Hearing Date: February 1, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) 

 Objection Deadline: December 5, 2022 at 3:00 p.m. (ET) / 4:00 p.m. (AST) 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

_____________________________________________/

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

SUMMARY COVER SHEET FOR THE NINTH & FINAL FEE APPLICATION OF 

GENOVESE JOBLOVE & BATTISTA, P.A., AS SPECIAL LITIGATION COUNSEL TO 

OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES 

RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD OF 

JANUARY 1, 2022 – JULY 31, 2022 

All Fees and Services included in this Final Application were performed outside of Puerto Rico 

SUMMARY COVER SHEET

Name of applicant: Genovese Joblove & Battista, P.A. (“GJB”) 

Authorized to provide 

professional services to: 

Special Litigation Counsel for the Official Committee 

of Unsecured Creditors (the “Committee”)2

 

1

 The Debtors in these 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) 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), (iii) Puerto Rico 

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

Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (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). 

2

 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and 

COFINA. 

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2

Name of Client: Official Committee of Unsecured Creditors of all 

Title III Debtors (other than COFINA and PBA) 

Petition Date: May 3, 20173

 Date of retention: May 31, 2019, effective as of April 16, 2019 

 [Docket No. 7181] 

 Period for which compensation 

and reimbursement are sought:

January 1, 2022 – July 31, 2022 (the “Application 

Period”) 

 Amount of final compensation 

 sought as actual, reasonable, and 

 necessary: 

$147,175.50 4

 Amount of interim expense 

 reimbursement sought as actual, 

 reasonable, and necessary: 

$11,922.93

Are your fee or expense totals 

different from the sum of 

previously-served monthly 

statements for the Application 

Period? 

No. 

Total compensation approved by 

interim order to date: 

$657,907.05 (First Interim Fee Order ECF No. 9046) 

$1,339,434.84 (Second Interim Fee Order ECF No. 13296) 

$1,171,906.40 (Third Interim Fee Order ECF No. 13824) 

$887,215.20 (Fourth Interim Fee Order ECF No. 15971) 

$499,302.23 (Fifth Interim Fee Order DE 17646) 

$327,033.50 (Sixth Interim Fee Order DE 18371) 

$163,364.88 (Seventh Interim Fee Order DE 20412) 

$278,543.20 (Eighth Interim Fee Order DE 22727) 

 

3

 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. 

4 The full amount of fees incurred by GJB during the Application Period total $147,175.50. GJB agreed taking a 

voluntary fee reduction equal to 20% in the amount of $29,435.10 and, thereby, seeks allowance and payment of fees 

in the amount of $117,740.40. By the time of the hearing on this Application, a portion of this amount should have 

been paid by the Debtors pursuant to the Interim Compensation Order, and GJB reserves its rights to seek relief from 

the Court to the extent any outstanding fees and expenses that are due and payable are not paid on the terms set forth 

in the Interim Compensation Order. 

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Total expenses approved by 

interim order to date: 

$3,848.56 (First Interim Fee Order ECF No. 9046) 

$43,602.27(Second Interim Fee Order ECF No. 13296)

$33,296.95 (Third Interim Fee Order ECF 13824) 

$54,671.58 (Fourth Interim Fee Order ECF No. 15971) 

$31,381.55 (Fifth Interim Fee Order DE 17646) 

$37,092.49 (Sixth Interim Fee Order DE 18371) 

$30,614.97 (Seventh Interim Fee Order DE 20412) 

$19,344.38 (Eighth Interim Fee Order DE 22727) 

Total allowed compensation paid 

to date: 

$5,324,707.30 

Total allowed expenses paid to 

date: 

$253,852.75 

Blended rate in this Application 

for all attorneys: 

$487.92/hour5

Blended rate in this Application 

for all timekeepers: $430.59/hour

Total compensation sought in this 

Application already paid pursuant 

to a monthly compensation order 

but not yet allowed: 

$64,368.00 

Total expenses sought in this 

Application already paid pursuant 

to a monthly compensation order 

but not yet allowed. 

$0.00 

Total time expended for 

fee application preparation 

during the Application 

Period: 

87.80hrs 

Total compensation requested 

for fee application preparation 

during the Application Period: 

$37,934.00 

Number of professionals included

in this Application: 

12 

 If applicable, number of 

 professionals in this Application 

 not included in a staffing plan 

 approved by the client: 

N/A 

 

5

 The calculation of the blended hourly rates reflected in this Application Period does not take into account GJB’s 

agreement to reduce its fees by an amount equal to 20% of its hourly rates. 

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4

If applicable, difference 

between fees budgeted and 

compensation sought for the 

Application Period: 

N/A 

Number of professionals billing 

fewer than 15 hours to the case 

during the Application Period: 

5 

Are any timekeeper’s hourly rates 

higher than those approved or 

disclosed at retention? If yes, 

calculate and disclose the total 

compensation sought in this 

Application using the rates 

originally disclosed in the retention 

application: 

None. 

 SUMMARY OF PRIOR MONTHLY FEE STATEMENTS FOR THE COMPENSATION 

PERIOD JANUARY 1, 2022 THROUGH JULY 31, 2022

Date Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested

(90%) 

Holdback

(10%) Expenses Requested

Fees Paid Expenses Paid 

June 30, 

2022 

January 1, 2022 – 

January 31, 2022 

$89,400.00 $17,880.00 $64,368.00 $7,152.00 $0.00 $64,368.00 $0.00 

Summary of Amounts Requested to be Paid 

Total Unpaid Fees: $53,372.40

Total Unpaid Expenses: $11,922.93

Total 10% Holdback on Fees: $32,752.08

Reimbursement for 29% Tax Withholding: N/A

Reimbursement for 1.5% Government Contribution: $N/A 

Less expenses voluntarily reduced herein: N/A

Total Amount Requested to be Paid in Fees and Expenses for this period: $65,295.33.

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5

PRIOR INTERIM FEE APPLICATIONS 

First Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees Requested 

(90%) 

Holdback 

(10%) 

Expenses 

Requested

7/15/19 7994 April 19, 2019- 

May 31, 2019 

$691,742.25 $553,393.80 $498,054.42 $55,339.38 $10,373.05 

Second Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested

11/15/19 9213 June 1, 2019- 

September 30, 

2019 

$1,728,948.00 $1,383,158.40 $1,244.842.56 $138,315.84 $43,602.27 

Third Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested

3/15/20 12409 October 1, 2019- 

January 31,2020

$1,494,787.75 $1,195,830.20 $1,076,247.18 $119,583.02 $33,296.95 

Fourth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

11/16/20 15142 February 1,2020 

-August 31,2020

$1,124,542.00 $899,633.60 $809,670.24 $89,963.36 $56,687.18 

Fifth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

03/15/21 16068 September 1 

2020 - January 

31, 2021

$499,302.23 $399,441.78 $359,497.62 $39,944.16 $31,381.55 

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Sixth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

07/15/21 17365 February 1, 

2021-April 30, 

2021

$327,033.50 $261,626.80 $235,464.12 $26,162.68 $37,092.49 

Seventh Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

11/15/21 19219 June 1, 2021 – 

September 30, 

2021

$204,609.00 $163,687.20 $147,318.48 $16,368.72 $33,089.07 

Eighth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

08/31/22 21992 October 1, 2021 

– December 31, 

2021

$349,725.50 $279,780.40_ _____ $251,802.36_

___ $25,180.24

____ $19,344.38 

SUPPORTING CERTIFICATION, EXHIBITS, AND SCHEDULES

In accordance with the U.S. Trustee Guidelines, at the end of this Application are the 

following Exhibits and Schedules: 

EXHIBIT A CERTIFICATION OF MARIAELENA GAYO-GUITIAN IN SUPPORT 

OF APPLICATION 

EXHIBIT B CUSTOMARY AND COMPARABLE COMPENSATION 

DISCLOSURES 

EXHIBIT C SUMMARY OF TIMEKEEPERS INCLUDED IN THIS APPLICATION 

EXHIBIT D BUDGETS AND STAFFING PLANS FOR APPLICATION PERIOD 

EXHIBIT E SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

 CATEGORY 

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EXHIBIT E-1 SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

 CATEGORY AS COMPARED TO BUDGET 

EXHIBIT E-2 SUMMARY OF EXPENSE REIMBURSEMENT REQUESTED BY 

CATEGORY 

EXHIBIT F BREAKDOWN OF COMPENSATION AND EXPENSE 

REIMBURSEMENT REQUESTED AND BY WHETHER SERVICES 

WERE RENDERED IN PUERTO RICO OR OUTSIDE PUERTO RICO 

SCHEDULE 1 LIST OF PROFESSIONALS BY MATTER 

SCHEDULE 2 MONTHLY STATEMENTS COVERED IN APPLICATION 

SCHEDULE 3 PROPOSED ORDER 

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 Hearing Date: February 1, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) 

 Objection Deadline: December 5, 2022 at 3:00 p.m. (ET) / 4:00 p.m. (AST) 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.6

_____________________________________________/

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

NINTH AND FINAL APPLICATION OF GENOVESE JOBLOVE & BATTISTA, P.A, 

SPECIAL LITIGATION COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR ALLOWANCE OF COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR PERIOD FROM 

JANUARY 1, 2022 THROUGH JULY 31, 2022

To The Honorable United States District Judge Laura Taylor Swain: 

Genovese Joblove & Battista, P.A. (“GJB”), special litigation counsel to the Official 

Committee of Unsecured Creditors (the “Committee”), in the above-captioned Title III cases (the 

“Title III Cases”)7 hereby submits its Ninth & Final Fee Application (the “Application”) for 

allowance of compensation for professional services rendered, and reimbursement for actual and 

 

6 The Debtors in these 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) 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), (iii) Puerto Rico 

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

Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (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). 

7 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and 

COFINA.

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necessary expenses incurred in connection with such services, for the period from January 1, 2022 

through July 31, 2022 (the “Application Period”). 

On February 15, 2022, former GJB attorneys John Arrastia (“J. Arrastia”), Jesus Suarez 

(“J. Suarez”) and Angelo Castaldi (“A. Castaldi”) formed the law firm, Continental, PLLC 

(“Continental”) and took over representation of the Committee as special litigation counsel for the 

Committee. In connection with the foregoing, Arrastia, Suarez and Castaldi filed Notices of 

Appearance and Request for Notices and Papers [D.E. 20136]. On February 28, 2022, Continental 

filed their Informative Motion Regarding Change of Firm and Address, and Proposed Substitution 

of Counsel [Docket No. 20225]. As a result of the foregoing, GJB no longer is representing any 

party in these proceedings and thereby submits its Ninth and Final Fee Application. GJB submits 

this Application pursuant to sections 316 and 317 of the Puerto Rico Oversight, Management and 

Economic Stability Act of 2016 (“PROMESA”),8 section 503(b) of Title 11, United States Code 

(the “Bankruptcy Code”) as made applicable to these cases by section 301(a) of PROMESA, Rule 

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

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

“Local 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 

Larger Chapter 11 Cases issued by the Executive Office for the United States Trustee, 28 CFR 

Part 58, Appendix B (the “Guidelines”), and in accordance with this Court’s the First Amended 

Order Setting Procedures for Interim Compensation and Reimbursement of Expenses of 

Professionals (“Interim Compensation Order”) [Docket No. 1715]; the Second Amended Order 

Setting Procedures for Interim Compensation and Reimbursement of Expenses of Professionals 

(“Second Interim Compensation Order”) [Docket No. 3269]; the Fee Examiner’s November 10, 

 

8 References to PROMESA are references to 48 U.S.C. §§ 2101 et. seq.

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2017 Memorandum (the “Fee Examiner Memorandum”); the Court’s Order on Fee Examiner’s 

Motion to Impose Presumptive Standards and Timeliness requirements for Professional Fee 

Applications (the “Presumptive Order”) [Docket No. 3932]; the Court’s Order Imposing 

Additional Presumptive Standards: Rate Increases and the Retention of Expert Witnesses or Other 

Sub-retained Professionals (the “Revised Presumptive Order”) [Docket No. 7678] and the Third 

Amended Order Setting Procedures for Interim and Final Compensation and Reimbursement of 

Expenses of Professionals [Docket No. 20546] (“Third Interim Compensation Order”). In support 

of the Application, GJB submits the Certification of Mariaelena Gayo-Guitian (the “Gayo-Guitian 

Certification”), attached as Exhibit A, and respectfully represents as follows: 

JURISDICTION AND VENUE 

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

Final 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 Third 

Interim Compensation Order. Attached as Exhibit A is a certification regarding compliance with 

the Local Guidelines. 

3. This Application is consistent with the Third Interim Compensation Order (as 

defined below), Local Rule 2016-1, and Appendix B of the United States Trustee’s Guidelines for 

Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. 

§ 330 by Attorneys in Larger Chapter 11 Cases (the “U.S. Trustee Guidelines”). To the extent 

necessary, GJB requests a waiver for cause shown of any requirements not met by this 

Application.9

 

9

 The Committee and GJB reserve all rights as to the relevance and substantive legal effect of the U.S. Trustee 

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BACKGROUND 

 A. Case Background

4. On May 3, 2017, the Oversight Board commenced a Title III case for the 

Commonwealth of Puerto Rico by filing a voluntary petition for relief pursuant to section 304(a) 

of PROMESA (the “Commonwealth Title III Case”). Thereafter, the Oversight Board commenced 

a Title III case for each of COFINA, the Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico (the “ERS Title III Case”), the Puerto Rico Highways and 

Transportation Authority (the “HTA Title III Case”), and the Puerto Rico Electric Power Authority 

(the “PREPA Title III Case”) (and together with the Commonwealth Title III Case, the “Title III 

Cases”).10 By orders dated June 29, 2017 [Docket No. 537] and October 6, 2017 [Docket No. 

1417], the Court approved the joint administration of the Title III Cases.

5. On June 15, 2017, the Office of the United States Trustee for the District of Puerto 

Rico (the “U.S. Trustee”) filed a Notice Appointing Creditors Committee for Unsecured Creditors 

[Docket No. 338]. Thereafter, the U.S. Trustee modified the composition of the Committee 

membership [Docket Nos. 1171, 3058, and 3947], such that, currently, the members of the 

Committee are the American Federation of Teachers, Baxter Sales and Distribution Puerto Rico

Corp., Doral Financial Corporation, Genesis Security Services, Inc., Service Employees 

International Union, Tradewinds Energy Barceloneta, LLC, and Unitech Engineering Group, S.E. 

(the “Committee Members”) [Docket No. 3947]. 

6. On August 25, 2017, the U.S. Trustee filed an Amended Notice of Appointment of 

Official Committee of Unsecured Creditors [Docket No. 1171], which expanded the role of the 

Committee to be the official committee for the HTA Title III Case, the ERS Title III Case, and the 

 

Guidelines with respect to any application for compensation in these cases.

10 Unless otherwise indicated, references to docket numbers shall be to the docket of the Commonwealth Title III Case. 

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PREPA Title III Case. 

B. Retention of Genovese Joblove & Battista, P.A. 

7. On April 16, 2019, the Committee selected GJB as proposed special litigation 

counsel to the Committee in connection with the evaluation and analysis of potential causes of 

action and representation as co-plaintiff in the filing and prosecution of certain claims and causes 

of action to be asserted against certain parties involved in the offering of (a) the Commonwealth’s 

General Obligation bonds (“GO Bonds”), (b) bonds issued by the Public Buildings Authority 

(“PBA”), and (c) bonds issued by ERS (“ERS”), including bond counsel, disclosure counsel, 

underwriters, underwriters’ counsel, swap counterparties, or auditors (collectively, the “Financial 

Party Targets”). 

8. The retention of GJB as special litigation counsel was necessary and appropriate 

because the Committee’s primary counsel, Paul Hastings, LLP (“Paul Hastings”) represents certain 

of the Financial Party Targets (or their affiliates) in matters unrelated to the Title III Cases. 

9. On April 26, 2019, the Court approved the Stipulation and Agreed Order By and 

Among Financial Oversight and Management Board, Its Special Claims Committee, and Official 

Committee of Unsecured Creditors to Joint Prosecution of Debtor Causes of Action [Doc No. 6524 

] (the “Joint Prosecution Stipulation”). In connection with the prosecution of such claims or causes 

of action, the Oversight Board agreed to the appointment of the members of the Special Claims 

Committee of the Oversight Board (“Special Claims Committee”), on the one hand, and the 

Committee, on the other hand, as co-trustees and co-plaintiffs with respect to the Co-Plaintiff 

Adversary Proceedings. 

10. As set forth in the Engagement Agreement dated April 30, 2019, GJB was retained 

by and authorized to represent the Committee as special litigation counsel and conflicts counsel in 

connection with, among other matters, the evaluation and analysis of potential causes of action 

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and representation as co-plaintiff in the filing and prosecution of certain claims and causes of 

action to be asserted against certain parties involved in the involved in the offering of (a) the 

Commonwealth’s General Obligation bonds, (b) bond issued by the Public Buildings Authority, 

and (c) bonds issued by ERS, including underwriters, underwriters’ counsel, swap counterparties, 

disclosure counsel, and auditors (collectively, the “Financial Party Targets”). 

11. On April 30, 2019, the Committee filed the Application for Order Pursuant to 

Bankruptcy Code Section 1103(a) and Local Bankruptcy Rule 2014-1(e) Authorizing Employment 

and Retention of Genovese Joblove & Battista, P.A. as Special Litigation Counsel to Official 

Committee of Unsecured Creditors, Effective as of April 16, 2019 [Docket No. 6661] (the “GJB 

Employment Application”). 

12. On May 31, 2019, the Court entered the Order Authorizing Employment and 

Retention of Genovese, Joblove & Battista, P.A. as Special Litigation Counsel to Official 

Committee of Unsecured Creditors, Pursuant to Bankruptcy Code Section 1103(A) and Local Rule 

2014-1(e), Effective as of April 16, 2019 [Docket No. 7181] (the “Retention Order”). 

13. GJB’s retention extends to the representation of the Committee as the official 

committee for the HTA Title III Case, the ERS Title III Case, and the PREPA Title III Case. In 

particular, the Retention Order provided that “[t]he retention of GJB, as counsel to the Committee, 

shall be deemed to apply to the representation of the Committee if ever enlarged to include 

unsecured creditors of other debtors, without the need to obtain a modification of this Order.”

14. The Retention Order authorized GJB to be compensated on an hourly basis and 

reimbursed for actual and necessary out-of-pocket expenses pursuant to sections 316 and 317 of 

PROMESA, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct. The 

Retention Order further provides that “[p]ursuant to Bankruptcy Code section 503(b)(1), made 

applicable by PROMESA section 301(a), the fees and expenses of GJB shall be an administrative 

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expense.” In addition, as provided in the Retention Order, the Committee has consented to the 

Debtors’ payment of GJB’s allowed fees and expenses. 

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 (the “Interim Compensation 

Order”) [Docket 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 and 

Bankruptcy Code Section 105(a) Appointing a Fee Examiner and Related Relief [Docket No. 

1416] (the “Fee Examiner Order”). The Court appointed Brady Williamson as the Fee Examiner 

in the Title III Cases. 

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 [Docket 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 [Docket 

No. 1715]. 

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

3, 2018, the Fee Examiner issued a supplemental memorandum (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 [Docket No. 3032] (the “Motion to Amend the Fee Examiner Order”). 

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

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

Interim Compensation Order [Docket 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 (“Second Interim 

Compensation Order”) [Docket No. 3269]. 

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 [Docket No. 3324] (the “Amended Fee Examiner Order”). 

24. On June 26, 2019, the Court entered the Order Imposing Additional Standards: 

Rate Increases and the Retention of Expert Witnesses or Other Sub-Retained Professionals 

[Docket No. 7678]. 

25. On April 12, 2022, the Court entered the Third Amended Order Setting Procedures 

for Interim Compensation and Reimbursement of Expenses of Professionals (the “Third Interim 

Compensation Order”) [Doc. No. 20546], and in accordance therewith, GJB and other 

professionals retained in these Title III Cases were authorized to serve upon the parties identified 

therein (the “Notice Parties”) monthly fee statements (the “Monthly Fee Statements”). 

26. Pursuant to the Third Amended Interim Compensation Order, the Notice Parties 

have ten (10) 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 

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27. In addition to the Monthly Fee Statements, the Third 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 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(d)). 

28. On July 15, 2019, GJB filed its First Interim Fee Application for the period from 

April 16, 2019 through May 31, 2019 [ECF No. 7994] (the “First Interim Fee Application”). The 

hearing on the First Interim Fee Application was held on October 30, 2019 at 9:30 a.m. 

29. On October 29, 2019, the Court entered the Omnibus Order Awarding Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Sixth Compensation Period from February 1, 2019 through May 31, 2019 [ECF No. 9046] 

(the “First Interim Fee Order”). Pursuant to the First Interim Fee Order, GJB was awarded 

$657,907.05 in fees and reimbursement of expenses in the amount of $3,848.56. 

30. On November 15, 2019, GJB filed its Second Interim Fee Application for the period 

from June 1, 2019 through September 30, 2019 [ECF No. 9213] (the “Second Interim Fee 

Application”). The hearing on the Second Interim Fee Application was held on March 4, 2020 at 

9:30 a.m. and was continued to April 22, 2020 at 9:30 a.m. 

31. On June 1, 2020, the Court entered the Second Supplemental Omnibus Order 

Awarding 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 [ECF No. 13296] (the “Second Interim Fee Order”). Pursuant to the 

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Second Interim Fee Order, GJB was awarded $1,339,434.84 in fees and reimbursement of 

expenses in the amount of $43,602.27. 

32. On March 16, 2020, GJB filed its Third Interim Fee Application for the period from 

October 1, 2019 through January 31, 2020 [ECF No. 12409] (the “Third Interim Fee Application”). 

The hearing on the Third Interim Fee Application was held on July 29, 2020 at 9:30 a.m. [ECF 

No. 12410]. 

33. On July 24, 2020, the Court entered the 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] (the “Third Interim Fee Order”). Pursuant to 

the Third Interim Fee Order, GJB was awarded $1,171,906.40 in fees and reimbursement of 

expenses in the amount of $33,296.95. 

34. On November 16, 2020, GJB filed its Fourth Interim Fee Application for the period 

from February 1, 2020 through August 31, 2020 [ECF No. 15142] (the “Fourth Interim Fee 

Application”). 

35. On March 8, 2021, the Court entered the Omnibus Order Awarding (I). Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Eighth 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] (the “Fourth Interim Fee Order”). Pursuant 

to the Fourth Interim Fee Order, GJB was awarded $887,215.80 in fees and reimbursement of 

expenses in the amount of $54,671.58. 

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36. On April 15, 2021, GJB filed its Fifth Interim Fee Application for the period from 

September 1, 2020 through January 31, 2021 [ECF No. 16068] (the “Fifth Interim Fee 

Application”). 

37. On August 3, 2021, the Court entered the Omnibus Order Awarding (I). 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] (the “Fifth Interim Fee Order”). Pursuant to the Fifth Interim Fee Order, GJB 

was awarded $393,780.03 in fees and reimbursement of expenses in the amount of $28,860.55. 

38. On April 15, 2021, GJB filed its Sixth Interim Fee Application for the period from 

February 1, 2021-May 1, 2021 [ECF No. 17365] (the “Sixth Interim Fee Application”). 

39. On October 4, 2021, the Court entered the Omnibus Order Awarding (I). 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] (the “Sixth Interim Fee Order”). Pursuant to the Sixth Interim Fee Order, GJB was 

awarded $260,272.72 in fees and reimbursement of expenses in the amount of $35,727.69. 

40. On November 15, 2021, GJB filed its Seventh Interim Fee Application for the 

period from June 1, 2021 through September 30, 2021 [ECF No. 19219] (the “Seventh Interim Fee 

Application”). 

41. On March 18, 2022, the Court entered the 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. 20412] (the “Seventh Interim Fee Order”). Pursuant to the Seventh Interim Fee Order, 

GJB was awarded $163,364.88 in fees and reimbursement of expenses in the amount of 

$30,614.97. 

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42. On August 31, 2022, GJB filed its Eighth Interim Fee application for the period 

from October 1, 2021 – December 31, 2021 [ECF No. 21992] (the “Eighth Interim Fee 

Application”). 

43. On October 28, 2022, the Court entered the Supplemental 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. 22727] (the “Eighth Interim Fee Order”). Pursuant to the Eighth 

Interim Fee Order, GJB was awarded $278,543.20 in fees and reimbursement of expenses in the 

amount of $19,344.38. 

COMPENSATION AND REIMBURSEMENT REQUEST

44. By this Application, GJB seeks an order authorizing (a) allowance of final 

compensation for professional services rendered to the Committee during the Application Period 

in the aggregate amount of $147,175.50 and (b) allowance of reimbursement of actual and 

necessary expenses incurred by GJB in the aggregate amount of $11,922.93 . These amounts were 

for legal services provided to the Committee in connection with the Commonwealth Title III case. 

45. During the Application Period, GJB attorneys and paraprofessionals expended a 

total of 341.80 hours for which compensation is requested. All services rendered and expenses 

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

on behalf of the Committee. 

46. The Committee has approved the amounts requested by GJB for services performed 

and expenses incurred in each of the monthly statements submitted to the Notice Parties as 

outlined in the Third Interim Compensation Order. 

47. During the Application Period, GJB submitted one (1) Monthly Fee Statement. The 

Monthly Fee Statement for the period from January 1, 2022 - January 31, 2022 was submitted and 

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served on the Notice Parties on June 30, 2022 (the “Monthly Fee Statement”) a copy of which is 

attached as Schedule 2. The objection deadline for the Monthly Fee Statement was July 11, 2022. 

GJB received no objection to the Monthly Fee Statement. 

48. As of the date of the filing of this Application, GJB has received payment for fees 

and costs of $64,368.00 for services rendered during the Application Period for the month of 

January, 2022. 

49. As a courtesy to the Committee and based on circumstances unique to the Title III 

Case, during the Application Period GJB voluntarily applied a 20% discount of its hourly rates 

totaling $29,435.10. For details regarding the waived fees, please see the Certification of 

Mariaelena Gayo-Guitian filed concurrently. 

50. By this Application, GJB requests allowance of all fees and expenses incurred for 

services rendered during the Application Period. At this time, GJB seeks approval and payment 

of (a) 100% of its fees for services invoiced during the Application Period and (b) 100% of 

expenses invoiced during the Application Period. The time billed by these timekeepers was 

reasonable, and GJB reserves the right to seek allowance and payment of these fees based on the 

facts and circumstances of these cases, including, without limitation, if objections are interposed 

to the allowance or payment of GJB’s fees and expenses. 

51. There is no agreement or understanding between GJB and any other person other 

than the attorneys, employees, and staff of GJB, for the sharing of compensation to be received 

for services rendered in these cases. 

52. GJB maintains computerized records, in the form of monthly statements, of the time 

spent by all GJB’s attorneys and paraprofessionals in connection with its representation of the 

Committee. The monthly statements are in the same form regularly used by GJB to bill its clients 

for services rendered and include the date that the services were rendered, a detailed, and 

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contemporaneous narrative description of the services provided, the amount of time spent for each 

service, and the designation of the professional who performed the service. 

53. The fees charged by GJB in the Title III Case are billed in accordance with its 

existing billing rates and procedures in effect during the Application Period. The rates GJB 

charges for the services rendered by its professionals and paraprofessionals in the Title III Case 

are comparable to the rates GJB charges for professional and paraprofessional services rendered 

in comparable non-bankruptcy related matters. 

54. GJB’s rates are set at a level designed to fairly compensate GJB for the work of its 

attorneys and paraprofessionals to cover fixed and routine overhead expenses. GJB operates in a 

national marketplace for legal services in which rates are driven by multiple factors relating to the 

individual lawyer, his or her area of specialization, the firm’s expertise, performance and 

reputation, the nature of the work involved, and other factors. Accordingly, GJB set its rates for 

attorneys and paraprofessionals both in the restructuring group and related litigation groups within 

the firm by reference to market information and market adjustments by firms considered to be 

industry peers. Based on this and reviews of contemporaneous time records and fee applications 

filed in other cases, GJB’s endeavors to set the hourly rates for its attorneys and paraprofessionals 

at levels comparable to those of its principal competitor firms. 

55. As is customary, and as permitted pursuant to paragraph 2 of the Retention Order, 

every year GJB reviews its rate structure and, when appropriate, adjusts its hourly rates based 

upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market 

for legal services, (iii) the rates charged for comparable non-bankruptcy services, and (iv) the 

firm’s analysis of the hourly rates being charged by professionals in other law firms. 

56. GJB’s professional services during the Application Period required an aggregate 

expenditure of 341.80 recorded hours by GJB’s attorneys and paraprofessionals broken down as 

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follows: partners (172.40), associates (115.10), and paraprofessionals (54.30). During the 

Application Period, GJB’s billing rates for attorneys rendering services in this matter ranged from 

$305.00 to $765.00 per hour. As a courtesy to the Committee, no rate increases were made in 

January 2022 for the incoming year. 

57. To the extent that time or disbursement charges for services rendered or 

disbursements incurred relate to the Application Period, but were not processed before the 

preparation of this Application, or GJB has for any other reason not sought compensation or 

reimbursement with respect to such services or expenses, GJB reserves the right to request 

additional compensation for such services, and reimbursement of such expenses, in a supplemental 

or future application. 

58. Pursuant to, and consistent with, the relevant requirements of the Guidelines, as 

applicable, the following exhibits are attached hereto and incorporated by reference: 

 Exhibit A- Certification of Mariaelena Gayo-Guitian 

 Exhibit B- contains disclosures regarding “customary and 

comparable compensation.” 

 Exhibit C contains a summary of GJB’s timekeepers included in 

this Application. 

 Exhibit D contains the budgets for GJB’s services during the 

Application Period. 

 Exhibit E contains (a) a summary of the compensation requested as 

compared to the compensation budgeted for the firm’s services 

during the Application Period, and (b) a further breakdown of the 

compensation requested by project category and matter number. 

 Exhibit E-1 contains summary of compensation requested by 

project category as compared to budget. 

 Exhibit E-2 contains a summary of the expense reimbursements 

requested by category. An itemized schedule of all such expenses 

is included in GJB’s monthly statements. 

 Exhibit F contains a breakdown of compensation and expense 

reimbursement requested by Debtors and by whether the services 

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were rendered in Puerto Rico or outside Puerto Rico. 

 Schedule 1 contains a list of the professionals providing Services 

during the Application Period by matter. 

 Schedule 2 includes the monthly fee statements covered in this

Application. 

 Schedule 3 includes the proposed order approving this Application. 

SUMMARY OF SERVICES PERFORMED BY GJB DURING 

THE APPLICATION PERIOD 

 

 59. Set forth below is a description of the professional services rendered by GJB during 

the Application Period broken down by project category. The following services described are not 

intended to be a comprehensive summary of the work performed by GJB. Detailed descriptions of 

all services rendered by GJB can be found in the detailed time records reflecting the services 

performed by GJB’s professionals, the time expended by each professional, and the hourly rate of 

each professional, annexed to the Monthly Fee Statements attached as Schedule 2 and such 

descriptions are incorporated herein by reference. 

60. As special litigation and conflicts counsel to the Committee, GJB has jointly 

worked on various matters with counsel for the Oversight Board or its Special Claims Committee 

and has made a concerted effort to perform these services in an economic, effective, and efficient 

manner commensurate with the complexity and importance of the issues involved while being 

mindful to avoid any unnecessary or unreasonable duplication of effort with respect to any 

incurrence of fees in connection with the adversary proceedings commenced under the Joint 

Prosecution Stipulation. As such, GJB has carefully reviewed its staffing needs on a monthly basis 

and taken affirmative steps to avoid charges for duplicative services. For example, the work 

performed by GJB was carefully assigned to appropriate professionals or paraprofessionals 

according to the experience and level of expertise required for each particular task. Moreover, 

whenever possible, GJB sought to minimize the costs of GJB’s services to the Committee by 

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utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the 

assignments. In addition, a small group of the same GJB attorneys was utilized for the vast majority 

of the work in these Title III cases to minimize the costs of intra-GJB communication and 

education about the cases. Notably, as a general matter, no more than two GJB attorneys attended 

the various hearings held during the Application Period, thereby minimizing the time billed on 

these hearings. 

61. Furthermore, to the extent appropriate, GJB sought to work closely with Paul 

Hastings as counsel for the Committee and Brown Rudnick LLP (“Brown Rudnick” or “Special 

Claims Committee Counsel”) as counsel for the Financial Oversight and Management Board, 

acting through its counsel Proskauer Rose or the Special Claims Committee (the “Oversight 

Board”), as applicable, in order to eliminate unnecessary duplication and allocate tasks in an 

efficient manner. In order to minimize duplication, GJB continues to meet with and confer with 

counsel for the Oversight Board to discuss pending and potential claims and discuss a division of 

labor and tasks to limit duplication. 

62. In sum, GJB respectfully submits that the services for which it seeks compensation 

in this Application were necessary for and beneficial to the Committee, and were rendered to 

protect, preserve, and maximize the value for unsecured creditors during the pendency of these 

Title III cases. Accordingly, in light of the nature and complexity of these Title III cases, GJB’s 

charges for professional services performed and expenses incurred are reasonable under applicable 

standards. For all these reasons, GJB respectfully requests that the Court grant the Application 

and allow final compensation for professional services performed and reimbursement for expenses 

as requested. 

63. For ease of reference and transparency purposes, GJB created several matter 

numbers for its representation of the Committee. The matter numbers are divided as follows: 

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Matter ID Matter Name

001 Official Committee of Unsecured Creditors 

002 PREPA Adversary Litigation 

003 ERS Adversary Litigation 

004 HTA Adversary Litigation 

005 Kobre & Kim Investigation Report Database 

Review 

I. Official Committee of Unsecured Creditors of Commonwealth of Puerto Rico 

 (Matter ID 001) 

(a) Case Administration (Task Code B110) 

 Fees: $6,052.50 Total Hours: 13.8 

64. During the Application Period, GJB reviewed and developed general case strategy 

and planning of litigation matters, attended to case management, and participated in meetings with 

Paul Hastings, Proskauer Rose, Brown Rudnick, and local counsel in Puerto Rico. In order to 

efficiently track deadlines, organize documents, and manage work streams, GJB created a task list 

and tracking chart for all adversary proceedings filed which it routinely updates to keep track of 

deadlines. In addition, during the Application Period, GJB held routine internal team conference 

calls and occasional meetings to discuss interim and long-term strategies regarding current status 

of the Title III cases, the Co-Plaintiff Adversary Proceedings, and to manage work assignments 

and deadlines, while ensuring efficiencies and avoiding duplication and unnecessary overlap. 

(b) Pleadings Review (Task Code B113) 

 Fees: $8,694.00 Total Hours: 27.60 

65. During the Application Period, GJB monitored the case docket for the Title III cases 

and applicable adversary proceedings. All daily Court filings are reviewed and analyzed. Upon the 

completion of the Court filing review, an internal memorandum is prepared summarizing each 

Court filing, upcoming hearings, and noting relevant filings which may impact a proceeding where 

GJB is serving as special litigation counsel to the Committee. 

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 (c) Fee/Employment Applications (GJB) (Task Code B160) 

 Fees: $37,934.00 Total Hours: 87.80 

66. During the Application Period, GJB prepared one (1) monthly fee statement for 

services rendered for the month of January, 2022, as well as responding to inquiries from the Fee 

Examiner. GJB also prepared and filed its Eighth Interim Fee Application and related exhibits [Doc 

No. 21992]. In connection with the foregoing, GJB prepared and filed its disclosure (the “Verified 

Statement”) pursuant to the requirements set forth in the Puerto Rico Recovery Accuracy in 

Disclosures Act, Pub. L. No. 117-82 (“PRRADA”) and Rule 2014(a) of the Federal Rules of 

Bankruptcy Procedure, and further pursuant to this honorable Court’s Order Approving List of 

Material Interested Parties Pursuant to the Puerto Rico Recovery Accuracy in Disclosures Act

(the “PRRADA Order”) [Docket No. 20467]. 

(d) Budgeting (Task Code B161) 

 Fees: $345.00 Total Hours: 0.60 

 67. During the Application Period, GJB reviewed Budget and staffing issues and 

procedures in connection with the preparation, submission and approval of same. GJB prepared 

the monthly budget for February, 2022, as required by the Fee Examiner and Interim Fee Orders. 

 (e) Fee/Employment Objections (Task Code B170) 

 Fees: $4,537.50 Total Hours: 9.0

68. During the Application Period, GJB, among other things, had

communications with Mr. Nicholas Hahn related to PRRADA Disclosures. Additionally, 

GJB had communications with the Fee Examiner related to resolution of comments and 

objections to GJB’s Eighth Interim Fee Application. 

 (f) General Litigation (Task Code B191)

 Fees: $14,053.00 Total Hours: 46.70 

69. During this Application Period, GJB has continued its representation as special 

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litigation and conflicts counsel to the Committee in connection with various adversary proceedings 

associated with the Title III cases. In addition to monitoring the modified Plan filings and 

observing Plan confirming hearings, GJB is currently prosecuting seven (7) adversary proceedings 

associated with Debtor, Commonwealth of Puerto Rico (Case No. 17-3283). GJB represents the 

Committee with respect to a limited “garden-variety” avoidance action against Merck Sharp & 

Dohme (I.A.) LLC [Adv. Proc. No. 19-276], Great Educational Services Corp [Adv. Proc. No. 19-

277] and Eastern America Insurance Agency, Inc. [Adv. Proc. No. 19-279] whom received 

preferential and fraudulent transfers before the petition date. The adversary proceeding against 

Eastern America Insurance Agency, Inc. was voluntarily dismissed on February 16, 2021 [ECF 

No. 16]. Additionally, adversary defendant Great Educational Services Corporation filed for 

bankruptcy relief under Chapter 7 of the Bankruptcy Code, Bankruptcy Case No. 19-02901. In 

Adv. No. 19-280, GJB is seeking a judgment in excess of four billion dollars against numerous 

financial institutions and advisors whom negligently underwrote numerous bond obligations 

despite knowing the Commonwealth was in a state of insolvency for their financial gain (the 

“Underwriter Litigation”). With regard to the Underwriter Litigation, GJB is involved in the 

evaluation and if warranted, litigation of, a lawsuit filed by certain monoline insurers to assert 

claims against the defendants in the Underwriter Litigation. The Underwriter Litigation case is 

stayed pending decision on Confirmation of Amended Plan per Court Order. Furthermore, GJB 

has been involved in the representation of the Committee in a subset of adversary proceedings 

seeking to recover, among other things, declaratory judgments that the pertinent challenged GO 

bonds were issued in violation of the Constitution of Puerto Rico and to recover fraudulent 

transfers of approximately $9 billion dollars in general obligation bonds that were not validly 

issued [Adv. Proc. No. 19-281, Adv. Proc. No. 19-282, Adv. Proc. No. 19-283, and Adv. Proc. 

No. 19-288] (the “Clawback Litigation”). The Clawback Litigation cases are stayed pending 

decision on the confirmation of plan per Court Order. However, a Fifth Amended Adversary 

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Complaint was filed on March 4, 2021 in the adversary proceeding against Defendant 1L, et al, 

[Adv. No. 19-283]. Additionally, the Committee has dismissed certain Defendants in Adv. Proc. 

Nos 19-281 and 19-282. Additionally, in Adv. No. 19-297, GJB is challenging the validity, 

enforceability and extent of alleged pre-petition liens of the Commonwealth’s general obligation 

and guaranteed bonds (the “GO Lien Challenges”). In connection with the foregoing, GJB has 

been working with Committee and Special Claims Committee counsel and monitoring the 

establishment and extension of Case Management Procedures and Approval of Settlements related 

to those litigation matters it is handling. GJB has also provided, from time-to-time, additional 

assistance to Committee counsel with respect to litigation matters within GJB’s subject matter 

expertise, but in no way duplicative of the work performed by other counsel on these matters. GJB 

has continued its representation of the Committee in certain adversary cases associated with Debtor 

Puerto Rico Electric Power Authority (“PREPA”); Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico (“ERS”); and Puerto Rico Highways and 

Transportation Authority (“HTA”) as further described below. Those adversary proceedings 

include: (A) two adversary proceedings involving or relating to the claims of PREPA against fuel 

oil suppliers and laboratories to avoid certain fraudulent transfers [Adv. Pro. Nos. 19-388-LTS, 

and 20-115-LTS]; (B) six adversary proceedings in connection with the ERS litigation which is 

seeking, among other things, declarations on the scope of the liens purportedly securing the ERS 

bonds adversary proceedings involving {Adv. Pro. Nos. 19-355, 19-356, 19-357, 19-359, 19-361 

and 19-367]; and (C) one adversary proceeding challenging liens asserted by certain holders of 

HTA bonds [Adv. Proc. No. 19-364]. 

(g) Meeting and Communications with Board (Task Code B211)

 Fees: $345.00 Total Hours: 2.30 

70. During this Application period, GJB prepared and submitted various 

Monthly Fee Objection Letters and with invoices for review and approval. 

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(h) Meeting and Communications with Board (Task Code B260)

 Fees: $460.00 Total Hours: 0.80 

 71. During the Application Period, GJB had communications with the 

Committee regarding case strategy and case updates. 

 II. PREPA (Matter ID 002) 

(a) Case Administration (Task Code B110) 

 Fees: $238.50 Total Hours: 0.30 

 

72. During the Application period, GJB reviewed emails from counsel for the 

Defendants and committees regarding certain claims asserted in the Amended Complaint. GJB 

had discussions regarding the Exhibits and next steps. GJB prepared status report. 

 (b) General Litigation (Task Code B191) 

 Fees: $74,909.50 Total Hours: 152.50 

 73. During the Application Period, GJB reviewed and analyzed various pleadings filed 

in the PREPA matter in additional to monitoring pending tolling agreement deadlines and tracking 

expiration deadlines of same. GJB paralegals prepared, reviewed and analyzed services and 

notices. GJB continued its representation of the Committee in connection with the Rule 9019 

Motion, as well as in certain adversary cases pursuing the claims of PREPA against fuel oil 

suppliers and laboratories to avoid certain fraudulent transfers [Adv. Pro. No. 19-388-LTS]. GJB 

is also defending the Committee’s interest in an adversary proceeding involving a complaint for 

declaratory judgment alleging that the claims asserted by the Oversight Board and Committee in 

Adv. Pro. 19-388-LTS are not assets of the estate [Adv. Pro. No. 20-00015-LTS]. During the 

Application Period, GJB was involved in extensive litigation in Adv. Pro. No. 19-00388. The 

Marrero Parties filed their Rule 24(c) pleading to intervene in the adversary proceeding, and 

Defendants filed their Motion to Dismiss the Third Amended Complaint. GJB conducted 

expansive research in additional to numerous meetings with co-counsel to prepare the Committee’s 

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Joinder in the Special Claims Committee’s Limited Objection to the Rule 24(c) pleading, including 

review of the Marrero Parties’ Response to the Objection and Joinder and Defendants’ Joint 

Response to the Rule 24(c) Pleading, as well as preparing a Limited Reply to the Response, 

resulting in an Order from the Court limiting the Marrero Parties’ intervention rights. 

Additionally, during the Application Period, GJB reviewed pleadings filed in the related 

Vitol Adversary as it related to claims and defenses of the Defendants in Adv. Pro. No. 19-388. In 

addition, GJB conferred with counsel to prepare a Motion for Relief from Stay and Joint Status 

reports regarding the Vitol Defendants’ responsive pleadings in Adv. Pro. 19-388. 

III. ERS (Matter ID 003) – N/A 

74. During the Application Period there was no time billed in this matter. 

 IV. HTA (Matter ID 004) – 

(a) General Litigation (Task Code B191) 

 Fees: $230.00 Total Hours: 0.40 

75. During the Application Period, GJB continued review of tolling agreements with 

various parties. 

V. Kobre & Kim Investigation Report Database Review (Matter ID 005)- N/A 

76. During the Application Period there was no time billed in this matter. 

ATTENDANCE AT HEARINGS

77. In accordance with the presumptions set forth in the Order on Fee Examiner’s

Motion to Impose Presumptive Standards and Timeliness Requirements for Professional Fee

Applications [Docket No. 3932] (the “Presumptive Standards Order”), GJB provides the following 

summary regarding the attendance of GJB’s professionals at Court hearings: 

 GJB did not attend Court hearings during the Application Period. 

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ACTUAL AND NECESSARY DISBURSEMENTS

78. As set forth in Exhibit D-2, GJB disbursed $11,922.93 as expenses incurred in 

providing professional services during the Application Period. 

79. The time constraints imposed by the circumstances of the matters handled by GJB 

during the Application Period required its attorneys and other employees, at times, to devote 

substantial time during the evenings and on weekends to perform legal services on behalf of the 

Committee. These extraordinary services were essential to meet deadlines, timely respond to 

inquiries on a daily basis, and satisfy the Committee’s needs and demands. Attorneys and other 

GJB employees who worked late in the evenings or on weekends were reimbursed for their 

reasonable meal and transportation costs in accordance with the Local Rules and firm policy. 

GJB’s regular practice is not to include components for those charges in overhead when 

establishing billing rates, but rather to charge its clients for these and all other out-of-pocket 

disbursements incurred during the regular course of the provision of legal services. 

80. GJB believes the rates for charges incurred are the market rates that the majority of 

law firms charge clients for such services. In addition, GJB believes that such charges are in 

accordance with the American Bar Association’s (“ABA”) guidelines, as set forth in the ABA’s 

Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other 

charges. 

REQUESTED COMPENSATION SHOULD BE ALLOWED

81. Section 316 of PROMESA provides for the compensation of professionals. 

Specifically, section 316 provides that a court may award a professional employed by a committee 

under section 1103 of the Bankruptcy Code “reasonable compensation for actual, necessary 

services rendered and reimbursement for actual, necessary expenses.” PROMESA § 316(a). 

Section 316 also sets forth the criteria for the award of such compensation and reimbursement: 

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(a) 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: 

(i) the time spent on such services; 

(ii) the rates charged for such services; 

(iii) 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; 

(iv) 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; 

(v) with respect to a professional person, whether the 

person is board certified or otherwise has 

demonstrated skill and experience in the 

restructuring field; and 

(vi) 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. 

PROMESA § 316(c). Further, section 317 of PROMESA provides that “a committee may apply 

to the court not more than once every 120 days for such compensation for services rendered. 

82. In the instant case, GJB respectfully submits that the services for which it seeks 

compensation in this Application were, at the time rendered, believed to be necessary for and 

beneficial to the Committee, the Debtors, and their stakeholders and were rendered to protect, 

preserve, and maximize value for unsecured creditors during the pendency of the Title III Cases. 

The services rendered to the Committee were performed in an economic, effective, and efficient 

manner commensurate with the complexity and importance of the issues involved. The results 

obtained to date have benefited not only the Committee but also the Debtors, their stakeholders, 

and other interested parties. Accordingly, the compensation requested is reasonable in light of the 

nature, extent, and value of such services to the Committee, the Debtors, and all parties in interest. 

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83. The work conducted was carefully assigned to appropriate professionals or 

paraprofessionals according to the experience and level of expertise required for each particular 

task. Whenever possible, GJB sought to minimize the costs of GJB’s services to the Committee 

by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of 

the assignments. A small group of the same GJB attorneys was utilized for the vast majority of 

the work in order to minimize the costs of intra-GJB communication and education about the Title 

III Cases. As demonstrated by this Application, GJB spent its time economically and without 

unnecessary duplication. Accordingly, approval of the compensation sought herein is warranted. 

NOTICE

84. In accordance with the Interim Compensation Order, GJB will provide notice of 

this Application to (i) the attorneys for the Oversight Board, Proskauer Rose LLP and O’Neill & 

Borges LLC; (ii) the attorneys for the Puerto Rico Fiscal Agency and Financial Advisory 

Authority, O’Melveny & Myers LLP and Marini Pietrantoni Muñiz LLC; (iii) the Office of the 

United States Trustee for the District of Puerto Rico; (iv) the attorneys for the Official Committee 

of Retired Employees, Jenner & Block LLP and Bennazar, García & Milián, C.S.P.; (v) the Puerto 

Rico Department of Treasury; (vi) the Fee Examiner, Brady Williamson; and (vii) counsel to the 

Fee Examiner, Godfrey & Kahn, S.C. and EDGE Legal Strategies, PSC. In addition, the notice of 

hearing with respect to this Application will be served on all parties that have filed a notice of 

appearance in the Title III Cases. 

CONCLUSION 

WHEREFORE, GJB respectfully requests entry of an order, substantially in the form 

attached hereto as Schedule 3, (i) allowing final compensation for professional services rendered 

during the Application Period in the amount of $147,175.50, representing 100% of the fees billed 

during the Application Period plus 10% holdbacks in the amount $11,774.04 (not including GJB”s 

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voluntary fee reduction equal to 20% in the amount of $29,435.10) and reimbursement of 

$11,922.93, representing 100% of the actual and necessary expenses incurred during the 

Application Period (ii) authorizing and directing the Debtors’ payment of the fees allowed (net of 

credits for fee reductions) plus 100% of the expenses allowed and any amounts paid by the Debtors 

pursuant to the Third Interim Compensation Order, (iii) allowing such compensation and payment 

for professional services rendered and reimbursement of actual and necessary expenses incurred 

be without prejudice to GJB’s right to seek such further compensation and/or payment for the full 

value of services performed and expenses incurred, and (iv) granting GJB such other and further 

relief as is just. 

Dated: November 15, 2022.

 /s/ Mariaelena Gayo-Guitian 

GENOVESE JOBLOVE & BATTISTA, P.A. 

John H. Genovese, Esq. (Pro Hac Vice) 

Mariaelena Gayo-Guitian, Esq. (Pro Hac Vice)

100 SE 2nd Street, Suite 4400 

Miami, FL 33131 

Telephone: (305) 349-2300 

jgenovese@gjb-law.cdom

mguitian@gjb-law.com

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1 

_____________________________________________/

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

CERTIFICATION OF MARIAELENA GAYO-GUITIAN, ESQ. IN SUPPORT OF 

NINTH & FINAL FEE APPLICATION OF GENOVESE JOBLOVE & BATTISTA, P.A., 

AS SPECIAL LITIGATION COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDEREDAND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM JANUARY 1, 2022 – JULY 31, 2022 

I, Mariaelena Gayo-Guitian certify that the following is true to the best of my knowledge 

information, and belief: 

1. I am an attorney and partner of Genovese Joblove & Battista, P.A. (“GJB”), with 

four offices in Florida located at 100 SE 2nd Street, Suite 4400, Miami, FL 33131 (“Miami”); 200 

East Broward Blvd, Suite 1110, Fort Lauderdale, FL 33301 (“Ft. Lauderdale”), and 100 N. Tampa 

Street, Suite 2600, Tampa, FL (“Tampa”). GJB also has an affiliate office in Caracas Venezuela 

located at Av. Francisco de Miranda, Torre Provincial "A" piso 8 oficina 81 y 82 1060 Caracas, 

Venezuela. 

2. I am admitted to practice law in the state of Florida. By order dated April 16, 2019, 

 

1 The Debtors in these 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) 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), (iii) Puerto Rico 

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

Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (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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I was admitted to appear Pro Hac Vice in the Debtors Title III Cases [Docket No. 6330]. 

3. I am duly authorized to make this Certification on behalf of GJB. The facts set forth 

in this Certification are based upon my personal knowledge, my discussions with other GJB 

attorneys, and the review of GJB’s client/matter records by me or other GJB attorneys acting under 

my supervision and direction. 

4. 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 (the “Third 

Interim Compensation Order”), this Certification is made with respect to the Ninth & Final 

Application of Genovese Joblove & Battista, P.A., as Special Litigation Counsel to Official 

Committee of Unsecured Creditors, for Services Rendered and Reimbursement of Expenses for 

the Period from January 1, 2022 – July 31, 2022 (the “Application”).2

 

5. Pursuant to section (a)(4) of the Local Guidelines, I hereby certify that I have read 

the Application and, to the best of my knowledge, information, and belief, formed after reasonable 

inquiry, (a) the compensation and reimbursement of expenses sought in the Application conforms 

with the Bankruptcy Code, the Bankruptcy Rules, the U.S. Trustee Guidelines, and the Local 

Rules, (b) the compensation and reimbursement of expenses are billed at rates no less favorable to 

the Debtors than those customarily employed by GJB generally (taking into consideration that GJB 

employs a variety of fee arrangements with its clients, including hourly fees, contingency fees and 

hybrid fees involving reduced hourly rates and reduced contingency fee percentages) and billed in 

accordance with the Engagement Letter and Retention Order; and (c) in providing a reimbursable 

 

2 Capitalized terms used herein shall have the same meanings given to them in the Application.

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services, GJB does not make a profit on that service, whether the service is performed by GJB inhouse or through a third party. 

6. In accordance with the Engagement Letter and Retention Order, GJB agreed to a 

voluntary fee reduction equal to 20%, which results in a reduction in fees in the amount of 

$29,435.10 in the Application. GJB seeks allowance of all of its fees incurred during the 

Application Period in the net amount of $117,740.40, to the extent such amount has not been paid 

before the hearing scheduled on this Application. 

7. GJB provides the following response to the request for information set forth 

in the U.S. Trustee Guidelines: 

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? 

Response: Yes. As a courtesy to the Committee and based on circumstances 

unique to the Title III Case, during the Application Period, GJB 

agreed to a voluntary reduction of its fees by an amount equal to 20% 

of the total fees sought to be paid, which reduction totals $29,435.10. 

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

budgeted for the Application Period are higher by 10% or more, did 

you discuss the reasons for the variation with the client? 

Response: The fees were below the budgeted amount, therefore the request is 

not applicable. 

Question: Have any of the professionals included in this application varied their 

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

Response: No.

Question: Does the 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. 

Response: The Application includes approximately 87.80 hours and associated 

fees of approximately $37,934.00 related to preparing, reviewing, 

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and revising GJB’s fee statements. 

Question: Does this 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. 

Response: No. 

Question: If the application includes any rate increases since retention: (i) Did 

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

Response: No rate increases have occurred since the retention date. 

8. I declare under penalty of perjury that, to the best of my knowledge and after 

reasonable inquiry, the foregoing is true and correct. 

Executed this 15th day of November, 2022. 

 

/s/ Mariaelena Gayo-Guitian

 Mariaelena Gayo-Guitian, Esq.

 GENOVESE JOBLOVE & BATTISTA, P.A. 

Mariaelena Gayo-Guitian, Esq. (Pro Hac Vice) 

 100 SE 2nd Street, Suite 4400 

 Miami, FL 33131 

 Telephone: (305) 349-2300 

 mguitian@gjb-law.com

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EXHIBIT B

CUSTOMARY AND COMPARABLE COMPENSATION DISCLOSURES

(See Guidelines ¶ C.3. for definitions of terms used in this Exhibit.) 

CATEGORY 

OF 

TIMEKEEPER

(using categories 

already maintained 

by the firm)

BLENDED HOURLY RATE

NONBANKRUPTCY 

BLENDED 

HOURLY RATE

GJB BLENDED 

HOURLY RATE1

GJB BLENDED 

HOURLY RATE 

(AFTER 20%

REDUCTION)2

Partner $587.92 $587.92 $470.33 

Counsel N/A N/A N/A 

Associate $338.14 $338.14 $270.51 

All timekeepers 

aggregated $430.59 $430.59 $344.47 

 

 

1 The calculation of GJB’s Blended Hourly Rate does not take into account GJB’s agreement to reduce its fees by an 

amount equal to 20% of its total hourly fees. 

2

 For illustrative purposes only. 

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EXHIBIT C

SUMMARY OF TIMEKEEPERS INCLUDED IN THIS 

APPLICATION

Name 

Title 

or 

Position

Department, 

Group, or 

Section 

Date of 

First 

Admission

Fees Billed 

in this 

Application

Hours Billed

in this 

Application 

 Hourly Rate Bil In this Application

In E

Int

Appl

Arrastia, John Partner Litigation 1996 $34,960.00 60.80 $575.00 $57Friedman, Michael A. Partner Bankruptcy 2009 $12,265.00 22.30 $550.00 $55Genovese, John H. Partner Bankruptcy 1979 $13,234.50 17.30 $765.00 $76Suarez, Jesus M. Partner Bankruptcy 2008 $3,350.00 6.70 $500.00 $50Gayo-Guitian, Mariaelena Partner Bankruptcy 1989 $101,357.00 65.30 $575.00 

Total Partner: $101,357.00 172.40 

Castaldi, Angelo Associate Litigation 2015 $26,635.00 76.10 $375.00 $37Delgado, Joyce A. Associate Litigation 2017 $12,285.00 39.00 $315.00 $31

 Total Associate: $38,920.00 115.10 

Hopkins, Colleen Paralegal $78.00 0.40 $195.00 $19Sardina, Jessey Paralegal $952.50 12.70 $75.00 $7Scavone-Esser, Carolyn Paralegal $4,320.00 28.80 $150.00 $15Lambdin, Vonda Paralegal $300.00 2.00 $150.00 $15Garcia-Montes, Tricia Paralegal $6,898.50 54.30 $120.00 $12

 Total Paraprofessional: $6,898.50 54.30 

Total: $147,175.50 341.80 Blended Rate: $430.59 Blended Rate Excluding $487.92 

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EXHIBIT D

BUDGET AND STAFFING PLAN 

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EXHIBIT D-1

BUDGETS FOR: 

February 2022

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Case Name and Number: 17 BK 3283-LTS (Jointly Administered) 

Applicant’s Name: Genovese, Joblove & Battista, P.A., as Special Litigation Counsel 

 to the Official Committee Of Unsecured Creditors 

 Of The Commonwealth Of Puerto Rico, et al. 

BUDGET 

Period Covered: February 1 through February 28, 20221

U.S. Trustee Task Code and Project Category Estimated Hours for 

Period February 1 

through 

February 28, 2022 

B110 Case Administration 

Notes: This task code includes general case strategy and 

planning, case management, internal Committee matters, 

internal meetings, and meetings with Paul Hastings. 

Prior Month ~ 10

Trailing Two Month Average ~ 12 10

B112 General Creditor Inquiries 

Prior Month ~ 0 

Trailing Two Month Average ~0 0 

B113 Pleadings Review 

Notes: This task code includes review of relevant pleadings in 

the title III cases as well as all related adversary 

proceedings. GJB will focus its review on matters that 

impact its scope of work. 

Prior Month ~8 

Trailing Two Month Average ~ 16 15

 

1

 Unless otherwise indicated, this proposed budget is based on the following assumptions: (i) no additional title III 

cases or adversary proceedings will be commenced during the budget period; (ii) no new plan of adjustment will 

be filed during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and 

(iv) all adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss, motions to stay, and/or pretrial proceedings. In addition, it is 

impossible to predict how many hours will be required to prosecute contested matters where GJB is asked to 

participate as conflicts counsel. Thus, this proposed budget may be materially different from the work actually 

performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee may need 

to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is speculative. 

The proposed budget has been revised to account for the Committee’s agreement to the proposed plan of 

adjustment and the March 10, 2020 Final Order Regarding (A) Stay Period, (B) Mandatory Mediation, and (c) 

Certain Deadlines Related Thereto, (as amended and modified by subsequent orders) with regard to several 

adversary proceedings for which the Committee has been appointed as co-plaintiff/co-trustee with the Oversight 

Board or the members of the Special Claims Committee. 

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B120 Asset Analysis and Recovery 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B130 Asset Disposition 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B140 Relief from Stay / Adequate Protection Proceedings 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 

Notes: This task code includes time spent on telephone 

conferences, meetings, and other communications with 

the Committee, including preparation for such calls and 

meetings. GJB will focus its participation on matters 

that impact its scope of work and avoid unnecessary 

duplication with Paul Hastings. 

 Prior Month ~ ~2

Trailing Two Month Average ~3 3

B155 Court Hearings 

Notes: This task codes includes time spent in court hearings in 

the title III cases and the related adversary proceedings. 

This task code also includes time spent preparing for 

such hearings. GJB will focus its participation on 

matters that impact its scope of work and avoid 

unnecessary duplication with Paul Hastings and the 

Special Claims Committee. 

 Prior Month ~ 0 

Trailing Two Month Average ~0 10

B160 Employment / Fee Applications 

Notes: This task code includes time spent on complying with the 

interim compensation order, including preparing GJB’s 

fee statements, as well as responding to inquiries from 

the fee examiner related thereto. 

Prior Month ~10 

Trailing Two Month Average ~8 10

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B161 Budgeting (Case) 

Notes: This task code includes time spent on preparing GJB’s 

monthly budgets, as required by the fee examiner. 

 Prior Month ~ 2 

Trailing Two Month Average ~2 2

B165 Fee and Employment Applications of Other 

Professionals 

Notes: This task code includes time spent on reviewing fee and 

retention applications of other professionals in these title 

III cases only as it relates to (i) committee professionals 

operating at the direction of GJB as conflicts counsel; or 

(ii) where matters principally handled by GJB are 

implicated. 

 Prior Month ~0

Trailing Two Month Average ~0 0

B170 Fee and Employment Objections 

Notes: This task code includes time spent on preparing or 

responding to objections to fee and retention 

applications. 

 Prior Month ~ 1 

Trailing Two Month Average ~1 1

B180 Avoidance Action Analysis 

Notes: This task code includes time spent on analyzing potential 

claims for avoidance, including preferential transfers 

and fraudulent transfers as well as requests for 

settlement that are impacted by such claims. GJB will 

focus its participation on matters that impact its scope of 

work and avoid unnecessary duplication with Paul 

Hastings or other counsel handling such matters for the 

Committee or the Special Claims Committee, to the extent 

it is a Co-Plaintiff. 

 Prior Month ~ 10 

Trailing Two Month Average ~0 10

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B185 Assumption / Rejection of Leases and Contracts 

Notes: This task code includes time spent on analyzing issues 

related to the assumption or rejection of executory 

contracts and unexpired leases. GJB is role in this 

category is limited to instances, if any, where Paul 

Hastings may have a conflict. 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B190 Other Contested Matters 

Notes: This task code includes time spent on all contested 

matters in the Title III cases. GJB’s role in this category 

is limited to instances, if any, where Paul Hastings may 

have a conflict. 

This task code also includes the research, evaluation, and 

prosecution of potential objections to the plan of 

adjustment and disclosure statement, solely as it relates 

to claims in which Paul Hastings has a conflict. 

Prior Month ~ 0 

Trailing Two Month Average ~ 0

2 

 

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191 General Litigation (including Commonwealth litigation, 

mediation process, and handling of adversary 

proceedings) 

Notes: GJB is responsible for the prosecution of PREPA’s 

claims in AP 388 against the Fuel Oil Defendants, the 

stay of which has been lifted and briefing underway. 

 GJB is responsible for the litigation involving the 

Catesby-Jones/Marrero Class Action Plaintiffs efforts to 

intervene in AP 388, in direct and collateral litigation, 

the briefing of which is underway. 

 GJB is also reviewing claim objections that may impact 

AP 280, known as the Underwriter Litigation, which is 

current stayed. 

 GJB is also responsible for any matters relating to the 

Underwriter Litigation, to the extent raised during the 

stay 

 This task code includes all adversary proceedings, which 

consist of (a) the joint prosecution of causes of action 

together with Oversight Board/Special Claims 

Committee in 22 separate lawsuits, and (b) monitoring 

other adversary proceedings and litigation. GJB’s role 

in this category is limited to those adversary proceedings 

in which GJB has appeared as and is the lead counsel for 

the Committee. This role may require coordination with 

other counsel in related matters concerning global legal 

issues. Currently, many of these matters are stayed 

pursuant to Court orders in effect, subject to 

confirmation, with the expectation that such matters will 

be resolved as a result of confirmation.. 

Prior Month ~232 

Trailing Two Month Average ~ 208 250

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B195 Non-Working Travel2

Notes: This task code includes time spent on non-working travel, 

including to court hearings and Committee meetings in 

San Juan, Boston and New York City, although 

attendance will be limited if required due to a conflict on 

behalf of Paul Hastings. 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 

Notes: This task code includes time spent reviewing and 

analyzing the Debtors’ fiscal plans and related matters. 

GJB is role in this category is limited to instances, if any, 

where Paul Hastings may have a conflict or where GJB 

may need to familiarize itself with matters that may 

impact litigation where GJB is serving as conflicts 

counsel to the Committee. 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B220 Employee Benefits/Pensions 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B230 Financing / Cash Collections 

Prior Month ~ 0 

Trailing Two Month Average ~0 0

B231 Security Document Analysis 

 Prior Month ~0 

Trailing Two Month Average ~0 0

 

2

 The firm charges one-half a timekeeper’s normal billing rate for any time incurred on account of non-working 

travel. 

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B260 Meetings of and Communications with 

Debtors/Oversight Board 

Notes: This task code includes time spent on meeting and 

communicating with the Debtors, the Oversight Board, 

and their respective advisors. GJB anticipates significant 

collaboration with the Special Claims Committee of the 

FOMB on matters GJB has appears as conflicts counsel, 

with increased interaction due to briefing schedules in 

pending matters. 

 Prior Month ~ 3 

Trailing Two Month Average ~2 10

B261 Investigations 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B310 Claims Administration and Objections 

Notes: This task code includes time spent on matters related to 

claims administration, including time spent on 

investigating potential challenges to claims, including, 

most notably, the challenge to the GO bond claims and 

the ERS bond claims. This task code also includes time 

spent on analyzing the pool of unsecured claims against 

the Debtors. GJB is role in this category is limited to 

instances, if any, where Paul Hastings may have a 

conflict. 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

B320 Plan and Disclosure Statement 

Notes: This task code includes time spent on matters related to 

the evolving plan of adjustment for the Title III Debtors. 

GJB will focus its participation on matters that impact its 

scope of work and avoid unnecessary duplication with 

Paul Hastings, limited to implementing certain discrete 

plan elements. 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

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B420 Restructurings 

Notes: This task code includes time spent on general 

restructuring matters, including an anticipated 

amendment Commonwealth Plan of Adjustment and 

Disclosure Statement, and matters related to the 

pending PREPA RSA) and the related 9019 motion. 

 GJB anticipates continued involvement in the these 

matters to the extent that Paul Hastings is conflicted from 

the representation 

 Prior Month ~ 0 

Trailing Two Month Average ~0 0

TOTAL HOURS 323

TOTAL ESTIMATED FEE3 $166,367.61

MINUS 20% REDUCTION $33,273.52

TOTAL ESTIMATED FEE (NET OF REDUCTION) $133,094.09

ADDITIONAL STAFFING PLANS (INCL. SUB-BUDGETS) 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

Period Covered: February 1 through February 28, 2022 

A. Adversary Proceedings Against Financial Parties, Fuel Oil Defendants, and Other 

Proceedings 

Genovese Joblove & Battista PA., (“GJB” or “Firm”) as the Committee’s special litigation 

counsel, represents the Committee with respect to two (2) principal adversary proceedings against: 

(a) numerous underwriters and other financial target parties involved in the issuance of 

Commonwealth bonds [Adv. Proc. No. 19-280-LTS]; and (b) the claims of PREPA against fuel 

oil suppliers and laboratories to avoid certain fraudulent transfers [Adv. Pro. No. 19-388-LTS]. 

Pursuant to the Order entered on January 10, 2019, the litigation in Adv. Proc. No. 19-00388 was 

stayed through August 17, 2020 at which time a joint status report was issued. The Defendants 

responded and the issues were briefed for hearing on September 16, 2020, but not heard, and 

remain under advisement. The remaining issue is the intervention of the Marrero Class Action 

Plaintiffs, which the parties have agreed to resolve in the Marrero Class Action Plaintiffs’ 

complaint to declare its right to pursue the claims against the Fuel Oil defendants in Adv. Pro. No. 

20-00115. That matter has been resolved, and pursuant to Court Order, the stay has been lifted in 

Adv. Pro. No. 19-388 for the parties to engage in motion and pleading practice directed to the 

operative complaint and counterclaims, including renewed claims by the Marrero Class Action 

Plaintiffs to intervene. 

 

The March 10, 2020 Final Order Regarding (A) Stay Period, (B) Mandatory Mediation, and (c) 

 

3 Assumes Blended Rate of $515.07 

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Certain Deadlines Related Thereto stays the proceedings pending a decision on confirmation, with 

a plan of adjustment that will transfer this action to a post-confirmation Avoidance Action Trust. 

1. Staffing Plan 

Category of 

timekeeper 

(using categories 

maintained by the 

firm) 

Number of 

timekeepers 

expected to work 

on the matter 

during the budget 

period 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 (net of 

20% reduction) 

Partner 

(20+ Years) 2 $680 $544 

Partner 

(10+ Years) 2 $525 $420 

Associate 4 $375 $300 

Paraprofessionals 2 $195 $156 

2. Sub-Budget 

U.S. Trustee Task Code and Project Category Estimated Hours 

for Period 

February 1 

through February 

28, 2022 

B191 General Litigation 250

TOTAL HOURS 250

B. Garden-Variety Avoidance Actions 

GJB represents the Committee with respect to limited “garden-variety” avoidance actions [Adv. 

Proc. Nos. 19-267, 19-275-279] against entities that received preferential and fraudulent transfers 

before the petition date. Casillas, Santiago & Torres LLC, the Committee’s local counsel, 

represents the Committee with respect to the balance of the “garden-variety” avoidance actions 

initiated against vendors of the Commonwealth of Puerto Rico [Adv. Proc. Nos. 19-041 to 19-279, 

Adv. Proc. Nos. 19-347 to 19-354, and additional adversary proceedings to be commenced with 

respect to PREPA]. However, GJB may, from time-to-time, provide additional assistance to other 

committee counsel with respect to litigation matters within GJB’s subject matter expertise, but in 

no way duplicative of the work performed by other counsel on these matters. 

On June 7, 2019, the Co-Plaintiffs in these avoidance actions filed a motion [Docket No. 7325] 

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seeking approval of, among other things, procedures establishing a framework for streamlined 

execution of settlement agreements and procedures and guidelines for resolving the avoidance 

actions through a voluntary mediation process. On August 12, 2019, the Court entered an “Order 

Granting Omnibus Motion by the Financial Oversight and Management Board for Puerto Rico, 

acting by and through the Members of the Special Claims Committee and the Official Committee 

of Unsecured Creditors to (i) Establish Litigation Case Management Procedures and (ii) Establish 

Procedures for Approval of Settlements.” On December 6, 2019, the Court entered an “Order 

Granting Omnibus Motion to Extend Deadlines in Order Granting Omnibus Motion by the 

Financial Oversight and Management Board for Puerto Rico, acting by and through the Members 

of the Special Claims Committee and the Official Committee of Unsecured Creditors to (i) 

Establish Litigation Case Management Procedures and (ii) Establish Procedures for Approval of 

Settlements” as amended by subsequent orders. 

On August 26, 2021, the Court entered its Order Staying Vendor Avoidance Actions [Docket Entry 

17977] which stays those avoidance actions that could implicate GJB’s attention. 

1. Staffing Plan 

Category of 

timekeeper 

(using categories 

maintained by the 

firm) 

Number of 

timekeepers 

expected to work 

on the matter 

during the budget 

period 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 (net of 

20% reduction) 

Partner 

(20+ Years) 2 $575 $460 

Partner 

(10+ Years) 2 $500 $400 

Associate 2 $375 $300 

Paraprofessionals 2 $195 $156 

2. Sub-Budget 

U.S. Trustee Task Code and Project Category Estimated Hours 

for Period February 

1 through February 

28, 2022 

B191 General Litigation 0

TOTAL HOURS 210

C. Currently Stayed Co-Plaintiff Adversary Proceedings 

The Committee has been appointed as Co-Plaintiff/Co-Trustee with the Oversight Board or the 

members of the Special Claims Committee as to certain Adversary Proceedings. GJB represents 

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the Committee as Special Litigation counsel in a subset of these adversary proceedings. Pursuant 

to the March 10, 2020 Final Order Regarding (A) Stay Period, (B) Mandatory Mediation, and (c) 

Certain Deadlines Related Thereto the Court extended the stay. These matters are identified as 

follows: 

 Four adversary proceedings seeking, among other things, declaratory judgments 

that the pertinent challenged GO bonds were issued in violation of the Constitution 

of Puerto Rico and to recover fraudulent transfers made on account of GO bonds 

that were not validly issued [Adv. Proc. No. 19-281, Adv. Proc. No. 19-282, Adv. 

Proc. No. 19-283, and Adv. Proc. No. 19-288]. These matters are stayed pending 

the decision on the Confirmation of the Amended Plan of Adjustment; and 

 One adversary proceedings challenging liens asserted by certain holders of HTA 

bonds [Adv. Proc. No. 19-364]. These matters remain stayed until such time as 

the Court orders the stay lifted or a plan of adjustment is confirmed for HTA. 

Accordingly, GJB does not expect to expend any significant time on these adversary proceedings 

during the month of December other than minor administrative and/or procedural work, including 

responding to inquiries from defendants and assisting Brown Rudnick and Proskauer, in general 

administration of these cases. 

Also, on January 19, 2019, Judge Swain approved a briefing and hearing schedule with respect to 

motion to dismiss practice related to the GO Lien Challenge. This was stayed pending 

confirmation of the Amended Plan, pursuant to March 10, 2020 Final Order Regarding (A) Stay 

Period, (B) Mandatory Mediation, and (c) Certain Deadlines Related Thereto. GJB’s involvement 

in the GO Lien Challenge is limited to one adversary listed below. 

1. Staffing Plan 

Category of 

timekeeper 

(using categories 

maintained by the 

firm) 

Number of 

timekeepers 

expected to work 

on the matter 

during the budget 

period 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 (net of 

20% reduction) 

Partner 

(20+ Years) 2 $575 $460 

Partner 

(10+ Years) 2 $500 $400 

Associate 2 $375 $300 

Paraprofessionals 2 $195 $156 

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2. Sub-Budget 

D. ERS Lien Co-Plaintiff Adversary Proceedings 

Proskauer Rose LLP, as counsel to the Oversight Board, has primary responsibility for the 

adversary proceedings seeking, among other things, declarations on the scope of the liens 

purportedly securing the ERS bonds [Adv. Proc. No. 19-366 and Adv. Proc. No. 19-367]. GJB is 

counsel of record for the Committee in Adv. Proc. No. 19-367. These matters had been stayed 

pursuant to the August 25th, 2019 Order, but on October 24, 2019, the Court approved a scheduling 

order regarding discovery and summary judgment briefing on the lien scope issues and ultra vires 

issues with respect to the ERS bonds and lifted the stay. Accordingly, (a) the lien scope litigation, 

i.e., Adv. Proc. No. 19-366 and Adv. Proc. No. 19-367 and (b) Count I of the complaints seeking 

declarations that the pertinent ERS bonds were issued ultra vires and, thus, are null and void, i.e.,

Adv. Proc. No. 19-355, Adv. Proc. No. 19-356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-359, 

and Adv. Proc. No. 19-361 were unstayed. GJB’s involvement in the lien scope litigation is 

expected to be minimal and limited to Adv. Proc. No. 19-367. 

This litigation has been resolved among the parties and stayed pending confirmation. 

1. Staffing Plan 

Category of 

timekeeper 

(using categories 

maintained by the 

firm) 

Number of 

timekeepers 

expected to work 

on the matter 

during the budget 

period 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 (net of 

20% reduction) 

Partner 

(20+ Years) 2 $575 $460 

Partner 

(10+ Years) 2 $500 $400 

Associate 2 $375 $300 

Paraprofessionals 2 $195 $156 

2. Sub-Budget 

U.S. Trustee Task Code and Project Category Estimated Hours for Period 

February 1 through 

February 28, 2022 

B191 General Litigation 0

TOTAL HOURS 250

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U.S. Trustee Task Code and Project Category Estimated Hours 

for Period February 

1 through February 

28, 2022 

B191 General Litigation 0

TOTAL HOURS 250

E. Contested Matters. 

GJB represents the Committee with respect to several issues, including the following: the 

Adversary Defendants motion to participate in the GO Bond Claim Objections (and related 

mediation process); proceedings relating to terminating the PREPA RSA; and anticipated, litigated 

contested matters that are currently under advisement by the Committee. GJB anticipates its 

involvement in these matters as it relates to conflict issues. 

1. Staffing Plan 

Category of 

timekeeper 

(using categories 

maintained by the 

firm) 

Number of 

timekeepers 

expected to work 

on the matter 

during the budget 

period 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 (net of 

20% reduction) 

Partner 

(20+ Years) 3 $645 $516 

Partner 

(10+ Years) 2 $525 $420 

Associate 4 $375 $300 

Paraprofessionals 2 $195 $156 

2. Sub-Budget 

U.S. Trustee Task Code and Project 

Category 

Estimated Hours for Period February 1 

through February 28, 2022 

B190 Other Contested Matters 0

TOTAL HOURS 0

GENERAL STAFFING PLAN 

Period Covered: February 1 through February 28, 20224

 

4

 Unless otherwise indicated in this budget, this proposed staffing plan is based on the following assumptions: (i) 

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Category of 

timekeeper 

(using categories 

maintained by the 

firm) 

Number of 

timekeepers 

expected to work 

on the matter 

during the budget 

period 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 

Average hourly 

rate for period 

February 1 

through February 

28, 2022 (net of 

20% reduction) 

Partner (20+ 

Years) 5 $615 $492 

Partner (10+ 

Years) 2 $525 $420 

Associate 4 $375 $300 

Paraprofessionals 2 $195 $156 

 

no additional title III cases or adversary proceedings will be commenced during the budget period; (ii) no 

adversary proceedings will require discovery and trial preparation; and (iii) all adversary proceedings in which 

the Committee has intervened and/or sought to intervene will only involve briefing and hearings on motions to 

dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the work 

actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee 

may need to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is 

speculative. The proposed amended budget has been revised to account for the stay of litigation and other 

proceedings. 

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EXHIBIT D-2

STAFFING PLAN 

Period Covered: January 1, 2022 – July 31, 2022

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 01/01/22 

through 07/31/22

Average hourly rate 

for period 01/01/22 

through 07/31/22 

(net of 20% 

reduction)

Partner 

(20+ Years) 2 $670 $536 

Partner 

(10+ Years) 3 $542 $433.60 

Associate 2 $332.50 $266.00 

Paraprofessionals 5 $138.00 $110.40 

 

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EXHIBIT E 

SUMMARY OF COMPENSATION REQUESTED BY PROJECT CATEGORY

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EXHIBIT E-1 

SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

CATEGORY

U.S. TRUSTEE 

TASK CODE 

AND PROJECT 

CATEGORY 

January 

2022 

February

2022 

March 

2022 

April 

2022 

May 

2022 

June 

2022 

July 

2022 TOTAL 

B110 Case 

Administration 2.2 2.9 

1.50 0.40 2.90 2.40 1.80 

14.10 

B113 Pleadings 

Review 

13.00 2.60 

9.80 0.90 1.30 

27.60 

B160 

Employment / Fee 

Applications (GJB) 

3.70 0.50 45.40 1.00 7.70 27.20 2.30 87.80 

B161 Budgeting 

(Case) 

0.60 0.60 

B170 Fee and 

Employment 

Objections 

0.50 2.40 

 

4.50 1.60 9.00 

B191 General 

Litigation 175.8 11.20 1.20 0.50 9.90 0.50 0.50 199.60 

B211 Financial 

Reports 2.30 

 

2.30 

B260 

Meetings/Communi

cations with 

Debtors/ Oversight 

Board 

0.80 

 

0.80 

TOTAL 

HOURS: 196.60 19.50 60.30 2.80 21.80 34.60 6.20 341.80 

TOTAL FEES: $89,400.00 $7,909.50 $23,237.00 $1,376.00 $7,279.50 $14,956.50 $3,017.00 $147,175.50 

MINUS 20% 

REDUCTION: $17,880.00 $1,581.90 $4,647.40 $275.20 $1,455.90 $2,991.30 $603.40 $29,435.10 

TOTAL 

FEES: 

(NET OF 

REDUCTION) 

$71,520.00 $6,327.60 $18,589.60 $1,100.80 $5,823.60 $11,965.20 $2,413.60 $117,740.40 

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FURTHER BREAKDOWN OF COMPENSATION REQUESTED 

 BY PROJECT CATEGORY AND BY MATTER 

Official Committee of Unsecured Creditors of Commonwealth of PR (Matter ID 001) 

U.S. Trustee Task Code and Project Category Hours Billed Fees Sought

B110 Case Administration 13.8 $6,052.50 

B113 Pleadings Review 27.60 $8694.00 

B160 Fee/Employment Applications 87.80 $37,934.00 

B161 Budgeting 0.60 $345.00 

B170 Fee/Employment Objections 9.00 $4537.50 

B191 General Litigation 46.70 $$14,053.00 

B211Financial Reports (Monthly Operating Reports) 2.30 $345.00 

B260 Meetings and Communications with Board 0.80 $460.00 

TOTAL $72,421.00 

PREPA (Matter ID 002)

U.S. Trustee Task Code and Project Category Hours Billed Fees Sought

B110 Case Administration 0.30 $238.50 

B191 General Litigation 152.50 $74,909.50 

TOTAL $75,148.00 

ERS (Matter ID 003) – 

N/A

HTA (Matter ID 004) – 

U.S. Trustee Task Code and Project Category Hours Billed Fees Sought

B191 General Litigation 0.40 $230.00 

TOTAL $230.00 

Kobre & Kim Report (Matter ID 005) - N/A 

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EXHIBIT E-2

SUMMARY OF EXPENSE REIMBURSEMENTS REQUESTED BY CATEGORY

Category Amount

Travel Expenses – Airfare $0.00 

Travel Expenses – Lodging $0.00 

Travel Expenses - Taxi / Ground Transportation $0.00 

Travel Expenses – Parking $0.00 

Meals (while working on Committee matters) $0.00 

Court call $0.00 

Long Distance Phone Calls $0.00 

Process Service Fee $0.00 

Messenger $0.00 

Computer Search $539.10

Articles and Publications $0.00 

Court Reporting Services $0.00 

In-house Black and White Reproduction Charges $0.00 

Outside Photocopies $0.00 

Outside Professional Services $0.00 

Postage/Express Mail $0.00 

Data Management/Web Hosting $11,383.83 

Miscellaneous- Website Domain and Maintenance $0.00

TOTAL $11,922.93 

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EXHIBIT F 

BREAKDOWN OF COMPENSATION AND EXPENSE REIMBURSEMENT AND BY 

WHETHER SERVICES WERE RENDERED IN PUERTO RICO OR OUTSIDE 

PUERTO RICO

January 2022 Fee Statement 

Fees 20% Discount 

Fees 

Requested to 

Be Paid 

(90%)

Expenses 

Requested to 

Be Paid 

(100%)

Total Fees & 

Expenses 

Requested to 

Be Paid

Total for Commonwealth 

(all outside of Puerto Rico) $16,248.00 $12,998.40 

($3,249.60) $11,698.56 $0.00 $11,698.56 

Total for PREPA 

(all outside of Puerto Rico) $72,922.00 $58,337.60 

($14,584.40) $52,503.84 $0.00 $52,503.84 

Total for ERS 

(all outside of Puerto Rico) N/A N/A N/A N/A N/A 

Total for HTA 

(all outside of Puerto Rico) $230.00 $184.00 

($46.00) 

$165.60 $0.00 $165.60 

 Grand Total $89,400.00 $71,520.00 $64,368.00 $0.00 $64,368.00

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SCHEDULE 1

LIST OF PROFESSIONALS BY 

MATTER

Official Comm. of Unsecured Creditors of Commonwealth of PR (Matter ID 001)

Name Title or Position Department, Group, or

Section

Genovese, John H. Partner Bankruptcy 

Gayo-Guitian, Mariaelena Partner Bankruptcy 

Arrastia, John Partner Litigation 

Friedman, Michael Partner Bankruptcy 

Castaldi, Angelo M. Associate Litigation 

Delgado, Joyce A. Associate Litigation 

Hopkins, Colleen Paralegal Bankruptcy 

Sardina, Jessey Paralegal Bankruptcy 

Garcia-Montes, Tricia Paralegal Litigation 

Lambdin, Vonda Paralegal Bankruptcy 

Scavone, Carolyn Paralegal Bankruptcy 

PREPA (Matter ID 002)

Name Title or Position Department, Group, or

Section

Genovese, John H. Partner Bankruptcy 

Arrastia, John Partner Litigation 

Suarez, Jesus M. Partner Bankruptcy 

Friedman, Michael Partner Bankruptcy 

Castaldi, Angelo M. Associate Litigation 

Sardina, Jessey N. Paralegal Bankruptcy 

ERS (Matter ID 003) 

– N/A

HTA (Matter ID 004) 

Name Title or Position Department, Group, or

Section

Arrastia, John Partner Litigation 

Kobra & Kim Report (Matter ID 005) 

 – N/A

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SCHEDULE 2

 MONTHLY STATEMENTS COVERED IN APPLICATION

(Attached Hereto)

DATE 

PERIOD 

COVERED 

TOTAL 

FEES 

20% 

DISCOUNT 

FEES 

REQUESTED 

(90%) 

HOLDBACK 

(10%) 

EXPENSES 

REQUESTED 

June 30, 

2022 January 1, 2022 – January 31, 2022 $89,400.00 $17,880.00 $64,368.00 $7,152.00 $0.00 

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June 30, 2022 

Via Electronic Mail 

The Commonwealth of Puerto Rico 

Puerto Rico Fiscal Agency and Financial Advisory Authority 

c/o O’Melveny & Myers, LLP 

Time Square Tower 

7 Times Square 

New York, NY 10036 

Attn: John J. Rapisardi, Esq., Suzzanne Uhland, Esq.,Peter Friedman, Esq. and Diana M. Perez, 

Esq. 

Re: In re Commonwealth of Puerto Rico, et al. Case No. 17-BK-3283 (LTS) 

(Jointly Administered) – 

 Genovese, Joblove & Battista, P.A. January 2022 Fee Statement 

Dear Mr. Rapisardi, Ms. Uhland, Mr. Friedman, and Ms. Perez: 

 By order entered May 31, 2019 (the “Retention Order”), the U.S. District Court for the 

District of Puerto Rico authorized the employment and retention of Genovese, Joblove & 

Battista, P.A. (“GJB”) as special litigation counsel to the Official Committee of Unsecured 

Creditors. 

 In accordance with the second interim compensation order, dated June 6, 2018 (the 

“Interim Compensation Order”) please find enclosed copies of GJB’s January 2022 Fee 

Statement (the “January Fee Statement”) for certain services rendered and expenses incurred 

during the period ending January 31, 2022. 

 In accordance with the Interim Compensation Order, I hereby certify that no public 

servant of the Department of Treasury and no employee of the Puerto Rico Highways and 

Transportation Authority, the Employees Retirement Systems of the Government of the 

Commonwealth of Puerto Rico, or the Puerto Rico Electric Power Authority is a party to or has 

any 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 Committee.1 The amount shown on the attached invoices is reasonable. The services were 

rendered and the corresponding payment has not been made. To the best of my knowledge, GJB 

does not have any debts owed to the Government of Puerto Rico or its instrumentalities. 

                                                            

1

 For the avoidance of doubt, in accordance with the Retention Order, the Debtors are responsible for the 

compensation of GJB’s fees and reimbursement of its expenses, and under no circumstances are the Committee 

members responsible for payment of GJB’s fees and expenses. 

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2 

 Further, in accordance with the Interim Compensation Order, please see attached as 

Exhibit “A” the certification authorizing the submission of the January Fee Statement. Also 

attached hereto as Exhibit “B” is the related Declaration regarding fees and expenses related to 

the activities undertaken in Puerto Rico vs. outside of Puerto Rico. 

 A summary of the breakdown of fees and expenses in the January Fee Statement is 

provided below for your ease of reference. 

1. Commonwealth of Puerto Rico 001 Matter 

 i. Services rendered outside of Puerto Rico 

Matter Matter 

Name 

Invoice 

Number 

Fees 20% 

Discount 

($3,249.60) 

Fees 

Requested 

to be Paid 

(90%) 

Expenses 

Requested 

to be Paid 

(100%) 

Fees & 

Expenses 

Requested 

to be Paid 

12272-

001 

Promesa 

Special 

Conflicts 

Counsel 

106315 $16,248.00 $12,998.40 $11,698.56 $0.00 $11,698.56 

2. Puerto Rico Electric Power Authority (“PREPA”) 002 Matter 

 i. Services rendered outside Puerto Rico 

Matter Matter 

Name 

Invoice 

Number 

Fees 20% 

Discount 

($14,584.40) 

Fees 

Requested 

to be Paid 

(90%) 

Expenses 

Requested 

to be Paid 

(100%) 

Fees & 

Expenses 

Requested 

to be Paid 

12272-

002 

PREPA 

Adversary 

106316 $72,922.00 $58,337.60 $52,503.84 $0.00 $52,503.84 

3. HTA Litigation (“HTA”) 004 Matter 

 i. Services rendered outside Puerto Rico 

Matter Matter 

Name 

Invoice 

Number 

Fees 20% 

Discount 

($46.00) 

Fees 

Requested 

to be Paid 

(90%) 

Expenses 

Requested 

to be Paid 

(100%) 

Fees & 

Expenses 

Requested 

to be Paid 

12272-

004 

HTA 

Litigation 

16317 $230.00 $184.00 $165.60 $0.00 $165.60 

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3 

Under the Retention Order (¶2, page 2), GJB agreed to reduce its regular hourly rates by 

twenty (20%) percent. The attached invoices reflect the full amount billed by GJB for fees in the 

amount of $89,400.00 plus costs of $0.00 for a total of $89,400.00. The travel times that appear 

on the invoice have been adjusted to fifty (50%) percent of the billing rate. The twenty (20%) 

percent discount applied to fees in January is equal to $17,880.00. The costs are $0.00. 

Accordingly, GJB seeks payment of $64,368.00 in fees (90% of the total discounted fees) and 

$0.00 in costs (100% of the costs) as detailed in the January Fee Statement for a total of 

$64,368.00. 

 

 Any objections you may have to the January Fee Statement should be served on GJB and 

the other Notice Parties so as to be received on or before 4:00 pm (Atlantic Standard Time) on 

the 10th day (or the next business day if such day is not a business day) following service of the 

January Fee Statement, which July 11, 2022 (“Objection Deadline”). If no party serves an 

objection to the January Fee Statement on GJB and the other Notice Parties attached hereto as 

Exhibit “C” so as to be received by the Objection Deadline, GJB respectfully requests payment 

of $64,368.00 to the following account: 

Wiring and ACH Instructions: 

 Beneficiary Bank: City National Bank of Florida 

Beneficiary Bank Address: 100 SE 2nd Street, Miami, FL 33131 

Beneficiary Bank ABA: 066004367 

Beneficiary Bank SWIFT: CNBFUS3M 

Beneficiary Name: GENOVESE JOBLOVE & BATTISTA PA 

Beneficiary Account: 30000160777 

 If an objection is timely served with respect to the January Fee Statement, GJB requests 

payment of 90% of the requested fees and 100% of the requested costs that are not subject to 

such Objection, in accordance with the Interim Compensation Order. 

 Please let me know if you have any questions regarding any of the foregoing. 

 Sincerely, 

/s/ Mariaelena Gayo- Guitian 

 Mariaelena Gayo-Guitian, Esq. 

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Document Page 67 of 140
Exhibit A 

Certification

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PRINCIPAL CERTIFICATION 

I, Alvin Velazquez, on behalf of the Service Employees International Union, solely in its 

capacity as a member of the Official Committee of Unsecured Creditors of the Title III Debtors 

(other than COFINA) (the “Committee”) (and not in its individual capacity), hereby certify that 

the Committee has approved Genovese Joblove & Battista, P.A.’s January fee statement for 

certain services rendered and expenses incurred during the period ending January 31, 2022. 

/s/ Alvin Velazquez 

Name: Alvin Velazquez 

Company: Service Employees International 

Union 

Dated: June 30, 2022 

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Document Page 69 of 140
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Document Page 70 of 140
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Document Page 71 of 140
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Document Page 72 of 140
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Exhibit C 

Notice Parties 

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Counsel for the Oversight Board

Proskauer Rose LLP 

Eleven Times Square 

New York, NY 

10036

Attn: Martin J. Bienenstock, Esq.

Ehud Barak Esq. and 

Proskauer Rose LLP,

70 West Madison 

Street, Chicago, IL 

60602

Attn: Paul V. Possinger, Esq. 

and 

O’Neill & Borges LLC

250 Mulioz Rivera Ave., Suite 800 

San Juan, PR 00918

Attn: Hermann D. Bauer, Esq.

Counsel for the Puerto Rico Fiscal Agency and Financial Advisory Authority

Marini Pietrantoni Muniz 

LLC MCS Plaza, Suite 500

255 Ponce de Le6n Ave

San Juan, PR 00917

Attn: Luis C. Marini-Biaggi, Esq.

Carolina Velaz-Rivero Esq. 

The Office of the United States Trustee for the District of Puerto Rico 

Edificio Ochoa 

500 Tanca Street, Suite 301 

San Juan, Puerto Rico 00901 (re: In Commonwealth of Puerto Rico) 

Counsel for the Official Committee of Unsecured Creditors 

 Paul Hastings 

 200 Park Avenue 

 New York, NY 10166 

 Attn: Luc A. Despins, Esq. 

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Counsel for the Official Committee of Unsecured Creditors 

Casillas, Santiago & Torres, LLC 

El Caribe office Building 

53 Palmeras Street, Ste. 1601 

San Juan, Puerto Rico 00901 

Attn: Juan J . Casillas Ayala, Esq. 

Alberto J.E. Aneses Negron, Esq. 

Counsel for the Fee Examiner

Godfrey & Kahn S.C.

One East Main Street, Suite 500

Madison, Wisconsin 53703-3300

Attn: Katherine Stadler, Esq. 

and 

 EDGE Legal Strategies, PSG

252 Ponce de Le6n 

Avenue Citibank Tower, 

12th Floor San Juan, PR 

00918

Attn: Eyck 0. Luge

U.S. Trustee

Office of the United States Trustee for the District of Puerto Rico

Edificio Ochoa

500 Tanca Street, Suite 301

San Juan, PR 00901 (re: In re: Commonwealth of Puerto Rico)

Counsel for the Official Committee of Retired Employees

Jenner & Block LLP

919 Third Ave.

New York, NY 10022

Attn: Robert Gordon, Esq.

Richard Levin, Esq. 

and

Jenner & Block LLP

353 N. Clark Street

Chicago, IL 60654

Attn: Catherine Steege, Esq.

Melissa Root, Esq. 

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Document Page 76 of 140
and

Bennazar, Garcia & Milian, C.S.P.

Edificio Union Plaza, PH-A,

416 Ave. Ponce de Leon

Hate Rey, PR 00918

Attn: A.J. Bennazar-Zequeira, Esq. 

Puerto Rico Department of Treasury

Puerto Rico Department of 

Treasury

PO Box 9024140

San Juan, PR 00902-4140

Attn: Reylam Guerra Goderich, Deputy Assistant of Central Accounting

Omar E. Rodriguez Perez, CPA, Assistant Secretary of Central Accounting

Angel L. Pantoja Rodriguez, Deputy Assistant Secretary of Internal Revenue and Tax 

Policy

Francisco Pares Alicea, Assistant Secretary of Internal Revenue and Tax Policy

Francisco Pefia Montanez, CPA, Assistant Secretary of the Treasury

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Document Page 77 of 140
Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

Employer ID# 65-0518134

 PROMESA - Official Committee of Unsecured Creditors June 07, 2022

 , Please Refer to

Invoice Number: 106315

GJB Tax I.D. No.: 65-0518134

 RE: PROMESA: Official Committee of Unsecured Creditors /

 Special Conflict Counsel

 SUMMARY / REMITTANCE COPY

 Client/Matter # 012272-000001

 PROMESA - Official Committee of Unsecured Creditors

 PROMESA: Official Committee of Unsecured Creditors /

 (Services rendered outside of Puerto Rico)

 For fees for professional services

 for the period ending January 31, 2022 $16,248.00

 Current Fees and Costs Due $16,248.00

 We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

 remittance address below:

 TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

 to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

 kforrest @ gjb-law.com and requesting written and verbal confirmation.

Remittance Address Wire and ACH/Wire Instructions:

 Genovese Joblove & Battista, P.A. Beneficiary Bank: City National Bank of Florida

 Attn.: Accounts Receivable 100 SE 2nd Street

 100 Southeast Second Street, 44th FL Miami, FL 33131

 Miami, FL 33131 ABA Routing Number: 066004367

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

 For payment, please reference the invoice, client and matter number(s) being paid.

 Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

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Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone: (305) 349-2300 Facsimile: (305) 349-2310

Employer ID# 65-0518134

 PROMESA - Official Committee of Unsecured Creditors June 07, 2022

 , Please Refer to

Invoice Number: 106315

GJB Tax I.D. No.: 65-0518134

 RE: PROMESA: Official Committee of Unsecured Creditors /

 Special Conflict Counsel

 For Professional Services Rendered

 for the period endingJanuary 31, 2022

Date Initials Description Hours Rate Amount

 B110Case Administration

 1/5/2022 MAF Attend transition meeting regarding 0.70 $550.00 $385.00

 non-underwriter FT claims among SCC and

 UCC/litigation trust teams (0.7). [B110]

 1/11/2022 MAF Review emails concerning status of confirmation 0.20 $550.00 $110.00

 order circulated among UCC group (0.2). [B110]

 1/12/2022 MAF Call with JA regarding issues surrounding 1.30 $550.00 $715.00

 amendment to complaint (0.9); review several

 emails among UCC and SCC group concerning

 the same (0.4). [B110]

 B113Pleadings Review

 1/3/2022 JAD Review and analyze all court filings in Main 1.20 $315.00 $378.00

 Case, Title III cases, and adversary proceedings

 for December 31, 2021 through January 3, 2022

 in order to prepare digest of matters relevant to

 special litigation counsel, prepare digest of

 filings, direct paraprofessionals to calendar

 appropriate deadlines, and circulate summary.

 [B113]

 1/5/2022 JAD Conference call with counsel for Creditors' 1.30 $315.00 $409.50

 Committee to discuss status of proceedings,

 pertinent litigation issues, pending motions, and

 budget (.5); review and analyze all court filings in

 Main Case, Title III cases, and adversary

 proceedings for January 4 and 5, 2022 in order

 to prepare digest of matters relevant to special

 litigation counsel, prepare digest of filings, direct

 paraprofessionals to calendar appropriate

 deadlines, and circulate summary (8). [B113]

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 012272 - 000001

 Invoice No. 106315

Date Initials Description Hours Rate Amount

 B113Pleadings Review

 1/11/2022 JAD Review and analyze all court filings in Main 1.30 $315.00 $409.50

 Case, Title III cases, and adversary proceedings

 for January 7 through January 11, 2022 in order

 to prepare digest of matters relevant to special

 litigation counsel, prepare digest of filings, direct

 paraprofessionals to calendar appropriate

 deadlines, and circulate summary. [B113]

 1/17/2022 JAD Review and analyze all court filings in Main 1.70 $315.00 $535.50

 Case, Title III cases, and adversary proceedings

 for January 14 through January 17, 2022 in order

 to prepare digest of matters relevant to special

 litigation counsel, prepare digest of filings, direct

 paraprofessionals to calendar appropriate

 deadlines, and circulate summary. [B113]

 1/18/2022 JAD Review and analyze all court filings in Main 0.80 $315.00 $252.00

 Case, Title III cases, and adversary proceedings

 for January 18, 2022 in order to prepare digest of

 matters relevant to special litigation counsel,

 prepare digest of filings, direct paraprofessionals

 to calendar appropriate deadlines, and circulate

 summary. [B113]

 1/19/2022 JAD Review and analyze all court filings in Main 2.60 $315.00 $819.00

 Case, Title III cases, and adversary proceedings

 for January 19, 2022 in order to prepare digest of

 matters relevant to special litigation counsel,

 prepare digest of filings, direct paraprofessionals

 to calendar appropriate deadlines, and circulate

 summary. [B113]

 1/21/2022 JAD Review and analyze all court filings in Main 0.90 $315.00 $283.50

 Case, Title III cases, and adversary proceedings

 for January 20 and 21, 2022 in order to prepare

 digest of matters relevant to special litigation

 counsel, prepare digest of filings, direct

 paraprofessionals to calendar appropriate

 deadlines, and circulate summary. [B113]

 1/25/2022 JAD Review and analyze all court filings in Main 1.80 $315.00 $567.00

 Case, Title III cases, and adversary proceedings

 for January 20 through 25, 2022 in order to

 prepare digest of matters relevant to special

 litigation counsel, prepare digest of filings, direct

 paraprofessionals to calendar appropriate

 deadlines, and circulate summary. [B113]

 1/28/2022 JAD Review and analyze all court filings in Main 1.40 $315.00 $441.00

 Case, Title III cases, and adversary proceedings

 for January 26 through 28, 2022 in order to

 prepare digest of matters relevant to special

 litigation counsel, prepare digest of filings, direct

 paraprofessionals to calendar appropriate

 deadlines, and circulate summary. [B113]

 B160Fee/Employment Applications

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 Invoice No. 106315

Date Initials Description Hours Rate Amount

 B160Fee/Employment Applications

 1/5/2022 CBH Receipt and review of invoices and statement for 0.40 $195.00 $78.00

 October 2021; download and organization.

 [B160]

 1/7/2022 CAS Preparation of Monthly Fee Cover Letter for 0.50 $150.00 $75.00

 November, 2021. [B160]

 1/7/2022 CAS Service of the Monthly Fee Cover Letter and fee 0.40 $150.00 $60.00

 statement for November, 2021 to the fee

 examiner, U.S. Trustee for the District of Puerto

 Rico and the Oversight Board. [B160]

 1/7/2022 CAS Service of the Monthly Fee Cover Letter and fee 0.40 $150.00 $60.00

 statement for October, 2021 to the fee examiner,

 U.S. Trustee for the District of Puerto Rico and

 the Oversight Board. [B160]

 1/7/2022 CAS Calendar the deadline to object to the monthly 0.20 $150.00 $30.00

 fee statements for October and November.

 [B160]

 1/26/2022 JA Review and revise Fee Statements. [B160] 0.30 $575.00 $172.50

 1/27/2022 JA Revise Fee Statements in conformity with Fee 0.30 $575.00 $172.50

 Examiner Guidelines. [B160]

 1/27/2022 JA Review correspondence from Fee Examiner (.2); 0.30 $575.00 $172.50

 email correspondence with Fee Examiner (.1).

 [B160]

 1/27/2022 CAS Circulate February 2022 Budget. [B160] 0.20 $150.00 $30.00

 1/31/2022 JA Review Memorandum from Fee Examiner 0.30 $575.00 $172.50

 relating to Final Fee Applications. [B160]

 1/31/2022 JA Revise Fee Statements in confirmity with Fee 0.40 $575.00 $230.00

 Examiner Guidelines. [B160]

 B161Budgeting

 1/14/2022 JA Prepare draft budget. [B161] 0.60 $575.00 $345.00

 B170Fee/Employment Objections

 1/7/2022 CAS Preparation of Monthly Fee Cover Letter for 0.50 $150.00 $75.00

 October, 2021. [B170]

 B191General Litigation

 1/3/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/4/2022 JA Revise and analyze Appellate Decision 0.70 $575.00 $402.50

 concerning Monoline action against underwriters.

 [B191]

 1/4/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/4/2022 JNS Attention to email dated December 29, 2021, 0.30 $75.00 $22.50

 from counsel at BrownRudnick regarding tolling

 agreement (URS and Petrowest) extension for

 agreements with termination date on December

 31, 2021. Print review and and update case file,

 tracking chart and calendar events. [B191]

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 012272 - 000001

 Invoice No. 106315

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/5/2022 JA Confer with UCC regarding pending cases, 0.50 $575.00 $287.50

 issues & strategy. [B191]

 1/5/2022 JA Confer with SCC regarding transfer of files and 0.90 $575.00 $517.50

 information to Avoidance Action Trust (.5); confer

 and strategize with A. Castaldi and J. Suarez

 (.4). [B191]

 1/5/2022 JA Review DGC FA Insolvency Analysis. [B191] 0.60 $575.00 $345.00

 1/5/2022 AMC Telephone conference with counsel for SCC. 0.70 $350.00 $245.00

 [B191]

 1/5/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/6/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/6/2022 JNS Attention to email dated December 29, 2021, 0.40 $75.00 $30.00

 from counsel at BrownRudnick regarding tolling

 agreement (Cabrera Auto Group, Genesis

 Security and Petrobas) extension for agreements

 with termination date on December 31, 2021.

 Print review and and update case file, tracking

 chart and calendar events. [B191]

 1/7/2022 JA Review correspondence from SCC regarding 0.50 $575.00 $287.50

 transition of Avoidance Actions (.2); review and

 analyze current matters to be transferred (.3).

 [B191]

 1/7/2022 JNS Review of daily litigation summary prepared by J. 0.40 $75.00 $30.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/10/2022 JA Receive correspondence regarding Motion to 1.70 $575.00 $977.50

 Terminate Stay in Avoidance Action (.2); confer

 with D. Mack (.2); review update on confirmation

 and MBIA/National Motion for Reconciliation (.4);

 review court order on confirmation issues and

 proposed findings of fact and proposed order

 (.6); strategize (.3). [B191]

 1/10/2022 MAF Review memo from PR counsel regarding LPRA 2.20 $550.00 $1,210.00

 avoidance claims, potential pitfalls, strategic

 issues and recommendations for re-pleading

 under various theories (0.8); conference with

 SCC and UCC group regarding strategic issues

 with respect to draft completion, pleading issues,

 legal issues, list of tasks (1.0); post call

 conference with UCC counsel group regarding

 the foregoing (0.4). [B191]

 1/10/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/11/2022 JA Review multiple updates regarding confirmation. 0.30 $575.00 $172.50

 [B191]

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 012272 - 000001

 Invoice No. 106315

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/11/2022 AMC Review and analyze Court's Order regarding 1.30 $350.00 $455.00

 plan modifications (DE 19721) and analyze

 filings concerning status of pre-emption issues

 implicated by Adv. Proc. 20-119 (.4), and

 review, consider, and analyze proposed

 confirmation order and corresponding findings of

 fact (DE 19721-1, -2) (.9). [B191]

 1/11/2022 AMC Review and analyze provisions of Modified 0.30 $350.00 $105.00

 Eighth Amended Title III Joint Plan of Adjustment

 of the Commonwealth of Puerto Rico concerning

 plan consummation and effective date. [B191]

 1/11/2022 JNS Review of daily litigation summary prepared by J. 0.40 $75.00 $30.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/12/2022 JA Review ISSC Stay Relief Motion. [B191] 0.20 $575.00 $115.00

 1/12/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/13/2022 JA Review communications and issues regarding 0.30 $575.00 $172.50

 inverse condemnation. [B191]

 1/13/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/14/2022 JNS Review of daily litigation summary prepared by J. 0.20 $75.00 $15.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/17/2022 JNS Review of daily litigation summary prepared by J. 0.40 $75.00 $30.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/18/2022 JA Review communication from mediation team 1.10 $575.00 $632.50

 (.2); confer with SCC regarding transition of

 underwriter complaint (.1); confer with client (.1);

 review Findings of Fact to ensure consistency

 with draft (.3); confer with JP Bado regarding

 Kobre Kim Report (.1); review Order Confirming

 Plan for consistency with draft (.3). [B191]

 1/18/2022 AMC Received and analyzed DE 19798, agenda 0.30 $350.00 $105.00

 regarding Jan. 19-20 omnibus hearing. [B191]

 1/18/2022 AMC Reviewed and analyzed the court's findings of 0.70 $350.00 $245.00

 fact re: Confirmation, DE 19812. [B191]

 1/18/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/19/2022 JA Confer with SCC and opposing counsel 0.10 $575.00 $57.50

 regarding transition. [B191]

 1/19/2022 AMC Detailed review and analysis of the Court's 2.30 $350.00 $805.00

 Confirmation Order, and compare against

 provisions of Eighth Amended Plan. [B191]

 1/19/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

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 012272 - 000001

 Invoice No. 106315

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/20/2022 JA Review Order Dissolving Mediation Team. 0.10 $575.00 $57.50

 [B191]

 1/20/2022 JNS Review of daily litigation summary prepared by J. 0.40 $75.00 $30.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/21/2022 JNS Review of daily litigation summary prepared by J. 0.40 $75.00 $30.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/24/2022 JA Attend to tolling issue (.3); confer with 0.50 $575.00 $287.50

 Committee (.2). [B191]

 1/24/2022 JNS Review of daily litigation summary prepared by J. 0.20 $75.00 $15.00

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/25/2022 JA Email correspondence with UCC regarding 0.30 $575.00 $172.50

 tolling (.1); confer with J. Suarez (.2). [B191]

 1/25/2022 AMC Review of Order concerning requiring conferral 0.40 $350.00 $140.00

 [DE 19860], and analyze PRRAD Act concerning

 same (.3); analyze recent stipulation concerning

 tolling of statute(s) of limitation [DE 19857] (.1).

 [B191]

 1/25/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/26/2022 JA Communicate with client regarding tolling issues. 0.20 $575.00 $115.00

 [B191]

 1/26/2022 JNS Review of daily litigation summary prepared by J. 0.40 $75.00 $30.00

 Delgado including calendaring and updating

 electronic case file. Attention to email regarding

 comments and revisions of the draft notice of

 Withdraw. [B191]

 1/27/2022 JNS Review of daily litigation summary prepared by J. 0.30 $75.00 $22.50

 Delgado including calendaring and updating

 electronic case file. [B191]

 1/27/2022 JNS Draft Notice of Withdrawal of Appearance and 0.40 $75.00 $30.00

 Request to Case Service of Jesus M. Suarez.

 [B191]

 1/28/2022 JA Email correspondence to SCC regarding Tolling 0.20 $575.00 $115.00

 Agreements. [B191]

 1/28/2022 AMC Assist with filing and finalizing numerous notices 0.40 $350.00 $140.00

 in main case and adversary proceedings. [B191]

 1/28/2022 JNS Finalize Notices of Withdrawal of Jesus M. 1.40 $75.00 $105.00

 Suarez to be filed in each case where GJB is

 counsel of record. E-File each Notice in its

 respective case. [B191]

 B260Board of Directors Matters

 1/14/2022 JA Committee call regarding case strategy. [B260] 0.50 $575.00 $287.50

 1/18/2022 JA Conference meeting with Committee regarding 0.30 $575.00 $172.50

 case updates. [B260]

 Total 46.20 $16,248.00

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 012272 - 000001

 Invoice No. 106315

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

 JA John Arrastia Senior Partner 11.20 $575.00 $6,440.00

 MAF Michael A. Friedman Partner 4.40 $550.00 $2,420.00

 AMC Angelo M. Castaldi Associate 6.40 $350.00 $2,240.00

 JAD Joyce A. Delgado Associate 13.00 $315.00 $4,095.00

 CBH Colleen B. Hopkins Paralegal 0.40 $195.00 $78.00

 JNS Jessey N. Sardina Paralegal 8.60 $75.00 $645.00

 CAS Carolyn A. Scavone Paralegal 2.20 $150.00 $330.00

 Total 46.20 $16,248.00

 Current Fees and Costs $16,248.00

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 012272 - 000001

 Invoice No. 106315

TASK RECAP

Services Disbursements

Category Hours Amount Category Amount

 B110 2.20 $1,210.00

 B113 13.00 $4,095.00

 B160 3.70 $1,253.00

 B161 0.60 $345.00

 B170 0.50 $75.00

 B191 25.40 $8,810.00

 B260 0.80 $460.00

 46.20 $16,248.00 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

 JA John Arrastia B160 1.60 $920.00

 JA John Arrastia B161 0.60 $345.00

 JA John Arrastia B191 8.20 $4,715.00

 JA John Arrastia B260 0.80 $460.00

 MAF Michael A. Friedman B110 2.20 $1,210.00

 MAF Michael A. Friedman B191 2.20 $1,210.00

 AMC Angelo M. Castaldi B191 6.40 $2,240.00

 JAD Joyce A. Delgado B113 13.00 $4,095.00

 CBH Colleen B. Hopkins B160 0.40 $78.00

 JNS Jessey N. Sardina B191 8.60 $645.00

 CAS Carolyn A. Scavone B160 1.70 $255.00

 CAS Carolyn A. Scavone B170 0.50 $75.00

 46.20 $16,248.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 86 of 140
Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

Employer ID# 65-0518134

 PROMESA - Official Committee of Unsecured Creditors June 07, 2022

 , Please Refer to

Invoice Number: 106316

GJB Tax I.D. No.: 65-0518134

 RE: PROMESA: Official Committee of Unsecured Creditors / PREPA

 Adversary - Puerto Rico Electric Power Authority

 SUMMARY / REMITTANCE COPY

 Client/Matter # 012272-000002

 PROMESA - Official Committee of Unsecured Creditors

 PROMESA: Official Committee of Unsecured Creditors / PREPA

 (Services rendered outside of Puerto Rico)

 For fees for professional services

 for the period ending January 31, 2022 $72,922.00

 Current Fees and Costs Due $72,922.00

 We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

 remittance address below:

 TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

 to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

 kforrest @ gjb-law.com and requesting written and verbal confirmation.

Remittance Address Wire and ACH/Wire Instructions:

 Genovese Joblove & Battista, P.A. Beneficiary Bank: City National Bank of Florida

 Attn.: Accounts Receivable 100 SE 2nd Street

 100 Southeast Second Street, 44th FL Miami, FL 33131

 Miami, FL 33131 ABA Routing Number: 066004367

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

 For payment, please reference the invoice, client and matter number(s) being paid.

 Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 87 of 140
Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone: (305) 349-2300 Facsimile: (305) 349-2310

Employer ID# 65-0518134

 PROMESA - Official Committee of Unsecured Creditors June 07, 2022

 , Please Refer to

Invoice Number: 106316

GJB Tax I.D. No.: 65-0518134

 RE: PROMESA: Official Committee of Unsecured Creditors / PREPA

 Adversary - Puerto Rico Electric Power Authority

 For Professional Services Rendered

 for the period endingJanuary 31, 2022

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/3/2022 JA Confer with D. D'Aquila (.1); review internal 2.80 $575.00 $1,610.00

 memorandum of points and issues (.6); prepare

 for conference with SCC counsel and strategize

 (.4); conduct conference with SCC counsel (.6); 

 Outline revisions to amended complaint and

 strategize (1.;1). [B191]

 1/3/2022 MAF Call with SCC counsel and UCC counsel 2.30 $550.00 $1,265.00

 regarding amended complaint (0.6); consider

 issues related to 10-year claims and conduct

 legal research related to the same (1.7). [B191]

 1/3/2022 AMC Detailed review and analysis of source materials 5.60 $350.00 $1,960.00

 for complaint, and prepare internal working

 memorandum concerning pending issues

 implicated by dispositive motions filed by

 defendants in Adv. P. 19-388 (4.1); Prepare for

 telephonic conference with counsel for the SCC

 (.7); Attend said telephonic conference (.8).

 [B191]

 1/4/2022 JA Revise draft of Amended Complaint with 1.60 $575.00 $920.00

 attention to Motion to Dismiss issues. [B191]

 1/4/2022 MAF Continue legal research concerning 10-year 1.60 $550.00 $880.00

 claims, effect of timing of assessment, related

 legal issues (1.6). [B191]

 1/4/2022 AMC Prepare and revise second amended complaint 8.20 $350.00 $2,870.00

 and conduct related legal research concerning

 the same. [B191]

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 88 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 2

 012272 - 000002

 Invoice No. 106316

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/5/2022 JA Receive and review Court Order on Intervention 3.10 $575.00 $1,782.50

 (.4); analyze impact of Order (.3); confer with and

 brief client (.3); confer and strategize with A.

 Castaldi regarding revisions to Amended

 Complaint in AP 388 (.8); revise draft Amended

 Complaint (1.3). [B191]

 1/5/2022 JHG Review and analysis of Court order regarding 0.30 $765.00 $229.50

 Marrero claims. [B191]

 1/5/2022 MAF Continue legal research concerning 10-year 5.80 $550.00 $3,190.00

 claims (2.2); conference with AC regarding the

 foregoing to prepare for call with SCC counsel

 (0.6); call with JS regarding PR legal research

 question (0.2); review case law dealing with

 section 6502 issues i preparation of discussion

 with SCC counsel (0.5); call with SCC counsel to

 discuss strategy with respect to the foregoing

 and follow up call with AC regarding same (1.5);

 review and analyze order on Marrero Plaintiffs’

 Rule 24 pleading and scope of intervention

 granted under the same (0.8). [B191]

 1/5/2022 AMC Prepare and revise second amended complaint. 3.60 $350.00 $1,260.00

 [B191]

 1/5/2022 AMC Conduct substantial legal research concerning 1.70 $350.00 $595.00

 reasonably equivalent value, pleading standards,

 and burdens concerning the same. [B191]

 1/5/2022 AMC Conference call with counsel to SCC concerning 1.40 $350.00 $490.00

 fraudulent transfer issues. [B191]

 1/5/2022 AMC Conduct substantial legal research concerning 2.30 $350.00 $805.00

 balance sheet insolvency, service insolvency,

 and municipal insolvency. [B191]

 1/6/2022 JA Confer and strategize regarding amendments 3.90 $575.00 $2,242.50

 (.6); legal research and analysis (.4); confer and

 strategize with M. Friedman and A. Castaldi

 regarding potential amendments to complaint

 (.6); revise draft complaint (1.1); strategize with

 J. Genovese (.4); review SCC revisions to draft

 complaint (.6); consider additional claims to

 assert in draft complaint and strategize (.6).

 [B191]

 1/6/2022 JHG Review and analysis of first set of redline to 2.20 $765.00 $1,683.00

 proposed complaint. [B191]

 1/6/2022 JHG Review issues regarding equitable subordination 1.30 $765.00 $994.50

 and 502(h) claims. [B191]

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 89 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 3

 012272 - 000002

 Invoice No. 106316

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/6/2022 MAF Review redline revisions to amended complaint, 3.40 $550.00 $1,870.00

 consider further revisions, apply proposed

 redlines, focus on revisions necessary to 10-year

 transfer claims, review notes from conference

 with SCC counsel concerning the same, apply

 proposed revisions in redline, and circulate

 revisions with comments to UCC counsel group

 (2.6); review several emails among UCC counsel

 regarding strategic issue / decisions with respect

 to draft amendment, potential additional claims,

 additional allegations, and implications related to

 them (0.6); review of emails among UCC and

 SCC counsel groups to discuss status of draft

 amendments (0.2). [B191]

 1/6/2022 AMC Review several technical assessment reports 1.30 $350.00 $455.00

 concerning quality of fuel testing and related

 issues. [B191]

 1/6/2022 AMC Prepare revisions to complaint in Adv. Proc. No. 3.30 $350.00 $1,155.00

 19-388. [B191]

 1/6/2022 AMC Research concerning remedies available under 0.60 $350.00 $210.00

 Section 548(a)(1)(A). [B191]

 1/6/2022 AMC Review of prior requests for proposals re: fuel oil 0.60 $350.00 $210.00

 purchases and materials concerning PREPA's

 purchase of No. 2 and No. 6 fuel. [B191]

 1/7/2022 JA Confer and strategize with A. Castaldi regarding 3.10 $575.00 $1,782.50

 PR law and co-counsel input (.2); review draft

 complaint (.6); review memorandum from PR

 counsel (.3); revire and analyze source materials

 (1.1); revise draft amended complaint (.9).

 [B191]

 1/7/2022 AMC Exhaustive review and analysis of findings of 4.80 $350.00 $1,680.00

 various Puerto Rico investigations concerning

 PREPA, declarations of prior PREPA executives,

 publicly-available discovery in related litigation,

 and other source materials. [B191]

 1/7/2022 AMC Preparation of second amended complaint, and 2.90 $350.00 $1,015.00

 conduct extensive legal research concerning

 equitable subordination and s. 502 concerning

 the same. [B191]

 1/7/2022 AMC Telephone conference with J. Nieves of CST 0.40 $350.00 $140.00

 concerning Puerto Rico fraudulent transfer law.

 [B191]

 1/10/2022 JA Confer with L. Rappaport (.2); revise draft 6.10 $575.00 $3,507.50

 amended complaint (1.6); confer with SCC team

 on revisions (.6); review source materials used in

 drafting (.7); strategize (.6); confer on proposed

 revisions (.8); strategize with A. Castaldi (.4);

 additional revisions to draft (1.2). [B191]

 1/10/2022 JHG Analysis of issues related to amendment to 3.40 $765.00 $2,601.00

 complaint. [B191]

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 90 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 4

 012272 - 000002

 Invoice No. 106316

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/10/2022 AMC Review and analysis of legislative materials 1.40 $350.00 $490.00

 submitted by La Comisión Especial para el

 Estudio de las Normas y Procedimientos

 Relacionados con la Compra y Uso de Petróleo

 por la Autoridad de Energía Eléctrica y de

 Integridad Gubernamental. [B191]

 1/10/2022 AMC Preparation for telephone conference with the 1.60 $350.00 $560.00

 Special Claims Committee counsel. [B191]

 1/10/2022 AMC Prepare and revise second amended complaint. 1.30 $350.00 $455.00

 [B191]

 1/10/2022 AMC Research and analysis of sections 3492 and 1.40 $350.00 $490.00

 3493 of the LPRA and cases applying the same.

 [B191]

 1/10/2022 AMC Telephone conference with counsel for SCC and 1.40 $350.00 $490.00

 brief post-conference debrief internally. [B191]

 1/10/2022 AMC Review and analyze EPA consent decree 0.60 $350.00 $210.00

 between PREPA and EPA. [B191]

 1/10/2022 AMC Strategize internally concerning second 0.40 $350.00 $140.00

 amended complaint. [B191]

 1/11/2022 JA Confer with L. Rappaport (.3); revise draft (1.9); 6.80 $575.00 $3,910.00

 strategize with A. Castaldi (.4); strategize with L.

 Rappaport (.4); review expert reports for source

 information (.6); review pleadings in Marrero

 Class Action to ensure consistency (1.7); confer

 with SCC (.3); strategize and confer with A.

 Castaldi (.6) confer with SCC (.3); additional

 revisions to draft (.3). [B191]

 1/11/2022 JMS Research issues concerning Trustee/Fiduciary 1.60 $500.00 $800.00

 Pleading Standard in support of amended

 complaint (1.6). [B191]

 1/11/2022 AMC Prepare revisions to second amended complaint. 3.40 $350.00 $1,190.00

 [B191]

 1/11/2022 AMC Conduct legal research concerning bad faith / 1.10 $350.00 $385.00

 dolo claims under Puerto Rico law and review

 Articles 1054 and 1220 of the Puerto Rico Civil

 Code concerning same. [B191]

 1/11/2022 AMC Comprehensive and extensive review and 3.20 $350.00 $1,120.00

 analysis of PREPA 100+ page responsive

 pleadings in pending litigation and compare

 same against allegations in affirmative

 complaints, and strategize internally concerning

 the same. [B191]

 1/11/2022 AMC Review of Vitol and Trafigura fuel contracts. 0.70 $350.00 $245.00

 [B191]

 1/12/2022 JA Review production of source documents (1.8); 7.40 $575.00 $4,255.00

 review exhibits (1.1); confer with CST regarding

 source documents (.1); confer with SCC

 (multiple) (1.1); revise motion (.8); revise draft of

 amended complaint (2.1); prepare

 correspondence to Committee (.4). [B191]

 1/12/2022 JHG Review email regarding transmittal of amended 0.20 $765.00 $153.00

 complaint and issues. [B191]

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 91 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 5

 012272 - 000002

 Invoice No. 106316

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/12/2022 JHG Review Doc. 117 in case 19-00388 LTS. [B191] 0.10 $765.00 $76.50

 1/12/2022 JHG Extensive review and analysis of email regarding 0.80 $765.00 $612.00

 proposed edits to amended complaint. [B191]

 1/12/2022 JHG Extensive review of second amended complaint. 2.40 $765.00 $1,836.00

 [B191]

 1/12/2022 JHG Review issues regarding filing joint status report. 0.40 $765.00 $306.00

 [B191]

 1/12/2022 JHG Attend telephone conference regarding amended 0.70 $765.00 $535.50

 complaint. [B191]

 1/12/2022 JMS Provide proposed changes to amended 2.90 $500.00 $1,450.00

 complaint against Fuel Oil Defendants. (1.6);

 attention to conferences with FOMB/SCC

 counsel and additional revisions thereto (1.3).

 [B191]

 1/12/2022 MAF Call with JA regarding issues surrounding 2.70 $550.00 $1,485.00

 amendment to complaint (0.9); review several

 emails among UCC and SCC group concerning

 the same (0.4); analyze several emails among

 SCC and UCC itemizing detailed analysis of

 pending outstanding issues with respect to

 proposed amended complaint (0.8); attend call

 with UCC and SCC counsel group to discuss

 pending outstanding issues with respect to draft

 amendment (0.6). [B191]

 1/12/2022 AMC Review and analysis of 2-, 4-, 10-, and 15-year 1.40 $350.00 $490.00

 transfer figures concerning second amended

 complaint and strategize internally concerning

 the same. [B191]

 1/12/2022 AMC Review of provisions of plan concerning 0.40 $350.00 $140.00

 avoidance actions. [B191]

 1/12/2022 AMC Strategize concerning finalizing proposed second 0.20 $350.00 $70.00

 amended complaint. [B191]

 1/12/2022 AMC Prepare revisions to latest iteration of second 2.30 $350.00 $805.00

 amended complaint and strategize internally

 concerning the same. [B191]

 1/12/2022 AMC Review and analyze revisions to second 2.40 $350.00 $840.00

 amended complaint circulated by FOMB

 counsel, and prepare further revisions and

 analysis concerning said document. [B191]

 1/12/2022 AMC Telephone conference with counsel for the SCC 0.70 $350.00 $245.00

 and post-conference debrief with GJB team.

 [B191]

 1/12/2022 AMC Conduct legal research concerning Section 0.70 $350.00 $245.00

 502(h) issues. [B191]

 1/13/2022 JA Email correspondence with Vitol re: joint status 2.60 $575.00 $1,495.00

 (.2); review SCC edits (.4); confer and strategize

 with J. Suarez (.1); confer and strategize with A.

 Castaldi (.3); strategize (.6); confer with SCC

 (.3); review amended complaint (.6); review

 comments from FOMB (.1). [B191]

 1/13/2022 JHG Review additional comments from J. Arrastia 1.30 $765.00 $994.50

 regarding amended complaint. [B191]

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 92 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 6

 012272 - 000002

 Invoice No. 106316

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/13/2022 JHG Review additional draft of second amended 1.70 $765.00 $1,300.50

 complaint. [B191]

 1/13/2022 JHG Review additional emails regarding deleting 0.40 $765.00 $306.00

 certain counts. [B191]

 1/13/2022 JMS Review additional issues concerning revisions to 2.20 $500.00 $1,100.00

 complaint (.7); and revise final draft of complaint

 (1.5). [B191]

 1/13/2022 MAF Review final version of second amended 1.60 $550.00 $880.00

 complaint, and numerous correspondence

 among SCC and UCC counsel group regarding

 revisions to the same (1.6). [B191]

 1/13/2022 AMC Review and analyze finalized exhibits prepared 4.60 $350.00 $1,610.00

 by SCC, compare same against prior analyses /

 versions, and confer internally concerning the

 same (1.2); Review of additional revisions to

 second amended complaint circulated Jan. 12

 (.4); Detailed review and analysis of second

 amended complaint (and, later) the finalized

 amended complaint, prepare revisions to the

 same, attend to internal communications with

 team concerning the same, and communicate

 with Co-Plaintiff's counsel concerning the same

 (2.8); Review and analyze final motion for leave

 to amend (.2). [B191]

 1/13/2022 AMC Prepare, revise, and confer with co-Plaintiff 1.80 $350.00 $630.00

 counsel concerning status report. [B191]

 1/14/2022 JA Review revised status report (.2); email 1.10 $575.00 $632.50

 correspondence with M. Kelso (.1); prepare,

 revise, and finalize Joint Status Report (.4);

 confer with SCC regarding extensions (.1);

 confer with defendants regarding extensions (.1);

 confer with A. Castaldi (.1); review Court Order

 (.1). [B191]

 1/14/2022 JHG Review motion for relief to amend. [B191] 0.70 $765.00 $535.50

 1/14/2022 JHG Review additional proposed edits to second 1.30 $765.00 $994.50

 amended complaint and upon information and

 belief issues. [B191]

 1/14/2022 AMC Review and analyze revisions made by SCC to 0.40 $350.00 $140.00

 joint status report; attend to multiple

 communications with SCC counsel and Vitol

 counsel concerning said report; finalize and

 prepare said report for filing. [B191]

 1/14/2022 JNS Review and Finalize formatting of Joint Status 0.70 $75.00 $52.50

 Report draft, e-file document; download, save

 and circulate to in-house counsel the e-file

 stamped copy of the Joint Status Report. [B191]

 1/17/2022 JHG Review Doc. 126 in 19-00388 status report and 0.10 $765.00 $76.50

 analysis regarding second amended complaint

 and amended answer. [B191]

 1/19/2022 JA Review Government Parties' Status Report. 0.20 $575.00 $115.00

 [B191]

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 93 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 7

 012272 - 000002

 Invoice No. 106316

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/21/2022 JA Confer with opposing counsel regarding 0.40 $575.00 $230.00

 enlargement (.1); confer with SCC (.2); confer

 with opposing counsel (.1). [B191]

 1/24/2022 JA Confer with opposing counsel regarding 0.40 $575.00 $230.00

 enlargement (.1); review draft motion and order

 (.1); confer with SCC (.1); confer with opposing

 counsel (.1). [B191]

 1/25/2022 JA Review Court Order in AP 388. [B191] 0.10 $575.00 $57.50

 1/26/2022 MAF Review status update / analysis of pending 0.20 $550.00 $110.00

 matters impacting GJB’s representation of the

 UCC by J Delgado, consider upcoming tasks

 and deadlines relative to potential conflicts (0.2).

 [B191]

 Total 150.00 $72,922.00

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

 JA John Arrastia Senior Partner 39.60 $575.00 $22,770.00

 JHG John H. Genovese Senior Partner 17.30 $765.00 $13,234.50

 MAF Michael A. Friedman Partner 17.60 $550.00 $9,680.00

 JMS Jesus M. Suarez Partner 6.70 $500.00 $3,350.00

 AMC Angelo M. Castaldi Associate 68.10 $350.00 $23,835.00

 JNS Jessey N. Sardina Paralegal 0.70 $75.00 $52.50

 Total $150.00 $72,922.00

 Current Fees and Costs $72,922.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 94 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 8

 012272 - 000002

 Invoice No. 106316

TASK RECAP

Services Disbursements

Category Hours Amount Category Amount

 B191 150.00 $72,922.00

 150.00 $72,922.00 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

 JA John Arrastia B191 39.60 $22,770.00

 JHG John H. Genovese B191 17.30 $13,234.50

 MAF Michael A. Friedman B191 17.60 $9,680.00

 JMS Jesus M. Suarez B191 6.70 $3,350.00

 AMC Angelo M. Castaldi B191 68.10 $23,835.00

 JNS Jessey N. Sardina B191 0.70 $52.50

150.00 $72,922.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 95 of 140
Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

Employer ID# 65-0518134

 PROMESA - Official Committee of Unsecured Creditors June 07, 2022

 , Please Refer to

Invoice Number: 106317

GJB Tax I.D. No.: 65-0518134

 RE: PROMESA: Official Committee of Unsecured Creditors / HTA

 Litigation - Puerto Rico Highways & Transportation Authority

 SUMMARY / REMITTANCE COPY

 Client/Matter # 012272-000004

 PROMESA - Official Committee of Unsecured Creditors

 PROMESA: Official Committee of Unsecured Creditors / HTA

 (Services rendered outside of Puerto Rico)

 For fees for professional services

 for the period ending January 31, 2022 $230.00

 Current Fees and Costs Due $230.00

 We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

 remittance address below:

 TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

 to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

 kforrest @ gjb-law.com and requesting written and verbal confirmation.

Remittance Address Wire and ACH/Wire Instructions:

 Genovese Joblove & Battista, P.A. Beneficiary Bank: City National Bank of Florida

 Attn.: Accounts Receivable 100 SE 2nd Street

 100 Southeast Second Street, 44th FL Miami, FL 33131

 Miami, FL 33131 ABA Routing Number: 066004367

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

 For payment, please reference the invoice, client and matter number(s) being paid.

 Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 96 of 140
Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone: (305) 349-2300 Facsimile: (305) 349-2310

Employer ID# 65-0518134

 PROMESA - Official Committee of Unsecured Creditors June 07, 2022

 , Please Refer to

Invoice Number: 106317

GJB Tax I.D. No.: 65-0518134

 RE: PROMESA: Official Committee of Unsecured Creditors / HTA

 Litigation - Puerto Rico Highways & Transportation Authority

 For Professional Services Rendered

 for the period endingJanuary 31, 2022

Date Initials Description Hours Rate Amount

 B191General Litigation

 1/21/2022 JA Review HTA GUC Treatment Proposal. [B191] 0.40 $575.00 $230.00

 Total 0.40 $230.00

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

 JA John Arrastia Senior Partner 0.40 $575.00 $230.00

 Total $0.40 $230.00

 Current Fees and Costs $230.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 97 of 140
 PROMESA - Official Committee of Unsecured Creditors Page: 2

 012272 - 000004

 Invoice No. 106317

TASK RECAP

Services Disbursements

Category Hours Amount Category Amount

 B191 0.40 $230.00

 0.40 $230.00 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

 JA John Arrastia B191 0.40 $230.00

0.40 $230.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 98 of 140
November 15, 2022

Invoice Number:107750

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$6,307.00

Costs incurred and advanced $11,383.83

Current Fees and Costs Due $17,690.83

for the period endingFebruary 28, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 99 of 140
November 15, 2022

Please Refer to

107750

For Professional Services Rendered

February 28, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

2/1/2022 JA Conference with Tolled parties regarding case

status (.3); revise settlement materials from

stayed avoidance target (.8); telephone

conference with counsel for avoidance actions

(.3); conference with client (.2). [B110]

1.60 $575.00 $920.00

2/2/2022 JA Conference with SCC & Tolled party counsel

regarding case strategies. [B110]

0.30 $575.00 $172.50

2/2/2022 JA Prepare fee statements i conformity with fee

examiner guidelines. [B110]

0.40 $575.00 $230.00

2/2/2022 JA Conference with client representative regarding

status. [B110]

0.30 $575.00 $172.50

B113 Pleadings Review

2/3/2022 JAD Review correspondence in Title III cases and

adversary proceedings for January 29 through

February 3, 2022 in order to prepare and

circulate brief summary and memorandum of

law. [B113]

2.60 $315.00 $819.00

B160 Fee/Employment Applications

2/28/2022 MGG Confer with Joyce Delgado on deadline for filing

interim application and order setting deadline.

[B160]

0.50 $575.00 $287.50

B191 General Litigation

2/3/2022 JA Review plan confirmation materials (.2); review

motions for stay pending appeal (.3); review

motion for briefing schedule (.1). [B191]

0.60 $575.00 $345.00

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PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.107750

-

Date Initials Description Hours Rate Amount

B191 General Litigation

2/3/2022 JNS Attention to email from Blair M Rinne enclosing

the tolling agreement amendments for

Greenberg Traurig, LLP and Nixon Peabody LL.

Download, review, circulate for signature of

attorney John Arrastia, scan and circulate back

via email to Blair Ronni. Update case file with

executed copies, calendar new deadlines (.6).

[B191]

0.60 $75.00 $45.00

2/4/2022 JA Prepare for and conduct meeting with Tolled

party regarding status of AP280 (.4); prepare for

and conduct meeting with defendant regarding

settlement of claims (.7); conference with Tolled

party regarding avoidance action (.6). [B191]

1.70 $575.00 $977.50

2/4/2022 JNS Attention to e-filed documents (in the absence of

Joyce Delgado). Review Dockets and/or any

document filed int he Promesa matters, circulate

any deadlines. [B191]

0.20 $75.00 $15.00

2/7/2022 JA Continued review of tolling agreement with

various parties. [B191]

0.30 $575.00 $172.50

2/7/2022 JA Conference with SCC regarding status report

(.2); conference with opposing counsel (.1).

[B191]

0.30 $575.00 $172.50

2/7/2022 JNS Attention to e-filed documents (in the absence of

Joyce Delgado). Review Dockets and/or any

document filed int he Promesa matters, circulate

any deadlines. [B191]

0.30 $75.00 $22.50

2/8/2022 JA Alternative to various tolling agreements. [B191] 0.40 $575.00 $230.00

2/8/2022 JNS Attention to e-filed documents (in the absence of

Joyce Delgado). Review Dockets and/or any

document filed int he Promesa matters, circulate

any deadlines. [B191]

0.30 $75.00 $22.50

2/9/2022 JA Conference with SCC regarding transition of

pending litigation. [B191]

0.60 $575.00 $345.00

2/9/2022 JNS Attention to e-filed documents (in the absence of

Joyce Delgado). Review Dockets and/or any

document filed int he Promesa matters, circulate

any deadlines. [B191]

0.30 $75.00 $22.50

2/10/2022 JA Continuing attention to additional Tolling

agreements. [B191]

0.30 $575.00 $172.50

2/10/2022 JNS Attention to e-filed documents (in the absence of

Joyce Delgado). Review Dockets and/or any

document filed int he Promesa matters, circulate

any deadlines. [B191]

0.20 $75.00 $15.00

2/11/2022 JA Continuing attention to tolling agreement. [B191] 0.30 $575.00 $172.50

2/11/2022 AMC Attend to ??? to communications concerning

tolling agreements. [B191]

1.60 $350.00 $560.00

2/11/2022 JNS Attention to email from John Arrastilla requesting

updated chart of Tolling Agreement Deadlines.

Update, download and circulate Tolling

Agreement tracking chart. [B191]

0.30 $75.00 $22.50

2/11/2022 TGM Download new data received; forward to

Trustpoint for loading to Relativity. [B191]

0.40 $120.00 $48.00

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Document Page 101 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.107750

-

Date Initials Description Hours Rate Amount

B211 Financial Reports (Monthly Operating Reports)

2/24/2022 CAS Preparation of Monthly Fee Objection Letter for

October, 2021. [B211]

0.40 $150.00 $60.00

2/24/2022 CAS Service of Monthly Fee Objection Letter for

October, 2021. [B211]

0.20 $150.00 $30.00

2/24/2022 CAS Preparation of Monthly Fee Objection Letter for

September, 2021. [B211]

0.40 $150.00 $60.00

2/24/2022 CAS Service of Monthly Fee Objection Letter for

September, 2021. [B211]

0.20 $150.00 $30.00

2/24/2022 CAS Preparation of Monthly Fee Objection Letter for

November, 2021. [B211]

0.40 $150.00 $60.00

2/24/2022 CAS Service of Monthly Fee Objection Letter for

November, 2021. [B211]

0.20 $150.00 $30.00

2/24/2022 CAS Review of December invoices and preparation of

Monthly Fee Cover Letter for December, 2021.

[B211]

0.50 $150.00 $75.00

Total 16.70 $6,307.00

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

JA John Arrastia Senior Partner 7.10 $575.00 $4,082.50

MGG Mariaelena Gayo-Guitian Partner 0.50 $575.00 $287.50

AMC Angelo M. Castaldi Associate 1.60 $350.00 $560.00

JAD Joyce A. Delgado Associate 2.60 $315.00 $819.00

TGM Tricia Garcia-Montes Paralegal 0.40 $120.00 $48.00

JNS Jessey N. Sardina Paralegal 2.20 $75.00 $165.00

CAS Carolyn A. Scavone Paralegal 2.30 $150.00 $345.00

Total $16.70 $6,307.00

Costs incurrent and advanced

Date Description Amount

01/31/2022 Trustpoint. One- Data management and hosting- Web hosting January

12272-001 [E100 - E124]

$5,768.16

02/28/2022 Trustpoint. One- Data management and hosting- Data hosting

12272-001 [E100 - E123]

$5,615.67

Total Costs incurrent and advanced $11,383.83

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 102 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 4

012272 000001

Invoice No.107750

-

Current Fees and Costs $17,690.83

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Document Page 103 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 5

012272 000001

Invoice No.107750

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 2.60 $1,495.00 E100 - E123 $5,615.67

B113 2.60 $819.00 E100 - E124 $5,768.16

B160 0.50 $287.50

B191 8.70 $3,360.50

B211 2.30 $345.00

16.70 $6,307.00 $11,383.83

BREAKDOWN BY PERSON

Person Category Hours Amount

JA John Arrastia B110 2.60 $1,495.00

JA John Arrastia B191 4.50 $2,587.50

MGG Mariaelena Gayo-Guitian B160 0.50 $287.50

AMC Angelo M. Castaldi B191 1.60 $560.00

JAD Joyce A. Delgado B113 2.60 $819.00

TGM Tricia Garcia-Montes B191 0.40 $48.00

JNS Jessey N. Sardina B191 2.20 $165.00

CAS Carolyn A. Scavone B211 2.30 $345.00

16.70 $6,307.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 104 of 140
November 15, 2022

Invoice Number:107751

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors / PREPA

Adversary - Puerto Rico Electric Power Authority

For fees for professional services

$1,602.50

Current Fees and Costs Due $1,602.50

for the period endingFebruary 28, 2022

Client/Matter # 012272 000002

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors / PREPA

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 105 of 140
November 15, 2022

Please Refer to

107751

For Professional Services Rendered

February 28, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors / PREPA

Adversary - Puerto Rico Electric Power Authority

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

2/3/2022 MAF Review emails among counsel for defendants

and committees regarding conference on certain

claims in amended complaint, discussion of

exhibits, next steps (0.2); emails regarding status

of senate report documents. [B110]

0.30 $550.00 $165.00

B191 General Litigation

2/3/2022 JA Prepare for meeting with inspectorate counsel

(.3); conference with inspectorate counsel (.3);

conference SCC counsel (.3); email

correspondence to inspectorate counsel (.3);

conference with local counsel organizing

investigation (.1). [B191]

1.30 $575.00 $747.50

2/9/2022 JA Conference with opposing counsel (.1);

conference with SCC (.1); initiate draft of status

report (.4). [B191]

0.60 $575.00 $345.00

2/11/2022 JA Finalize status report (.2); conference with

opposing counsel (.1); conference with opposing

counsel regarding meet and conference(.3).

[B191]

0.60 $575.00 $345.00

Total 2.80 $1,602.50

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

JA John Arrastia Senior Partner 2.50 $575.00 $1,437.50

MAF Michael A. Friedman Partner 0.30 $550.00 $165.00

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Document Page 106 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000002

Invoice No.107751

-

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

Total $2.80 $1,602.50

Current Fees and Costs $1,602.50

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 107 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000002

Invoice No.107751

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 0.30 $165.00

B191 2.50 $1,437.50

2.80 $1,602.50 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

JA John Arrastia B191 2.50 $1,437.50

MAF Michael A. Friedman B110 0.30 $165.00

2.80 $1,602.50

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 108 of 140
November 15, 2022

Invoice Number:107745

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$23,237.00

Costs incurred and advanced $450.70

Current Fees and Costs Due $23,687.70

for the period ending March 31, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 109 of 140
November 15, 2022

Please Refer to

107745

For Professional Services Rendered

March 31, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

3/1/2022 CAS Review various orders setting deadlines and

procedures for filing of interim fees. Telephone

conference with J. Delgado. E-mail

correspondence with M. Guitian. [B110]

0.50 $150.00 $75.00

3/8/2022 CAS Research and review various orders setting

Interim Fee Periods for filing fee applications.

[B110]

0.50 $150.00 $75.00

3/29/2022 MGG Review Notice of Filing Amended List of Material

Interest Parties Pursuant to Puerto Rico

Recovery Accuracy Disclosure Act. [B110]

0.50 $575.00 $287.50

B113 Pleadings Review

3/1/2022 JAD Confer with M. Guitian re: review of filings (.8);

review dockets of Title III and adversary cases to

determine status of pending filings (.6); confer

with M. Guitian re: Fee Application (.2); confer

with paralegal C. Scavone re: same (.3); review

of main case docket for Interim Fee Order

procedures (.5). [B113]

2.40 $315.00 $756.00

3/3/2022 JAD Emails with M. Guitian re: Interim Fee Order.

[B113]

0.30 $315.00 $94.50

3/9/2022 JAD Review correspondence with J. Genovese and

M. Guitian re: pending fees and Interim Fee

Application. [B113]

0.30 $315.00 $94.50

3/13/2022 JAD Correspondence with M. Guitian re: Interim Fee

Application. [B113]

0.20 $315.00 $63.00

3/14/2022 JAD Emails with M. Guitian re: Interim Fee

Application (.5); emails with paralegal J. Sardina

re: same (.5); emails with paralegal C. Scavone

re: same (.4). [B113]

1.40 $315.00 $441.00

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Document Page 110 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.107745

-

Date Initials Description Hours Rate Amount

B113 Pleadings Review

3/15/2022 JAD Emails with M. Guitian re: Interim Fee

Application (.9); revise Interim Fee Application

(.5); confer with M. Guitian re: same (.2); confer

with counsel for Fee Examiner (.3); confer with

paralegal C. Scavone re: Interim Fee Application

(.3); confer with V. Lambdin re: same (.6). [B113]

2.80 $315.00 $882.00

3/16/2022 JAD Emails with M. Guitian re: service of Fee

Application (.4); confer with counsel for fee

examiner re: same (.4); provide update to M.

Guitian re: same (.4). [B113]

1.20 $315.00 $378.00

3/18/2022 JAD Emails with M. Guitian re: appearance at

Omnibus Hearing. [B113]

0.30 $315.00 $94.50

3/20/2022 JAD Review emails with M. Guitian re: Interim Fee

Order. [B113]

0.30 $315.00 $94.50

3/21/2022 JAD Emails with counsel for Fee Examiner re:

appearance at Omnibus Hearing (.2); emails with

M. Guitian re: same (.2). [B113]

0.40 $315.00 $126.00

3/29/2022 JAD Emails with M. Guitian re: Notice of Interested

Parties. [B113]

0.20 $315.00 $63.00

B160 Fee/Employment Applications

3/1/2022 MGG Review docket and confirm filing of NOA and

substitution by John Arrastia and Jesus Suarez

(.3) Review copies of filings (.4) Review status

of invoices and notice of interim fee application

deadlines (1.0). Follow up with John Arrastia re:

December invoice (.3) Review outstanding

amounts due to GJB and confer with accounting

on open invoices (.7) Email to Executive

Committee (.5). Work with Carolyn Scavone on

preparation and service of December Invoice

(.4). [B160]

3.60 $575.00 $2,070.00

3/3/2022 MGG Research and review various fee orders re:

produced and deadlines for upcoming Interim

Fee Applications. Various communications with

Carolyn Scavone and Joyce Delgado. [B160]

2.30 $575.00 $1,322.50

3/3/2022 VLL E-mail correspondence with M. Guitian, C.

Scavone and J. Sardina regarding preparing fee

application, review of x-drive for form and reports

of prior fee applications (.4) E-mail

correspondence with M. Guitian regarding order

setting deadlines, review of docket, x-drive,

e-mail correspondence/telephone calls with J.

Sardina and C. Scavone regarding same (1.0).

[B160]

1.40 $150.00 $210.00

3/6/2022 MGG Review Fee Statements and accounting of

payments received for preparation of Interim Fee

Applications. [B160]

1.00 $575.00 $575.00

3/7/2022 MGG Communications with Jessey Sardina re:

preparation of Interim Fee Application. [B160]

0.20 $575.00 $115.00

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Document Page 111 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.107745

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

3/8/2022 MGG Review and confer with C. Scavone re: service of

December Monthly Fee Letter. Follow-up with

Ken Forrest regarding same. (.5). Work on

accounting details for 8th Interim Fee Application

and overall procedures. Review various orders

and deadlines related thereto (1.90). [B160]

2.40 $575.00 $1,380.00

3/8/2022 CAS Finalize December 2022 Monthly Fee Letter.

[B160]

0.60 $150.00 $90.00

3/8/2022 CAS Serve the December 2022 Monthly Fee Letter to

the Fee Examiner, US Trustee and Oversight

Board. Calendar objection deadline. [B160]

0.50 $150.00 $75.00

3/9/2022 MGG Communications with C. Scavone and response

to John Genovese re: status of Budgets and

submission of fee invoices to Committee for

approval. [B160]

0.60 $575.00 $345.00

3/10/2022 MGG Confer with Ken Forrest re; billing recap and

invoices for 8th Interim Fee Period. Review

same. [B160]

1.00 $575.00 $575.00

3/12/2022 MGG Review payment received from Promesa and

summary of application and incorporate into

Interim Fee Application. Various communications

with Ken Forrest re: reports for Interim Fee

Application (1.6). Work on Interim Fee

Application (1.5). [B160]

3.10 $575.00 $1,782.50

3/14/2022 MGG Continued review of invoices and preparation of

8th Interim Fee Application (2.90). Research

docket re: procedures for service and/or filing of

Interim Fee Applications and service on Fee

Examiner (1.0). Review information on Puerto

Rico Recovery Accuracy in Disclosures Act

(PRRADA) (.4). [B160]

4.30 $575.00 $2,472.50

3/14/2022 CAS Organize and review October - December

invoices and billing reports in preparation of the

8th fee application. [B160]

0.30 $150.00 $45.00

3/14/2022 CAS Revise draft of the Eight Fee Application. [B160] 1.50 $150.00 $225.00

3/14/2022 CAS Revise Schedule 2 Monthly Statements Covered

in Application. [B160]

0.40 $150.00 $60.00

3/14/2022 CAS E-mail correspondence and telephone

conferences with K. Forrest re: financial reports.

[B160]

0.60 $150.00 $90.00

3/14/2022 CAS Revise Certification of Mariaelena Gayo-Guitian,

Esq. in Support of Eighth Interim Fee Application

of Genovese, Joblove & Battista. [B160]

0.70 $150.00 $105.00

3/14/2022 CAS Revise Exhibit of Prior Interim Fee Applications.

[B160]

0.40 $150.00 $60.00

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Document Page 112 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 4

012272 000001

Invoice No.107745

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

3/15/2022 MGG Finalize preparation of 8th Interim Fee

Application and updates from Ken Forrest re:

amounts due and hold-back. Revise Summary of

amounts due (6.0) Various communications with

Joyce Delgado re: procedure and

communications with Fee Examiner's counsel re:

procedures for service of Interim Fee Application

(.70). Various communications with Clerk's office

re: filing credentials (.5). Communications with

John Arrastia re: time entries (.4). [B160]

7.60 $575.00 $4,370.00

3/15/2022 CAS Conference with J. Delgado re: Seventh Interim

Fee Order and scheduling of Omnibus Hearings

for 03/23/22. [B160]

0.30 $150.00 $45.00

3/15/2022 CAS Review report of timekeepers by associates,

paralegals, and partners. Attention to blended

hourly rates; Update Eighth Interim Fee

Application. [B160]

0.70 $150.00 $105.00

3/15/2022 CAS Continue revisions to the Eighth Interim Fee

Applications. [B160]

1.80 $150.00 $270.00

3/15/2022 CAS E-mail correspondence to J. Arrastia re:

attendance at hearings during the compensation

period of October through December. [B160]

0.20 $150.00 $30.00

3/15/2022 CAS Review financial reports and update Exhibit C,

Summary of Timekeepers Included In This

Application. [B160]

1.30 $150.00 $195.00

3/15/2022 CAS Compile Exhibit D-1 Budgets for October through

December. [B160]

0.30 $150.00 $45.00

3/15/2022 CAS Revise Exhibit E - Summary of Compensation

Requested by Project Category. [B160]

1.30 $150.00 $195.00

3/15/2022 CAS Revise Exhibit E-2 - Summary of Expense

Reimbursements Requested by Category. [B160]

0.40 $150.00 $60.00

3/15/2022 CAS Revise Exhibit F - Breakdown of Compensation

and Expense Reimbursement. [B160]

0.50 $150.00 $75.00

3/15/2022 CAS Combine and attach Monthly Fee Letters for

October through December. [B160]

0.20 $150.00 $30.00

3/15/2022 CAS Combine and attach monthly invoices for

October through December. [B160]

0.20 $150.00 $30.00

3/15/2022 CAS Conferences with V. Lambdin and J. Sardina re:

electronic filing issues in U.S. Bankruptcy Court

for District of Puerto Rico. [B160]

0.50 $150.00 $75.00

3/15/2022 CAS Finalize and serve Eighth Interim Fee

Application. [B160]

2.00 $150.00 $300.00

3/15/2022 CAS Telephone conference with M. Guitian re:

revisions to Eighth Interim Fee Application.

[B160]

0.70 $150.00 $105.00

3/16/2022 MGG Follow up with counsel to Fee Examiner re:

service of Interim Fee Application in lieu of filing.

Confer with Joyce Delgado regarding same.

[B160]

0.50 $575.00 $287.50

3/16/2022 CAS Interoffice conferences with M. Guitian and J.

Delgado re: updated procedures for filing Eighth

Interim Fee Application. [B160]

0.70 $150.00 $105.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 113 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 5

012272 000001

Invoice No.107745

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

3/18/2022 MGG Communications with Jay Bushman and Ken

Forrest re: invoices from Trustpoint.One. 

Communications with C. Scavone re: monthly

invoices and reimbursement of Trustpoint One

invoices. Follow up with Mr. Forrest. [B160]

0.50 $575.00 $287.50

3/18/2022 MGG Review Certification of Counsel Regarding

Proposed Third Amended Order Setting

Procedures for Interim and Final Compensation

and Reimbursement of Expenses of

Professionals. Communications with Carolyn

Scavone and Joyce Delgado regarding same.

[B160]

0.50 $575.00 $287.50

3/25/2022 MGG Review Promesa invoice for February. 

Comments to Ken Forrest regarding same.

[B160]

0.30 $575.00 $172.50

B170 Fee/Employment Objections

3/14/2022 CAS E-mail correspondence with L. Rice regarding

reports and final invoices for preparation of fee

application. [B170]

0.40 $150.00 $60.00

3/22/2022 MGG Receipt and review Fee Examiners Revised

Report on Uncontested Professional Fee Matters

for Consideration in Connection with the March

23, 2022 Omnibus Hearing. Email to Executive

Committee regarding same. [B170]

0.60 $575.00 $345.00

3/24/2022 MGG Review December fee letter and confer with

Carolyn Scavone regarding same (.4). Follow up

on status of January and February invoices (.4).

[B170]

0.80 $575.00 $460.00

3/24/2022 CAS Preparation of December 2021 Monthly Fee

Objection letter. [B170]

0.40 $150.00 $60.00

3/24/2022 CAS Finalize and serve December 2021 Monthly Fee

Objection letter. [B170]

0.20 $150.00 $30.00

B191 General Litigation

3/8/2022 JNS Attention to e-filed documents (in the absence of

Joyce Degado). Review Dockets and/or any

document filed int he Promesa matters, circulate

any deadlines. [B191]

0.30 $75.00 $22.50

3/14/2022 JNS Review last filed Case Management Order (.3).

Prepare draft Notice of Filing Eighth Fee

Application (.5). Circulate email to Mariaelena

Guitian and Joyce Delgado with upcoming

omnibus hearing dates. (.1). [B191]

0.90 $75.00 $67.50

Total 60.30 $23,237.00

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Document Page 114 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 6

012272 000001

Invoice No.107745

-

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

MGG Mariaelena Gayo-Guitian Partner 29.80 $575.00 $17,135.00

JAD Joyce A. Delgado Associate 9.80 $315.00 $3,087.00

VLL Vonda L. Lambdin Paralegal 1.40 $150.00 $210.00

JNS Jessey N. Sardina Paralegal 1.20 $75.00 $90.00

CAS Carolyn A. Scavone Paralegal 18.10 $150.00 $2,715.00

Total $60.30 $23,237.00

Costs incurrent and advanced

Date Description Amount

03/31/2022 PACER Service Center- Online Research- Searches 12272-001 [E100 -

E106]

$293.70

03/31/2022 PACER Service Center- Online Research- Searches 1272-001 [E100 -

E106]

$157.00

Total Costs incurrent and advanced $450.70

Current Fees and Costs $23,687.70

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 115 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 7

012272 000001

Invoice No.107745

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 1.50 $437.50 E100 - E106 $450.70

B113 9.80 $3,087.00

B160 45.40 $18,667.50

B170 2.40 $955.00

B191 1.20 $90.00

60.30 $23,237.00 $450.70

BREAKDOWN BY PERSON

Person Category Hours Amount

MGG Mariaelena Gayo-Guitian B110 0.50 $287.50

MGG Mariaelena Gayo-Guitian B160 27.90 $16,042.50

MGG Mariaelena Gayo-Guitian B170 1.40 $805.00

JAD Joyce A. Delgado B113 9.80 $3,087.00

VLL Vonda L. Lambdin B160 1.40 $210.00

JNS Jessey N. Sardina B191 1.20 $90.00

CAS Carolyn A. Scavone B110 1.00 $150.00

CAS Carolyn A. Scavone B160 16.10 $2,415.00

CAS Carolyn A. Scavone B170 1.00 $150.00

60.30 $23,237.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 116 of 140
November 15, 2022

Invoice Number:107746

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$1,376.00

Current Fees and Costs Due $1,376.00

for the period endingApril 30, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 117 of 140
November 15, 2022

Please Refer to

107746

For Professional Services Rendered

April 30, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

4/26/2022 MGG Communications with Tricia Garcia-Montes re:

Promesa and Relativity platform. [B110]

0.40 $575.00 $230.00

B113 Pleadings Review

4/1/2022 JAD Review docket, Notice of Interested Parties,

Amended Notice, and Order Approving same to

determine obligations of an interested party

under PRRADA (.5); confer with M. Guitian re:

same (.4). [B113]

0.90 $315.00 $283.50

B160 Fee/Employment Applications

4/1/2022 MGG Review Order Approving List of Material

Interested Parties Pursuant to the Puerto Rico

Recovery Accuracy in Disclosures Act and

application to GJB. Review Notice of Amended

List of Interested Parties. [B160]

1.00 $575.00 $575.00

B191 General Litigation

4/25/2022 MGG Confer with Tricia Garcia-Montes re: PNB

Paribas litigation and e-discovery. [B191]

0.50 $575.00 $287.50

Total 2.80 $1,376.00

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

MGG Mariaelena Gayo-Guitian Partner 1.90 $575.00 $1,092.50

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 118 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.107746

-

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

JAD Joyce A. Delgado Associate 0.90 $315.00 $283.50

Total $2.80 $1,376.00

Current Fees and Costs $1,376.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 119 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.107746

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 0.40 $230.00

B113 0.90 $283.50

B160 1.00 $575.00

B191 0.50 $287.50

2.80 $1,376.00 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

MGG Mariaelena Gayo-Guitian B110 0.40 $230.00

MGG Mariaelena Gayo-Guitian B160 1.00 $575.00

MGG Mariaelena Gayo-Guitian B191 0.50 $287.50

JAD Joyce A. Delgado B113 0.90 $283.50

2.80 $1,376.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 120 of 140
November 15, 2022

Invoice Number:107747

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$7,279.50

Current Fees and Costs Due $7,279.50

for the period ending May 31, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 121 of 140
November 15, 2022

Please Refer to

107747

For Professional Services Rendered

May 31, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

5/2/2022 MGG Review PRRADA disclosure requirements. 

Communications with Joyce Delgado regarding

same. [B110]

1.00 $575.00 $575.00

5/5/2022 MGG Review Ninth Supplemental Verified Statement

of Official Committee of Unsecured Creditors

Pursuant to 2019 and compliane with PPRADA.

[B110]

0.30 $575.00 $172.50

5/9/2022 MGG Review and consider disclosure requirements

and preparation of Disclosure Statement Verified

Statement Disclosing Connections Pursuant to

PRRADA. [B110]

1.00 $575.00 $575.00

5/12/2022 CAS E-mail correspondence to E. Lugo re: fee

examiner confidential letter report on interim fee

applications. [B110]

0.30 $150.00 $45.00

5/20/2022 CAS Follow up with F. Rosado re: payment of

holdbacks to GJB closed bank account and

resolution. [B110]

0.30 $150.00 $45.00

B113 Pleadings Review

5/2/2022 JAD Emails with M. Guitian re: PRRADA disclosures.

[B113]

0.20 $315.00 $63.00

5/9/2022 JAD Review Disclosure Statements to determine

PRRADA requirements (.3); correspondence

with M. Guitian re: Same (.3). [B113]

0.60 $315.00 $189.00

5/13/2022 JAD Review correspondence re: PRRADA

disclosures. [B113]

0.50 $315.00 $157.50

B160 Fee/Employment Applications

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Document Page 122 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.107747

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

5/4/2022 MGG Review email from Hacienda re: GJB Fee

holdbacks. Communications with Ken Forrest

regarding same. [B160]

0.60 $575.00 $345.00

5/4/2022 CAS E-mail correspondence with F. Rosado and K.

Forrest re: holdback period and amounts. [B160]

0.40 $150.00 $60.00

5/10/2022 MGG Meeting with Carolyn Scavone re: request from

Hacienda regarding payment of GJB's

hold-backs for the Thirteenth Interim Period. 

Review request and adjustments by fee

examiner. Communications with accounting

regarding same. [B160]

0.90 $575.00 $517.50

5/12/2022 MGG Work with Carolyn Scavone re: Fee Examiner's

Confidential Letter Report and payment of

hold-backs. [B160]

0.50 $575.00 $287.50

5/13/2022 MGG Review and study PRADA disclosure

requirements. Communications with Nicholas

Hahn regarding PRADA Disclosures. 0. [B160]

3.50 $575.00 $2,012.50

5/16/2022 MGG Receipt and respond to email from Frank

Rosado Mendez : request from Hacienda for

payment of holdbacks. Communications with

Ken Forrest and Carolyn Scavone regarding

same. Review report and breakdown of

amounts owed. [B160]

0.50 $575.00 $287.50

5/16/2022 CAS E-mail correspondence with F. Rosado, K.

Forrest and M. Guitian re: hold back amounts

due by agency. [B160]

0.40 $150.00 $60.00

5/19/2022 MGG Review prebills (.6). Telephone conference with

Lillian Rice (.3). [B160]

0.90 $575.00 $517.50

B191 General Litigation

5/2/2022 TGM Download and categorize e-Discovery received

from BNP Paribas (2.11.22 - 05.06.22); prepare

for forwarding to J. Arrastia at Continental, PLLC,

for processing. [B191]

4.70 $120.00 $564.00

5/4/2022 TGM Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

0.40 $120.00 $48.00

5/5/2022 TGM Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

0.90 $120.00 $108.00

5/6/2022 TGM Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

0.70 $120.00 $84.00

5/10/2022 TGM Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

0.90 $120.00 $108.00

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 123 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.107747

-

Date Initials Description Hours Rate Amount

B191 General Litigation

5/11/2022 TGM Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

0.30 $120.00 $36.00

5/12/2022 TGM Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

1.20 $120.00 $144.00

5/20/2022 TGM `Download and categorize e-Discovery received

today from BNP Paribas; prepare for forwarding

to J. Arrastia at Continental, PLLC, for

processing. [B191]

0.40 $120.00 $48.00

5/31/2022 MGG Conference with Tricia Garcia-Montes re:

handling of documents received and termination

of service. [B191]

0.40 $575.00 $230.00

Total 21.80 $7,279.50

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

MGG Mariaelena Gayo-Guitian Partner 9.60 $575.00 $5,520.00

JAD Joyce A. Delgado Associate 1.30 $315.00 $409.50

TGM Tricia Garcia-Montes Paralegal 9.50 $120.00 $1,140.00

CAS Carolyn A. Scavone Paralegal 1.40 $150.00 $210.00

Total $21.80 $7,279.50

Current Fees and Costs $7,279.50

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 124 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 4

012272 000001

Invoice No.107747

-

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 125 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 5

012272 000001

Invoice No.107747

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 2.90 $1,412.50

B113 1.30 $409.50

B160 7.70 $4,087.50

B191 9.90 $1,370.00

21.80 $7,279.50 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

MGG Mariaelena Gayo-Guitian B110 2.30 $1,322.50

MGG Mariaelena Gayo-Guitian B160 6.90 $3,967.50

MGG Mariaelena Gayo-Guitian B191 0.40 $230.00

JAD Joyce A. Delgado B113 1.30 $409.50

TGM Tricia Garcia-Montes B191 9.50 $1,140.00

CAS Carolyn A. Scavone B110 0.60 $90.00

CAS Carolyn A. Scavone B160 0.80 $120.00

21.80 $7,279.50

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 126 of 140
November 15, 2022

Invoice Number:107748

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$14,956.50

Costs incurred and advanced $88.40

Current Fees and Costs Due $15,044.90

for the period endingJune 30, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 127 of 140
November 15, 2022

Please Refer to

107748

For Professional Services Rendered

June 30, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

6/6/2022 CAS Preparation of draft Supplemental Declaration of

Mariaelena Gayo-Guitian, Esq. Regarding

Retention of Genovese, Joblove & Battista, P.A.,

as Special Litigation Counsel to Official

Committee of Unsecured Creditors. [B110]

0.80 $150.00 $120.00

6/6/2022 CAS Conference with J. Delgado and M. Guitian re:

preparation of the Supplemental Declaration of

Mariaelena Gayo-Guitian, Esq., Regarding

Retention of Genovese, Joblove & Battista, P.A.

[B110]

0.50 $150.00 $75.00

6/29/2022 CAS Interoffice meeting with V. Lambdin re: filing

Unopposed Motion for Extension of Time to file

PRRADA Disclosures; E-mail proposed Order to

Judge for issuance. [B110]

0.50 $150.00 $75.00

6/29/2022 VLL File Unopposed Motion by Genovese Joblove &

Battista PA for Extension of Deadline Nunc Pro

Tunc to File Disclosures in Compliance with the

Requirements Under the Puerto Recovery

Accuracy in Disclosures Act (PRRADA);

telephone conference with C. Scavone and J.

Sardina regarding procedure to submit order.

[B110]

0.60 $150.00 $90.00

B160 Fee/Employment Applications

6/3/2022 MGG Review PRRADA Disclosure requirements and

orders. Review filings by Paul Hastings and

Continental LPPL. [B160]

1.50 $575.00 $862.50

6/6/2022 MGG Continue work on review of PRRADA Disclosure

requirements and preparation of supplemental

disclosures. [B160]

2.50 $575.00 $1,437.50

Case:17-03283-LTS Doc#:22880 Filed:11/15/22 Entered:11/15/22 23:43:29 Desc: Main

Document Page 128 of 140
PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.107748

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

6/6/2022 JAD Confer with M. Guitian and paralegal C. Scavone

re: PRRADA disclosures (1.5); revise Disclosure

Statement to comply with PRRADA (1.2). [B160]

2.70 $315.00 $850.50

6/7/2022 MGG Review Amended MIP List and confer with Joyce

Delgado re: running of new Conflict Check.

[B160]

0.60 $575.00 $345.00

6/7/2022 MGG Communications with Carolyn Scavone re:

services of invoices for January and February

2022. [B160]

0.50 $575.00 $287.50

6/7/2022 JAD Emails with M. Guitian re: Declaration in Support

of PRRADA Disclosures. [B160]

0.30 $315.00 $94.50

6/8/2022 JAD Correspondence with M. Guitian re: Motion for

Extension of Time. [B160]

0.40 $315.00 $126.00

6/9/2022 JAD Correspondence with United States Trustee re:

Motion for Extension of Time (.4). [B160]

0.40 $315.00 $126.00

6/13/2022 JAD Emails with United States Trustee and M. Guitian

re: Motion for Extension of Time (.3). [B160]

0.30 $315.00 $94.50

6/14/2022 MGG Communications with Joyce Delgado re: UST's

position on filing a retroactive motion to extend

deadline for PRRADA Disclosures. [B160]

0.30 $575.00 $172.50

6/14/2022 JAD Review correspondence with M. Guitian and

United States Trustee re: PRRADA Disclosures.

[B160]

0.50 $315.00 $157.50

6/16/2022 MGG Follow up with Joyce Delgado re: PRRADA

disclosures and conflict check. [B160]

0.50 $575.00 $287.50

6/16/2022 JAD Correspondence re: internal conflict check to

ensure compliance with PRRADA disclosure

requirements. [B160]

0.40 $315.00 $126.00

6/17/2022 JAD Review correspondence re: PRRADA

disclosures and Motion for Extension of Time

with M. Guitian. [B160]

0.50 $315.00 $157.50

6/17/2022 JAD Prepare Motion for Extension of Time to file

PRRADA Disclosures (1.8); revise Verified

Statement of GJB (.9). [B160]

2.70 $315.00 $850.50

6/18/2022 MGG Review and revise Motion for Extension of Time

for GJB to file PRRADA Disclosures. [B160]

0.60 $575.00 $345.00

6/18/2022 MGG Review Supplemental PRRADA Declaration.

[B160]

0.80 $575.00 $460.00

6/18/2022 JAD Revise Motion for Extension of Time to file

PRRADA Disclosures (.4); confer with M. Guitian

re: same (.2). [B160]

0.60 $315.00 $189.00

6/22/2022 MGG Review Motion of the United States Trustee For

Amendment of the Third Amended Order Setting

Procedures for Interim and Final Compensation

and Reimbursement of Expenses of

Professionals (ECF No. 20546) and proposed

order (.3). Communications with Joyce Delgado

re: revisions to Supplemental GJB Declaration

(.3). [B160]

0.60 $575.00 $345.00

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PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.107748

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

6/22/2022 JAD Review correspondence with M. Guitian and

conflict check staff re: internal conflict check

reports to ensure compliance with PRRADA.

[B160]

0.40 $315.00 $126.00

6/28/2022 MGG Review Amended MIP List, and 3 conflict check

reports and proposed revisions to Declaration.

[B160]

3.00 $575.00 $1,725.00

6/28/2022 JAD Review correspondence and Orders re: Motion

for Extension of Time. [B160]

0.80 $315.00 $252.00

6/29/2022 JAD Emails with paralegal C. Scavone for filing of

Motion for Extension of Time. [B160]

0.60 $315.00 $189.00

6/29/2022 CAS Review January 2022 invoices and preparation

of Monthly Fee Letter for January, 2022. [B160]

1.00 $150.00 $150.00

6/29/2022 CAS Preparation of Exhibit B Tax Declaration to the

January 2022 Monthly Fee Letter. E-mails with K.

Forrest re: same. [B160]

0.50 $150.00 $75.00

6/30/2022 MGG Work on supplemental Verified Statement for

GJB to disclose connections to Amended MIP

List per PRRADA Disclosure requirements.

[B160]

3.50 $575.00 $2,012.50

6/30/2022 CAS Finalize and serve Monthly Fee Letter for

January 2022 on Fee Examiner, U.S. Trustee,

and Committee of Unsecured Creditors. [B160]

0.50 $150.00 $75.00

6/30/2022 CAS Calendar the objection deadline to the January

2022 Monthly Fee Letter. [B160]

0.20 $150.00 $30.00

B170 Fee/Employment Objections

6/8/2022 MGG Communications with Nicholas Hahn, Esq re:

PRRADA Disclosures and procedures of Fee

Examiner on approval of interim fee application. 

Review procedures. Review February prebills.

[B170]

1.50 $575.00 $862.50

6/9/2022 MGG Communications with Allison Day re: PRRADA

Disclosures and request for information and

documents (1.0). Consider issues with PRRADA

disclosures (1.50). [B170]

2.50 $575.00 $1,437.50

6/14/2022 MGG Communications with Jose Francisco Cartaya re:

professional fee statement as local counsel.

[B170]

0.50 $575.00 $287.50

B191 General Litigation

6/19/2022 TGM Create spreadsheet with total of possible conflict

hits to review re: PROMESA Title III. [B191]

0.50 $120.00 $60.00

Total 34.60 $14,956.50

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

MGG Mariaelena Gayo-Guitian Partner 18.90 $575.00 $10,867.50

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PROMESA - Official Committee of Unsecured Creditors Page: 4

012272 000001

Invoice No.107748

-

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

JAD Joyce A. Delgado Associate 10.60 $315.00 $3,339.00

TGM Tricia Garcia-Montes Paralegal 0.50 $120.00 $60.00

VLL Vonda L. Lambdin Paralegal 0.60 $150.00 $90.00

CAS Carolyn A. Scavone Paralegal 4.00 $150.00 $600.00

Total $34.60 $14,956.50

Costs incurrent and advanced

Date Description Amount

06/30/2022 PACER Service Center- Online Research- Pacer 2nd qtr 2022 [E100 -

E106]

$88.40

Total Costs incurrent and advanced $88.40

Current Fees and Costs $15,044.90

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PROMESA - Official Committee of Unsecured Creditors Page: 5

012272 000001

Invoice No.107748

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 2.40 $360.00 E100 - E106 $88.40

B160 27.20 $11,949.00

B170 4.50 $2,587.50

B191 0.50 $60.00

34.60 $14,956.50 $88.40

BREAKDOWN BY PERSON

Person Category Hours Amount

MGG Mariaelena Gayo-Guitian B160 14.40 $8,280.00

MGG Mariaelena Gayo-Guitian B170 4.50 $2,587.50

JAD Joyce A. Delgado B160 10.60 $3,339.00

TGM Tricia Garcia-Montes B191 0.50 $60.00

VLL Vonda L. Lambdin B110 0.60 $90.00

CAS Carolyn A. Scavone B110 1.80 $270.00

CAS Carolyn A. Scavone B160 2.20 $330.00

34.60 $14,956.50

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November 15, 2022

Invoice Number:107749

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$3,017.00

Current Fees and Costs Due $3,017.00

for the period endingJuly 31, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

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November 15, 2022

Please Refer to

107749

For Professional Services Rendered

July 31, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B110 Case Administration

7/12/2022 CAS Review Order Denying as Moot, GJB's Motion for

Extension of Deadline to file PRRADA

disclosures; Calendar. [B110]

0.30 $150.00 $45.00

7/14/2022 MGG Review email from Allison Day re: disclosures. 

Revise and finalize Verified Statement pursuant

to PRRADA requirements. [B110]

1.50 $575.00 $862.50

B160 Fee/Employment Applications

7/1/2022 MGG Review conflict check reports prepared and

review by Paula Lawson. [B160]

1.00 $575.00 $575.00

7/8/2022 JAD Review correspondence re: Verified Statement.

[B160]

0.30 $315.00 $94.50

7/11/2022 JAD Review correspondence with M. Guitian re:

Verified Statement. [B160]

0.30 $315.00 $94.50

7/15/2022 MGG Finalize and file Verified Statement to comply

with PRRADA Disclosures. [B160]

0.50 $575.00 $287.50

7/15/2022 JAD Review filed Verified Statement. [B160] 0.20 $315.00 $63.00

B170 Fee/Employment Objections

7/1/2022 MGG Email to and from Jessey Sardinia re: Fee

Applications filed by GJB. Receipt and review

Second and Third Fee Applications filed and

disclosure of time entries by Allison Day.

Communications with Ms. Day regarding

disclosures. [B170]

1.60 $575.00 $920.00

B191 General Litigation

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PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.107749

-

Date Initials Description Hours Rate Amount

B191 General Litigation

7/15/2022 CAS Finalize and file Verified Statement of Mariaelena

Gayo-Guitian Regarding Retention of Genovese,

Joblove & Battista, P.A. [B191]

0.50 $150.00 $75.00

Total 6.20 $3,017.00

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

MGG Mariaelena Gayo-Guitian Partner 4.60 $575.00 $2,645.00

JAD Joyce A. Delgado Associate 0.80 $315.00 $252.00

CAS Carolyn A. Scavone Paralegal 0.80 $150.00 $120.00

Total $6.20 $3,017.00

Current Fees and Costs $3,017.00

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PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.107749

-

TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B110 1.80 $907.50

B160 2.30 $1,114.50

B170 1.60 $920.00

B191 0.50 $75.00

6.20 $3,017.00 $0.00

BREAKDOWN BY PERSON

Person Category Hours Amount

MGG Mariaelena Gayo-Guitian B110 1.50 $862.50

MGG Mariaelena Gayo-Guitian B160 1.50 $862.50

MGG Mariaelena Gayo-Guitian B170 1.60 $920.00

JAD Joyce A. Delgado B160 0.80 $252.00

CAS Carolyn A. Scavone B110 0.30 $45.00

CAS Carolyn A. Scavone B191 0.50 $75.00

6.20 $3,017.00

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SCHEDULE 3

PROPOSED ORDER

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

_____________________________________________/

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

ORDER GRANTING NINTH & FINAL INTERIM FEE APPLICATION OF GENOVESE 

JOBLOVE & BATTISTA, P.A. AS SPECIAL LITIGATION COUNSEL TO 

OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES 

RENDERED AND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM JANUARY 1, 2022 – JULY 31, 2022

Upon consideration of the Ninth & Final Fee Application (the “Application”)2 of Genovese 

Joblove & Battista, P.A. (“GJB”), as special litigation counsel to the Official Committee of 

Unsecured Creditors of all Title III Debtors (the “Committee”)3

, for an order pursuant to sections 

316 and 317 of PROMESA, section 503(b) of the Bankruptcy Code made applicable to these cases 

by section 301(a) of PROMESA, Bankruptcy Rule 2016, and Local Rule 2016-1, for allowance of 

 

1

 The Debtors in these 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) 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), (iii) Puerto Rico 

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

Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (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). 

2

 Capitalized terms not defined herein shall have the meanings ascribed to them in the Application. 

3

 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and COFINA. 

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compensation and reimbursement of expenses for the period from January 1, 2022 through July 

31, 2022, the Court hereby FINDS AND DETERMINES that (i) the Court has jurisdiction to 

consider the Application and the relief requested therein pursuant to section 306(a) of PROMESA; 

(ii) venue is proper before this Court pursuant to section 307(a) of PROMESA; (iii) due and proper 

notice of the Application has been provided under the particular circumstances and no other or 

further notice need be provided; (iv) any objections to the Application having been resolved; (v) 

all persons with standing having been afforded the opportunity to be heard on the Application; and 

after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

1. The Application is granted on a final basis. 

2. GJB’s claim for fees and expenses for services rendered during the Application 

Period and reimbursement for actual and necessary expenses incurred during the Application 

Period are hereby allowed in the amounts of $117,740.40 and $11,922.93 respectively. 

3. To the extent the amounts described in paragraph 2 hereof have not already been 

paid pursuant to the Interim Compensation Order, (a) the Debtors are directed to pay GJB the 

outstanding fees in the amount of $117,740.40 which represents 100% of the fees requested within 

fourteen days of the date of this Order, and any such payment shall be made net of any payments 

made by the Debtors pursuant to the Interim Compensation Order, withholding or other applicable 

taxes, and (b) the Debtors are directed to reimburse GJB for its outstanding expenses in the amount 

of $11,922.93, which represents 100% of the expenses requested within fourteen days of the date 

of this Order. 

4. This Court shall retain jurisdiction to hear and determine all matters arising from 

the implementation of this Order. 

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5. GJB is authorized and empowered to take all necessary actions to implement the 

relief granted in this Order. 

6. Notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 

9014, or otherwise, the terms and conditions of this Order shall be immediately effective and 

enforceable upon its entry. 

7. All time periods set forth in this Order shall be calculated in accordance with 

Bankruptcy Rule 9006(a).

Dated:_____________, 2022. ___________________________________________ 

HON. LAURA TAYLOR SWAIN 

UNITED STATES DISTRICT JUDGE

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