UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

 

 ) PROMESA

In re ) 

) 

Title III 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO

et al.,

1

) 

) 

) 

) 

) 

) 

) 

No. 17-BK-3283 (LTS) 

(Jointly Administered) 

Re: 23061, 22847, 23035 

Debtors. ) 

 ) 

 

SECOND SUPPLEMENTAL DECLARATION OF KATHERINE STADLER IN 

SUPPORT OF TENTH INTERIM AND CONSOLIDATED SEMIANNUAL 

APPLICATION OF THE FEE EXAMINER AND GODFREY & KAHN, S.C. 

I, Katherine Stadler, hereby declare under penalty of perjury: 

1. I am a shareholder with Godfrey & Kahn, S.C. (“Godfrey & Kahn”), a 

law firm with its principal offices at 833 East Michigan Street in Milwaukee, Wisconsin, 

and One East Main Street in Madison, Wisconsin, and other offices in Wisconsin and in 

1

 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number and the last 

four (4) digits of each Debtor’s federal tax identification number, as applicable, are the (i) Commonwealth 

of Puerto Rico (the “Commonwealth”) (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) Puerto Rico Highways and 

Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567-LTS) (Last Four Digits of Federal 

Tax ID: 3808); (iv) 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); (v) 

Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780-LTS) (Last Four 

Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy 

Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed 

as Bankruptcy Case numbers due to software limitations). 

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Washington, D.C. I am authorized to make this Declaration on behalf of myself, the Fee 

Examiner Brady C. Williamson, and Godfrey & Kahn. 

2. This Declaration supplements the Tenth Interim and Consolidated 

Semiannual Application of the Fee Examiner and Godfrey & Kahn, S.C., Counsel to the 

Fee Examiner, for Allowance of Compensation for Services Rendered and 

Reimbursement of Expenses for the Period from April 1, 2022 Through September 30, 

2022 [Dkt. No. 22847 in Case No. 17-3283] (the “Tenth Semiannual Fee Application”) 

and the Supplemental Declaration of Katherine Stadler in Support of Tenth Interim and 

Consolidated Semiannual Application of the Fee Examiner and Godfrey & Kahn, S.C.

[Dkt. No. 23035] (the “Supplemental Declaration”) based on my personal knowledge. 

If called to testify, I could and would testify competently to the written statements made 

in this Declaration. 

3. On November 11, 2022, through Puerto Rico co-counsel, I filed the Tenth 

Semiannual Fee Application, requesting $893,779.30 in fees and $103.90 in expenses 

incurred for the period April 1, 2022 through September 30, 2022, and $116,526.30 in 

previously withheld taxes. 

4. On December 8, 2022, the Court issued the Order Concerning Tenth 

Interim and Consolidated Semiannual Application of the Fee Examiner and Godfrey & 

Kahn, S.C. [Dkt. No. 23026], ordering the Fee Examiner to clarify the basis for the tax 

refund portion of the Tenth Semiannual Fee Application. 

5. On December 9, 2022, I filed the Supplemental Declaration. On 

December 13, the Court issued the Order Concerning Responses to the Tenth Interim and 

Consolidated Semiannual Application of the Fee Examiner and Godfrey& Kahn, S.C.

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[Dkt. No. 23052], ordering responses to the Tenth Semiannual Fee Application and the 

Supplemental Declaration no later than 5:00 p.m. (Atlantic Standard Time) on 

December 13, 2022. 

6. Also on December 13, 2022, the Fee Examiner filed the Stipulation to 

Adjourn the Discrete Matter of Repayment of the Tax Withholdings in Connection with 

Their Tenth Interim and Consolidated Semiannual Application for Allowance of 

Compensation for Services Rendered and Reimbursement of Expenses for the Period 

from April 1, 2022 Through September 2022 [Dkt. No. 22847] Set for Hearing on 

December 14-15, 2022, Omnibus Hearing [sic] [Dkt. No. 23059] to allow Hacienda, to 

evaluate requested refund of tax withholding and to allow the parties to seek a consensual 

resolution. 

7. Finally, on December 13, 2022, the Court entered the Order Allowing 

Tenth Interim and Consolidated Semiannual Application of the Fee Examiner and 

Godfrey & Kahn, S.C. But Adjourning Only the Tax Withholding Issue [Dkt. No. 23061]. 

8. Subsequently, through counsel for AAFAF, Hacienda has informed the 

Fee Examiner that the taxes had been mistakenly withheld. Hacienda issued a full refund 

of the mistakenly withheld taxes on December 14, 2022. Godfrey & Kahn, S.C. now 

holds those funds in trust pending further order of the Court. 

9. In light of the above, and unless the Court orders otherwise, the adjourned 

portion of the Tenth Semiannual Interim Fee Application may be removed from the 

February 1, 2023 omnibus hearing agenda. Counsel for the Oversight Board has been 

advised as such. 

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 Dated this 19th day of January, 2023. 

GODFREY & KAHN, S.C. 

 s/ Katherine Stadler 

Katherine Stadler 

One East Main Street, Suite 500 

Madison, Wisconsin 53703 

Telephone: (608) 257-3911 

Facsimile: (608) 257-0609 

E-mail: kstadler@gklaw.com 

Counsel to the Fee Examiner

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Dated: January 19, 2023. 

WE HEREBY CERTIFY that on this date, we electronically filed the foregoing 

declaration with the Clerk of the Court using the CM/ECF system that will send 

notification of such filing to all attorneys of record registered in the use of the CM/ECF 

system. 

EDGE LEGAL, LLC 

 /s/ Eyck O. Lugo 

Eyck O. Lugo 

252 Ponce de León Avenue 

Citibank Tower, 12th Floor 

San Juan, Puerto Rico 00918 

Telephone: (787) 522-2000 

Facsimile: (787) 522-2010 

Puerto Rico Counsel for Fee Examiner 

 GODFREY & KAHN, S.C. 

 /s/ Katherine Stadler

Katherine Stadler, Admitted Pro Hac Vice 

One East Main Street, Suite 500 

P.O. Box 2719 

Madison, Wisconsin 53701-2719 

Telephone: (608) 257-3911 

Facsimile: (608) 257-0609 

E-mail: bwilliam@gklaw.com 

 kstadler@gklaw.com 

Attorneys for the Fee Examiner

28416088.2 

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