answer: Given that LS&E’s services were and continue to be performed 

on an ad hoc basis, the amount of time it bills in any given month or 

Compensation Period can fluctuate substantially. Accordingly, and based 

on discussions with the Fee Examiner, LS&E is no longer subject to the 

budgeting requirement with respect to the work it performs on an ad hoc

basis. 

c. Question: Have any of the professionals included in this fee application 

varied their hourly rate based on geographic location of the bankruptcy case? 

Answer: No.

d. Question: Does the fee application include time or fees related to reviewing 

or revising time records or preparing, reviewing, or revising invoices? (This 

is limited to work involved in preparing and editing billing records that would 

not be compensable outside of bankruptcy and does not include reasonable 

fees for preparing a fee application.). If so, please quantify by hours and fees. 

Answer: No. LS&E voluntarily reduced its time and fees billed in this 

Application relating to reviewing and revising time records or preparing, 

reviewing or revising invoices. These amounts were not separately 

calculated but are included in the voluntary reductions made in this 

Fifteenth Interim Application, which are not reflected in the amounts 

sought therein. 

e. Question: Does this fee application include time or fees for reviewing time 

records to redact any privileged or other confidential information? If so, 

please quantify by hours and fees. 

Answer: No. Any such time and fees related to reviewing and revising 

invoices to protect privileged or confidential information are included in 

the voluntary reductions referenced in the response to the question in 

paragraph 112(d) and are not separately calculated.

f. Question: If the fee application includes any rate increases in retention: 

(i) Did your client review and approve those rate increases in advance? and 

(ii) Did your client agree when retaining the law firm to accept all future rate 

increases? If not, did you inform your client that they need not agree to 

modified rates or terms in order to have you continue the representation, 

consistent with ABA Formal Ethics Opinion 11-458? 

Answer: The Fifteenth Interim Application does not include any 

additional rate increases but incorporates hourly rate increases for certain 

of LS&E’s timekeepers during the thirteenth Interim Fee Period. Such 

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rate increases were approved by the client pursuant to the terms of the 

Engagement Letter and LS&E was authorized by its client to increase the 

hourly rates for its timekeepers, both with respect to the effective date of 

September 1, 2021 and the amounts set forth on Exhibit A to the Third

Notice of Hourly Rate Adjustment.21 Such rate adjustments are

presumptively reasonable pursuant to the guidelines set forth in the 

Additional Presumptive Standards Order. 

Notice

113. Notice of this Application has been provided to: (a) the United States 

Trustee for the District of Puerto Rico, (b) the Oversight Board and its counsel, (c) counsel to the 

AAFAF, (d) counsel to the Fee Examiner, (e) counsel to the Official Committee of Unsecured 

Creditors, (f) counsel to the Official Committee of Retirees, and (g) the Puerto Rico Department 

of Treasury. LS&E respectfully submits that no further notice of this Application should be 

required. 

No Prior Request

114. No prior interim fee application for the relief requested herein has been 

made to this or any other Court. 

Conclusion 

WHEREFORE, LS&E respectfully requests that the Court enter an order 

(a) approving the interim allowance of $10,096.50 for compensation for professional services 

rendered during the Compensation Period, (b) approving the reimbursement of LS&E’s out-ofpocket expenses incurred in connection with the rendering of such services during the 

Compensation Period in the amount of $0.00, (c) approving interim allowance of $13,521.60 for 

the Fifteenth Interim Gross-Up Amount in connection with the Tax Withholding during the 

21 See ECF No. 17656, Exhibit B at ¶3.

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fourteenth Interim Fee Period,

22 (d) authorizing payment of the outstanding fees and expense 

reimbursement in the aggregate amount of $10,096.50, and (e) granting such other and further 

relief as the Court deems just and proper. 

Dated: White Plains, New York 

October 3, 2022 

Respectfully submitted,

/s/ Michael Luskin

Michael Luskin (admitted pro hac vice) 

Lucia T. Chapman (admitted pro hac vice)

Stephan E. Hornung (admitted pro hac vice)

LUSKIN, STERN & EISLER LLP

50 Main Street

White Plains, New York 10606 

Telephone: (212) 597-8200 

Facsimile: (212) 597-8240 

luskin@lsellp.com

chapman@lsellp.com

hornung@lsellp.com

Special Counsel to the Financial Oversight and 

Management Board for Puerto Rico

22 LS&E has not previously sought interim allowance of the Fifteenth Interim Gross-Up Amount (but has always 

reserved the right to do so). LS&E will only request payment of the Fifteenth Interim Gross-Up Amount from the 

Debtors if it is determined that the Tax Withholding does not result in federal and state tax credits offsetting the 

Fifteenth Interim Gross-Up Amount.

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EXHIBIT A

Certification of Michael Luskin in Support of the Application

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Estimated Hearing Date: November 2, 2022 at 9:30 a.m. AST

Objection Deadline: October 24, 2022 at 4:00 p.m. AST

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

PROMESA

Title III

 

 No. 17-BK-03283 (LTS) 

(Jointly Administered)

CERTIFICATION UNDER GUIDELINES FOR FEES AND DISBURSEMENTS FOR 

PROFESSIONALS IN RESPECT OF FIFTEENTH INTERIM APPLICATION OF

LUSKIN, STERN & EISLER LLP, AS SPECIAL COUNSEL TO THE FINANCIAL 

OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO, 

FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES 

FOR THE PERIOD FROM FEBRUARY 1, 2022 THROUGH MARCH 15, 2022 

I, Michael Luskin, hereby certify that: 

1. I am an attorney admitted to practice before the United States District 

Court for the Southern District of New York and am admitted pro hac vice before this Court. 

I am a member of the law firm of Luskin, Stern & Eisler LLP (“LS&E” or “Applicant”), with 

offices located at 50 Main Street, White Plains, New York 10606. Applicant is special counsel 

to the Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”) as 

representative of the Debtors in the above-captioned title III cases pursuant to section 315(b) of 

1 The Debtors in these jointly-administered Title III Cases, along with each Debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor’s federal 

tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 

3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17 BK 

3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation Authority 

(“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) Last Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico 

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 

3747).

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

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2 

the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”).

2

 I have 

personal knowledge of all of the facts set forth in this certification except as expressly stated 

herein.

2. In accordance with (a) Local Bankruptcy Rule 2016-1 (the “Local 

Guidelines”), (b) Appendix B of the United States Trustee Guidelines for Reviewing 

Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330, 

effective as of November 1, 2013 (the “U.S. Trustee Guidelines”), and (c) the Third Amended

Order Setting Procedures for Interim Compensation and Reimbursement of Expenses of 

Professionals entered April 12, 2022 (as amended, the “Interim Compensation Order”), this

certification is made with respect to the Fifteenth Interim Application of LS&E, as special 

counsel to the Oversight Board, dated October 3, 2022 (the “Application”),3 for interim 

compensation and reimbursement of expenses for the period of February 1, 2022 through and 

including March 15, 2022 (the “Compensation Period”).

3. With respect to section (a)(4) of the Local Guidelines, I certify that: 

a) I have read the Application; 

b) to the best of my knowledge, information, and belief, formed after 

reasonable inquiry, the compensation and reimbursement of 

expenses sought conforms with the Bankruptcy Code, the Federal 

Rules of Bankruptcy Procedure, the U.S. Trustee Guidelines and 

these Local Guidelines; 

c) except to the extent that fees or disbursements are prohibited by 

the Local Guidelines, the compensation and reimbursement of 

expenses requested are billed at rates no less favorable to the 

Debtors than those customarily employed by LS&E and generally 

accepted by LS&E’s clients (with the exception of a small number 

2 PROMESA has been codified in 48 U.S.C. §§ 2101-2241.

3 Capitalized terms used but not defined herein have the meanings given to them in the Application.

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3 

of high-volume clients who have negotiated reduced-fee 

agreements, see Application at Exhibit D); and

d) in providing a reimbursable service, LS&E does not make a profit 

on that service, whether the service is performed by LS&E inhouse or through a third party. 

Dated: White Plains, New York 

October 3, 2022 

Respectfully submitted,

/s/ Michael Luskin 

Michael Luskin (admitted pro hac vice) 

LUSKIN, STERN & EISLER LLP

50 Main Street

White Plains, New York 10606 

Telephone: (212) 597-8200 

Facsimile: (212) 597-8240 

luskin@lsellp.com 

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EXHIBIT B

Summary of Hours Billed by Professionals and Paraprofessionals 

for the Period from February 1, 2022 through March 15, 20221

Timekeeper Position and Year 

Admitted to Practice

This Interim Fee Application First Interim 

Application 

Hourly 

Billing Rate

Rate 

Increases 

Since Case 

Inception

Total Fees 

Billed

Total 

Hours 

Billed

Hourly 

Billing 

Rate2

Michael Luskin Senior Partner 1978 $4,050.00 4.50 $900.00 $800.00 3 

Stephan E. 

Hornung

Junior Partner 2008 $ 232.50 0.30 $775.00 $635.00 5 

Catherine D. Trieu Paralegal N/A $5,814.00 20.40 $285.00 $255.00 2 

TOTAL $10,096.50 25.20

1 These amounts were adjusted to reflect 2.80 hours and $1,228.50 in fees which LS&E has voluntarily reduced.

2 Effective as of September 1, 2021, LS&E adjusted its hourly rates on a timekeeper-by-timekeeper basis for its 

timekeepers as set forth in its Third Notice of Hourly Rate Adjustment. Such rate increases are presumptively 

reasonable pursuant to the Additional Presumptive Standards Order. See ECF No. 17656.

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EXHIBIT C 

Summary of Compensation by Matter for the Period 

from February 1, 2022 through March 15, 20221

1 These amounts were adjusted to reflect 2.80 hours and $1,228.50 in fees which LS&E has voluntarily reduced.

2 Following LS&E’s filing of the McKinsey Report on February 18, 2019 [ECF No. 5154], the Oversight Board 

requested that LS&E review and advise on various conflicts and disclosure issues related to the Oversight Board’ 

vendors. LS&E has changed the name of this project category on its billing system from “McKinsey Report” to 

“Conflicts and Disclosure Issues.”

Project

Category

Total

Billed Hours

Total Fees

Requested ($)

Fee Applications 22.00 $7,216.50 

Conflicts and Disclosure Issues2 3.20 $2,880.00 

TOTAL 25.20 $10,096.50 

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EXHIBIT D 

Summary of Blended Hourly Rates and Comparable Hourly Rates of Timekeepers1

Category of 

Timekeeper

Blended Hourly Rate

Billed in this Fee 

Application

Billed for 2021 

(excluding bankruptcy)

Billed for 2021 (excluding 

bankruptcy and legacy clients) 

Senior Partners $900.00 $803.02 $849.58 

Junior Partners $775.00 $763.41 $770.85 

Attorney Total $892.19 $785.75 $803.93 

Paralegals $285.00 $215.38 $271.08 

All Timekeepers $400.65 $707.24 $752.74 

1 The difference in rates charged in this case versus other non-bankruptcy cases is attributable to three factors. First, 

LS&E has long-standing rate schedule agreements with a small number of clients that have negotiated fixed 

“legacy” rates based on the significant volume of services LS&E provides to such clients which are below its 

customary rates. We have included a third column, which reflects the firm’s blended hourly rates without including 

the hours worked for legacy clients. Second, as disclosed in Exhibit B, LS&E increased its hourly rates in 

September, 2021, and all of the time during this Compensation Period was billed subsequent to that rate increase. 

Virtually all of the legal work was done by one senior partner and there was no time billed by associates during this 

Compensation Period. Finally, LS&E is a small firm consisting of nine attorneys (six partners, one senior associate, 

one mid-level associate and one junior associate). Staffing allocations can have a disproportionate and misleading 

impact on LS&E’s blended hourly rates across a small sample size.

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EXHIBIT E 

Fifty-fourth Monthly Fee Statement 

(February 1, 2022 – March 15, 2022) 

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Document Page 49 of 65
Objection Deadline: April 29, 2022 at 4:00 p.m. (AST)

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

PROMESA

Title III

No. 17-BK-03283 (LTS)

(Jointly Administered)

COVER SHEET TO CONSOLIDATED FIFTY-FOURTH MONTHLY FEE 

STATEMENT OF LUSKIN, STERN & EISLER LLP FOR COMPENSATION FOR 

FEES AND SERVICES RENDERED OUTSIDE OF PUERTO RICO AND 

REIMBURSEMENT OF EXPENSES AS SPECIAL COUNSEL TO THE 

FINANCIAL OVERSIGHT AND MANAGEMENT BOARD FOR PUERTO RICO, 

FOR THE PERIOD FROM FEBRUARY 1, 2022 THROUGH MARCH 15, 2022

ALL FEES AND SERVICES IN THIS MONTHLY FEE STATEMENT WERE 

INCURRED OUTSIDE OF PUERTO RICO

1 The Debtors in these jointly-administered Title III Cases, along with each Debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor’s federal 

tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 

3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17 

BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation 

Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) Last Four Digits of Federal Tax ID: 3808); and (v) 

Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of 

Federal Tax ID: 3747).

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

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Principal Certification

I hereby authorize the submission of Luskin, Stern & Eisler LLP’s Consolidated Monthly 

Fee Statement for the period from February 1, 2022 through March 15, 2022.

Jaime A. El Koury

General Counsel to the Financial Oversight 

and Management Board for Puerto Rico

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Summary Sheet

Name of Applicant: Luskin, Stern & Eisler LLP

Authorized to Provide Professional 

Services to:

The Financial Oversight and Management 

Board for Puerto Rico

Period for Which Compensation and 

Reimbursement are Sought

February 1, 2022 to March 15, 2022

Amount of Compensation Sought as Actual, 

Reasonable and Necessary:

$10,096.501

90% of Compensation Sought as Actual, 

Reasonable and Necessary:

$9,086.85

10% Holdback: $1,009.65

Amount of Expense Reimbursement Sought 

as Actual, Reasonable and Necessary:

$0.00

This is a: X monthly ___ interim ___ final statement.

This is Luskin, Stern & Eisler LLP’s consolidated fifty-fourth monthly fee statement in these 

cases.

1 LS&E reserves the right to seek an offsetting adjustment or “gross up” on account of any tax withholding pursuant

to Act 257 amending the Puerto Rico Internal Revenue Code of 2011.

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2

Summary of Hours Billed by Professionals and Paraprofessionals

for the Period February 1, 2022 through March 15, 20222

Timekeeper Position and Year 

Admitted to Practice

Hourly Billing 

Rate ($)3

Total Hours

Billed

Total Fees ($)

Michael Luskin Sr. Partner 1978 $900.00 4.50 $4,050.00

Stephan E. Hornung Jr. Partner 2008 $775.00 0.30 $232.50

Catherine D. Trieu Paralegal N/A $285.00 20.40 $5,814.00

TOTAL 25.20 $10,096.50

Summary of Legal Fees for the Period

February 1, 2022 through March 15, 20224

Project

Category

Total

Hours Billed

Total Fees

Requested ($)

Fee Applications 22.00 $ 7,216.50

Conflicts and Disclosure Issues5 3.20 $ 2,880.00

TOTAL 25.20 $10,096.50

2 These amounts reflect a total of 2.80 hours of time and $1,228.50 of fees which Luskin, Stern & Eisler LLP 

(“LS&E”) has voluntarily written off.

3 With the consent of the Oversight Board, LS&E adjusted its hourly rates on a timekeeper-by-timekeeper basis 

effective as of September 1, 2021. (See Third Notice of Proposed Hourly Rate Adjustment of Luskin, Stern & 

Eisler LLP, as Special Counsel to the Financial Oversight and Management Board for Puerto Rico, effective as of 

September 1, 2021 [Docket No. 17656]).

4 Because LS&E performs work for the Oversight Board on an ad hoc basis, the amount of time it bills in any given 

month can fluctuate substantially.

5 Following LS&E’s filing of the McKinsey Report on February 18, 2019 [Docket No. 5154], the Oversight Board 

asked LS&E to review and advise on various conflicts and disclosure issues involving vendors other than

McKinsey. Accordingly, LS&E has changed the name of this project category on its billing system from 

“McKinsey Report” to “Conflicts and Disclosure Issues.” This change is reflected in LS&E’s invoices.

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3

In accordance with the Court’s Third Amended Order Setting Procedures for Interim 

Compensation and Reimbursement of Expenses of Professionals [Docket No. 20546] 

(the “Interim Compensation Order”), Luskin, Stern & Eisler LLP (“LS&E”), special counsel to 

the Financial Oversight and Management Board for Puerto Rico (“Oversight Board”), hereby 

submits this Fifty-second Monthly Fee Statement for Compensation for Professional Services 

Rendered and Reimbursement of Expenses Incurred (the “Monthly Fee Statement”) for the 

period from February 1, 2022 through March 15, 2022 (the “Statement Period”). In support of 

the Monthly Fee Statement, LS&E respectfully represents as follows:

Relief Requested

1. LS&E submits this Monthly Fee Statement in accordance with the Interim 

Compensation Order. All services for which LS&E requests compensation were performed by

LS&E on behalf of the Oversight Board. 

2. LS&E submits the certification attached hereto as Exhibit A with respect 

to this Monthly Fee Statement and in accordance with the Interim Compensation Order. 

3. LS&E seeks compensation for professional services rendered and 

reimbursement of expenses incurred for the Statement Period in the amounts set forth below:

Total Fees $10,096.50

Total Expenses $ 0.00

Total $10,096.50

4. A detailed statement of hours spent by LS&E rendering legal services to 

the Oversight Board and disbursements made by LS&E during the Statement Period is attached 

hereto as Exhibit B.

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4

5. Pursuant to the Interim Compensation Order, LS&E seeks payment of 

$9,086.85 for the Statement Period, representing (a) ninety percent (90.00%) of the total fees for 

services rendered and (b) 100% of the total expenses incurred.

6

Notice and Objection Procedures

6. In accordance with the Interim Compensation Order, notice of the 

Monthly Fee Statement has been served upon the parties listed on the attached Exhibit C

(together, as further defined in the Compensation Order, the “Notice Parties”).

7. Pursuant to the Interim Compensation Order, objections to the Monthly 

Fee Statement, if any, must be filed and served upon LS&E, no later than April 29, 2022 at 

4:00 p.m. Atlantic Standard Time (the “Objection Deadline”), setting forth the nature of the 

objection and the specific amount of fees and expenses at issue.

8. If no objection to the Monthly Fee Statement is received by the Objection 

Deadline, the Debtors will pay to LS&E the amounts of fees and expenses identified in the 

Monthly Fee Statement.

9. To the extent an objection to the Monthly Fee Statement is received on or 

before the Objection Deadline, the Debtors will withhold payment of that portion of the payment 

requested to which the objection is directed and will promptly pay the remainder of the fees and 

expenses as set forth herein. To the extent such objection is not resolved, it shall be preserved 

and scheduled for consideration at the next interim fee application hearing.

6 LS&E reserves the right to seek an offsetting adjustment or “gross up” on account of any tax withholding pursuant 

to Act 257 amending the Puerto Rico Internal Revenue Code of 2011.

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5

Dated: White Plains, New York

April 19, 2022

Respectfully submitted,

/s/ Michael Luskin

Michael Luskin (admitted pro hac vice)

Lucia T. Chapman (admitted pro hac vice)

Stephan E. Hornung (admitted pro hac vice)

Luskin, Stern & Eisler LLP

50 Main Street

White Plains, New York 10606

Telephone: (212) 597-8200

Facsimile: (212) 597-8240

luskin@lsellp.com

chapman@lsellp.com

hornung@lsellp.com

Special Counsel to the Financial Oversight and 

Management Board for Puerto Rico

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EXHIBIT A

Certification of Michael Luskin in 

Compliance with Puerto Rico Law

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Objection Deadline: April 29, 2022 at 4:00 p.m. (AST)

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

PROMESA

Title III

No. 17-BK-03283 (LTS)

(Jointly Administered)

CERTIFICATION OF MICHAEL LUSKIN IN SUPPORT OF THE CONSOLIDATED 

FIFTY-FOURTH MONTHLY FEE STATEMENT OF LUSKIN, STERN & EISLER LLP,

AS SPECIAL COUNSEL TO THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO, FOR COMPENSATION FOR PROFESSIONAL 

SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES INCURRED FOR 

THE PERIOD FROM FEBRUARY 1, 2022 THROUGH MARCH 15, 2022

I, Michael Luskin, hereby certify that:

1. I am a member of the law firm of Luskin, Stern & Eisler LLP (“LS&E”), 

with offices located at 50 Main Street, White Plains, New York 10606. LS&E is special counsel 

to the Financial Oversight and Management Board for Puerto Rico (the “Oversight Board”) as 

representative of the Debtors in the above-captioned title III cases pursuant to section 315(b) of 

the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”).

2

 I have 

1 The Debtors in these jointly-administered Title III Cases, along with each Debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations and the last four (4) digits of each Debtor’s federal 

tax identification number, as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 

3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation 

(“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17 

BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (iv) Puerto Rico Highways and Transportation 

Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) Last Four Digits of Federal Tax ID: 3808); and (v) 

Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of 

Federal Tax ID: 3747).

2 PROMESA has been codified in 48 U.S.C. §§ 2101-2241.

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

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2

personal knowledge of all of the facts set forth in this certification except as expressly stated 

herein.

2. In accordance with the Third Amended Order Setting Procedures for 

Interim Compensation and Reimbursement of Expenses of Professionals entered April 12, 2022

[Docket No. 20546] (the “Interim Compensation Order”), this certification is made in support of 

the Consolidated Fifty-fourth Monthly Fee Statement of LS&E, as special counsel to the 

Oversight Board, dated April 19, 2022 (the “Monthly Fee Statement”), for compensation and 

reimbursement of expenses for the period of February 1, 2022 through and including March 15, 

2022 (the “Statement Period”).

3. With respect to the Monthly Fee Statement, I hereby certify that no public 

servant of the Department of Treasury is a party to or has interest in the gains or benefits derived 

from the contract that is the basis of this invoice. The only consideration for providing services 

under the contract is the payment agreed upon with the authorized representatives of the 

Oversight Board. The amount of this invoice is reasonable. The services were rendered and the 

corresponding payment has not been made. To the best of my knowledge, LS&E does not have 

any debts owed to the Government of Puerto Rico or its instrumentalities. All services 

performed by LS&E in connection with the Monthly Fee Statement were rendered in 

White Plains, New York.

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3

Dated: White Plains, New York

April 19, 2022

Respectfully submitted,

/s/ Michael Luskin

Michael Luskin (admitted pro hac vice)

LUSKIN, STERN & EISLER LLP

50 Main Street

White Plains, New York 10606

Telephone: (212) 597-8200

Facsimile: (212) 597-8240

luskin@lsellp.com

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EXHIBIT B

Time and Expense Records

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Bill #: 202112

Luskin, Stern & Eisler LLP

50 Main Street

White Plains, New York 10606

Telephone: (212) 597-8200

Fax: (212) 597-8240

March 15, 2022

Bill # 202112

Client/ Matter # 675-003

Tax ID 13-3524567

Attn: Arturo A. Ortiz

Financial Oversight and Management Board for Puerto Rico

PO Box 195556

San Juan, PR 009195556

Re: PROMESA Fee Applications

Professional Fees

Date Staff Description Hours Rate Amount

02/05/2021 ML B160/A105 Fee/Employment Applications/ Communicate 

(in firm) 

emails with C. Trieu re: outstanding receivables (Not 

charged: $0.00)

0.70 $0.00

02/18/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

[NOT BILLED] review January invoices re: Fifty-third 

Monthly Fee Statement (0.2); draft fee statement, 

declaration and objection statement re: same (0.8); revise 

Fifty-Second Monthly Fee Statement (0.1); finalize and 

submit Fifty-second and Fifty-third Monthly Fee Statements 

to J. El Koury for approval (0.3); submit fee statements to 

notice parties re: same (0.2)

1.60 $0.00

03/01/2022 CDT B160/A104 Fee/Employment Applications/ 

Review/analyze 

review Commonwealth docket and fee-related filings re: 

Fourteenth Interim Fee Application (0.3); FY 2021 firm 

blended rate analysis re: same (1.8)

2.10 $285.00 $598.50

03/02/2022 CDT B160/A104 Fee/Employment Applications/ 

Review/analyze 

review 16th amended case management procedures order 

and Fee Examiner memo on final fee app. process re: 

Fourteenth Interim Fee Application (0.4); draft notice of filing 

re: same (0.4)

0.80 $285.00 $228.00

03/02/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

[NOT BILLED] revise and finalize objection statement and 

declaration re: Fifty-second and Fifty-third Monthly Fee 

Statements (0.2); submit objection statement and 

declaration re: same (0.3)

0.50 $0.00

03/03/2022 CDT B160/A104 Fee/Employment Applications/ 

Review/analyze 

continue 2021 blended rate analysis re: Fourteenth Interim 

Fee Application (0.7); review status of payments re: same 

(0.1); payment and tax withholding analysis re: same (0.5)

1.30 $285.00 $370.50

$0.00

$0.00

$0.00

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Bill #: 202112

03/07/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

block-out initial draft re: Fourteenth Interim Fee Application 

(0.8); review fee-related filings (Fee Examiner report and 

order allowing 13th interim fees), monthly fee statements, 

prior interim fee applications and Fee Examiner 

communications re: same (0.7); fee analysis (timekeeper 

and project category totals, calculation of fees at retention 

rate, allowed amounts and total amounts paid) re: same 

(0.8)

2.30 $285.00 $655.50

03/08/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

continue fee analysis (blended rates and 2021 firm blended 

rates) re: Fourteenth Interim Fee Application (0.6); draft 

cover sheet, summary charts and exhibits re: same (1.3); 

begin draft fee application re: same (0.4)

2.30 $285.00 $655.50

03/09/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

continue draft re: Fourteenth Interim Fee Application (1.7); 

fee analysis (gross-up, payment and tax withholding) re: 

same (0.6)

2.30 $285.00 $655.50

03/10/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

complete initial draft fee application re: Fourteenth Interim 

Fee Application (2.7); related review of fee-related filings, 

Fee Examiner communications, monthly fee statements and 

prior interim fee applications re: same (0.5); review and cite 

check initial draft re: same (0.8); revise initial draft re: same 

(0.6)

4.60 $285.00 $1,311.00

03/11/2022 CDT B160/A104 Fee/Employment Applications/ 

Review/analyze 

review and reconcile payment of 13th interim holdback 

amount re: Fourteenth Interim Fee Application (0.2); 

correspondence with AAFAF (F. Rosado Mendez) on tax 

withholding discrepancy re: same (0.1); revise fee analysis 

charts re: same (0.2); revise initial draft fee application, 

cover sheet and summary charts re: same (0.3); review and 

compile exhibits, blended rate analysis, fee analysis and 

initial draft notice and fee application re: same (0.4); email 

initial drafts, exhibits and supporting analysis with summary 

to M. Luskin and S. Hornung re: same (0.3); 

correspondence with M. Luskin re: comments to initial draft 

of same (0.2)

1.70 $285.00 $484.50

03/11/2022 ML B160/A103 Fee/Employment Applications/ Draft/Revise 

revise fee application and email to C. Trieu re: 14th interim

0.50 $900.00 $450.00

03/14/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

revise draft per M. Luskn comments re: Fourteenth Interim 

Fee Application

0.40 $285.00 $114.00

03/15/2022 CDT B160/A103 Fee/Employment Applications/ Draft/Revise 

review additional payments received and update fee 

analysis charts re: Fourteenth Interim Fee Application (0.2); 

revise draft fee application, cover sheets and exhibits re: 

same (0.3); review and finalize notice of filing and 

application re: same (0.4); submit notice and application to 

G. Miranda (O'Neill Borges) for filing re: same (0.1); review

correspondence with G. Miranda re: same and notice of

withdrawal (0.1); review notice of withdrawal re: same (0.1)

1.20 $285.00 $342.00

03/15/2022 CDT B160/A104 Fee/Employment Applications/ 

Review/analyze 

review Fee Examiner memo re: final fee application process 

(0.3); correspondence with M. Luskin re: same (0.2); begin 

blocking out initial draft final fee application (0.9)

1.40 $285.00 $399.00

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Bill #: 202112

03/15/2022 SEH B160/A104 Fee/Employment Applications/ 

Review/analyze 

review fee application re: Fourteenth Interim

0.30 $775.00 $232.50

03/15/2022 ML B160/A104 Fee/Employment Applications/ 

Review/analyze 

review 14th fee application (0.3): emails with C. Trieu re: 

final fee application (0.2); review withdrawal notice re: 14th 

fee application (0.2); emails with G. Miranda re: notice of 

withdrawal (14th fee application) (0.1)

0.80 $900.00 $720.00

24.80 $7,216.50

BILLING SUMMARY:

TOTAL CHARGES: $7,216.50

TOTAL DUE: $7,216.50

Fee Summary

Hours Rate Total

 1.3

 0.7

20.4

 2.1

 0.3

$900.00

$ 0.00

$285.00

$ 0.00

$775.00

$1,170.00

$ 0.00

$5,814.00

$ 0.00

$ 232.50

Staff

Michael Luskin

Michael Luskin

Catherine Trieu

Catherine Trieu 

Stephan Hornung

Payment may be sent by wire to:

CITIBANK, N.A.

ABA#021000089

For Credit to Luskin, Stern & Eisler, LLP

Account # 6862748204

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Bill #: 202114

Luskin, Stern & Eisler LLP

50 Main Street

White Plains, New York 10606

Telephone: (212) 597-8200

Fax: (212) 597-8240

March 15, 2022

Bill # 202114

Client/ Matter # 675-008

Tax ID 13-3524567

Attn: Arturo A. Ortiz

Financial Oversight and Management Board for Puerto Rico

PO Box 195556

San Juan, PR 009195556

Re: Conflicts and Disclosure Issues

Professional Fees

Date Staff Description Hours Rate Amount

03/01/2022 ML L120/A104 Analysis/Strategy/ Review/analyze 

review latest McKinsey declaration and disclosure 

schedules (0.9); email with J. El Koury and A. Bonime-Blanc 

re: same (0.2); review changes to Interested Parties lists 

(0.5)

1.60 $900.00 $1,440.00

03/02/2022 ML L120/A106 Analysis/Strategy/ Communicate (with client) 

telephone call with L. Applegate (McKinsey) re: recent 

disclosures (0.4); email with J. El Koury re: same (0.1); 

review Schedule 1 (0.3); emails with Proskauer re: IP list 

(0.3)

1.10 $900.00 $990.00

03/14/2022 ML L120/A106 Analysis/Strategy/ Communicate (with client) 

telephone call with L. Applegate re: follow-up on McKinsey 

disclosures (0.3); telephone call with J. El Koury re: same 

(0.2)

0.50 $900.00 $450.00

3.20 $2,880.00

Fee Summary

Staff Hours Rate Total

Michael Luskin 3.2 $900.00 $2,880.00

BILLING SUMMARY:

TOTAL CHARGES: $2,880.00

TOTAL DUE: $2,880.00

Payment may be sent by wire to:

CITIBANK, N.A.

ABA#021000089

For Credit to Luskin, Stern & Eisler, LLP

Account # 6862748204

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