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 

------------------------------------------------------------------------- x 

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

 as representative of : Case No. 17-BK-3283 (LTS) 

 : 

THE COMMONWEALTH OF PUERTO RICO, et al., : (Jointly Administered) 

 : 

Debtors.1

 : 

------------------------------------------------------------------------- x 

NOTICE OF HEARING ON FOURTEENTH INTERIM FEE APPLICATION OF 

KROMA ADVERTISING, INC., AS COMMUNICATIONS ADVISOR TO OFFICIAL 

COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES RENDERED AND 

REIMBURSEMENT OF EXPENSES FOR PERIOD FROM 

APRIL 16, 2022 THROUGH AUGUST 15, 2022 

PLEASE TAKE NOTICE that a hearing on the annexed Fourteenth Interim Fee 

Application of Kroma Advertising, Inc., as Communications Advisor to Official Committee of 

Unsecured Creditors, for Services Rendered and Reimbursement of Expenses for Period from 

April 16, 2022 through August 15, 2022 (the “Application”) filed by the Official Committee of 

Unsecured Creditors (the “Committee”),2 pursuant to section 1103(a)(1) of the Bankruptcy Code, 

 

1

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

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

Rico (Bankruptcy Case No. 17-BK-3283- LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico 

Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284-LTS) (Last Four Digits of 

Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case 

No. 17-BK-3567-LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17-BK-3566-LTS) (Last 

Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case 

No. 17- BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-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. 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 1 of 25
2 

made applicable to these cases by section 301 of the Puerto Rico Oversight, Management and 

Economic Stability Act of 2016 (“PROMESA”), will be held before the Honorable Laura Taylor 

Swain, United States District Court Judge, at the United States District Court for the District of 

Puerto Rico, in Room 3, 150 Carlos Chardón Street, Federal Building, Office 150, San Juan, 

Puerto Rico 00918-1767 on February 1, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) (the 

“Hearing”). 

PLEASE TAKE FURTHER NOTICE that any responses or objections (“Objections”) 

to the Application by any party other than the Fee Examiner shall be in writing, shall conform to 

the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules for the District of 

Puerto Rico, shall be filed with the Court (a) by attorneys practicing in the District Court, 

including attorneys admitted pro hac vice, electronically in accordance with rule 5 of the Local 

Rules for the District of Puerto Rico, and (b) by all other parties in interest, by submitting a hard 

copy via mail to the Clerk’s Office, United States District Court, Room 150 Federal Building, 

San Juan, PR 00918-1767 or by hand delivery to the Clerk’s Office, United States District Court, 

150 Carlos Chardon Avenue, Room 150, San Juan, PR 00918, to the extent applicable, and shall 

be served in accordance with the Third Amended Order Setting Procedures for Interim 

Compensation and Reimbursement of Expenses of Professionals [Docket No. 20546] (the 

“Interim Compensation Order”), so as to be so filed and received by the Notice Parties (as 

defined in the Interim Compensation Order) no later than December 5, 2022 at 3:00 p.m. (ET) / 

4:00 p.m. (AST) (the “Objection Deadline”). 

[Remainder of page intentionally left blank.] 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

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3 

PLEASE TAKE FURTHER NOTICE that, in accordance with the Interim 

Compensation Order, if no Objections are timely filed, and if the Fee Examiner issues the Fee 

Examiner Report (as defined in the Interim Compensation Order) recommending approval of the 

Application in full or in part, the Court may grant the Application without a hearing. 

Dated: November 15, 2022 

 

/s/ G. Alexander Bongartz .

PAUL HASTINGS LLP 

Luc A. Despins, Esq. (Pro Hac Vice) 

James R. Bliss, Esq. (Pro Hac Vice) 

Nicholas A. Bassett, Esq. (Pro Hac Vice) 

G. Alexander Bongartz, Esq. (Pro Hac Vice) 

200 Park Avenue 

New York, New York 10166 

Telephone: (212) 318-6000 

lucdespins@paulhastings.com 

jamesbliss@paulhastings.com 

nicholasbassett@paulhastings.com 

alexbongartz@paulhastings.com 

Counsel to the Official Committee of Unsecured 

Creditors 

- and - 

/s/ Juan J. Casillas Ayala .

CASILLAS, SANTIAGO & TORRES LLC 

Juan J. Casillas Ayala, Esq. (USDC - PR 218312) 

Israel Fernández Rodríguez, Esq. (USDC - PR 225004) 

Juan C. Nieves González, Esq. (USDC - PR 231707) 

Cristina B. Fernández Niggemann, Esq. (USDC - PR 

306008) 

PO Box 195075 

San Juan, PR 00919-5075 

Tel.: (787) 523-3434 Fax: (787) 523-3433 

jcasillas@cstlawpr.com 

ifernandez@cstlawpr.com 

jnieves@cstlawpr.com 

cfernandez@cstlawpr.com 

Local Counsel to the Official Committee of Unsecured 

Creditors 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 3 of 25
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 

------------------------------------------------------------------------- x 

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

 as representative of : Case No. 17-BK-3283 (LTS) 

 : 

THE COMMONWEALTH OF PUERTO RICO, et al., : (Jointly Administered) 

 : 

Debtors.1

 : 

------------------------------------------------------------------------- x 

FOURTEENTH INTERIM FEE APPLICATION OF KROMA ADVERTISING, INC., AS 

COMMUNICATIONS ADVISOR TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM APRIL 16, 2022 THROUGH AUGUST 15, 2022 

SUMMARY COVER SHEET 

Name of applicant: Kroma Advertising, Inc. (“Kroma”) 

Authorized to provide professional services to: Official Committee of Unsecured 

Creditors (the “Committee”)2

Date of retention: Order entered February 22, 2018, 

effective as of February 1, 2018 [Docket 

No. 2572] 

 

1

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

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

Rico (Bankruptcy Case No. 17-BK-3283- LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico 

Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284-LTS) (Last Four Digits of 

Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case 

No. 17-BK-3567-LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17-BK-3566-LTS) (Last 

Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case 

No. 17- BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-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. 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

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2 

Period for which compensation and 

reimbursement are sought: 

April 16, 2022 through and including 

August 15, 2022 (the “Application 

Period”)3

Amount of interim compensation sought as 

actual, reasonable, and necessary: 

$20,000.00 

Amount of interim expense reimbursement 

sought as actual, reasonable, and necessary: 

$0.00 

Are your fee or expense totals different from 

the sum of previously-served monthly 

statements for the Application Period? 

No.

Compensation sought in this Application 

already paid pursuant to a monthly 

compensation order but not yet allowed: 

$4,500.00 

Expenses sought in this Application already 

paid pursuant to a monthly compensation order 

but not yet allowed: 

$0.00 

Total compensation approved by interim order 

to date: 

$1,035,000.00 

Total expenses approved by interim order to 

date: 

$23,719.51 

Total allowed compensation paid to date: $1,035,000.00 

Total allowed expenses paid to date: $23,719.51 

 

3

 Fees for the period between April 16, 2022, and May 15, 2022, will be sought pursuant to a 

subsequent interim fee application. 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 5 of 25
3 

MONTHLY FEE REQUESTS TO DATE 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested 

Fees (90%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

10% Fee 

Holdback 

Interim Fee Period: February 15, 2018 through April 15, 2018

4/25/18 2/15/18 - 

3/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

6/1/18 3/16/18 - 

4/15/18 

$27,000.00 $19,509.35 $30,000.00 $19,509.35 $3,000.00 

Total $54,000.00 $19,509.35 $60,000.00 $19,509.35 $6,000.00 

Interim Fee Period: April 16, 2018 through September 15, 2018

8/24/18 4/16/18 - 

5/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

8/24/18 5/16/18 - 

6/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

8/24/18 6/16/18 - 

7/15/18 

$27,000.00 $4,210.16 $30,000.00 $4,210.16 $3,000.00 

9/24/18 7/16/18 - 

8/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

11/8/18 8/16/18 - 

9/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Total $135,000.00 $4,210.16 $150,000.00 $4,210.16 $15,000.00 

 

Interim Fee Period: September 16, 2018 through January 15, 2019

11/21/18 9/16/18 - 

10/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

1/16/19 10/16/18 - 

11/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

2/19/19 11/16/18 - 

12/15/18 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

3/14/19 12/16/18 - 

1/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Total $108,000.00 $0.00 $120,000.00 $0.00 $12,000.00 

Interim Fee Period: January 16, 2019 through May 15, 2019

4/15/19 1/16/19 - 

2/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

5/30/19 2/16/19 - 

3/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 6 of 25
4 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested 

Fees (90%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

10% Fee 

Holdback 

7/3/19 3/16/19 - 

4/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

7/15/19 4/16/19 - 

5/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Total $108,000.00 $0.00 $120,000.00 $0.00 $12,000.00 

Interim Fee Period: May 16, 2019 through September 15, 2019

8/27/19 5/16/19 - 

6/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

10/4/19 6/16/19 - 

7/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

11/13/19 7/16/19 - 

8/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

11/14/19 8/16/19 - 

9/15/19 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

Total $85,500.00 $0.00 $95,000.00 $0.00 $9,500.00 

Interim Fee Period: September 16, 2019 through January 15, 2020

12/23/19 9/16/19 - 

10/15/19 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

1/20/20 10/16/19 - 

11/15/19 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

3/3/20 11/16/19 - 

12/15/19 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

3/13/20 12/16/19 - 

1/15/20 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Total $63,000.00 $0.00 $70,000.00 $0.00 $7,000.00 

Interim Fee Period: January 16, 2020 through May 15, 2020

5/11/20 1/16/20 - 

2/15/20 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

6/8/20 2/16/20 - 

3/15/20 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

7/8/20 3/16/20 - 

4/15/20 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

7/14/20 4/16/20 - 

5/15/20 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

Total $85,500.00 $0.00 $95,000.00 $0.00 $9,500.00 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 7 of 25
5 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested 

Fees (90%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

10% Fee 

Holdback 

Interim Fee Period: May 16, 2020 through September 15, 2020

9/24/20 5/16/20 - 

6/15/20 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

9/25/20 6/16/20 - 

7/15/20 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

10/20/20 7/16/20 - 

8/15/20 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

11/13/20 8/16/20 - 

9/15/20 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

Total $18,000.00 $0.00 $20,000.00 $0.00 $2,000.00 

Interim Fee Period: September 16, 2020 through January 15, 2021

12/23/20 9/16/20 - 

10/15/20 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

1/13/21 10/16/20 -

11/15/20 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

3/11/21 11/16/20 - 

12/15/20 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

3/12/21 12/16/20 - 

1/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Total $85,500.00 $0.00 $95,000.00 $0.00 $9,500.00 

Interim Fee Period: January 16, 2021 through May 15, 2021

5/7/21 1/16/21 - 

2/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

5/12/21 2/16/21 - 

3/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

7/14/21 3/16/21 - 

4/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

7/15/21 4/16/21 - 

5/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Total $108,000.00 $0.00 $120,000.00 $0.00 $12,000.00 

Interim Fee Period: May 16, 2021 through September 15, 2021

9/10/21 5/16/21 - 

6/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 8 of 25
6 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested 

Fees (90%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

10% Fee 

Holdback 

10/7/21 6/16/21 - 

7/15/21 

$27,000.00 $0.00 $30,000.00 $0.00 $3,000.00 

11/9/21 7/16/21 - 

8/15/21 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

11/15/21 8/16/21 - 

9/15/21 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

Total $63,000.00 $0.00 $70,000.00 $0.00 $7,000.00 

Interim Fee Period: September 16, 2021 through January 15, 2022

12/30/21 9/16/21 - 

10/15/21 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

1/27/22 10/16/21 - 

11/15/21 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

3/8/22 11/16/21 - 

12/15/21 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

3/14/22 12/16/21 - 

1/15/22 

$4,500.00 $0.00 $5,000.00 $0.00 $500.00 

Total $18,000.00 $0.00 $20,000.00 $0.00 $2,000.00 

Interim Fee Period: January 16, 2022 through April 15, 2022

5/4/22 1/16/22 - 

2/15/22 

$4,500.00 $0.00 $4,500.00 $0.00 $500.00 

6/16/22 2/16/22 - 

3/15/22 

$4,500.00 $0.00 $4,500.00 $0.00 $500.00 

6/22/22 3/16/22 - 

4/15/22 

$4,500.00 $0.00 $4,500.00 $0.00 $500.00 

Total $13,500.00 $0.00 $13,500.00 $0.00 $1,500.00 

Interim Fee Period: April 16, 2022 through August 15, 2022

8/5/22 4/16/22 - 

5/15/22 

$4,500.00 $0.00 $4,500.00 $0.00 $500.00 

8/31/22 5/16/22 - 

6/15/22 

$4,500.00 $0.00 $4,500.00 $0.00 $500.00

9/26/22 6/16/22 - 

7/15/22 

$4,500.00 $0.00 $4,500.00 $0.00 $500.00 

10/26/22 7/16/22 - 

8/15/22 

$4,500.00 $0.00 $0.00 $0.00 $500.00 

Total $18,000.00 $0.00 $13,500.00 $0.00 $2,000.00 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 9 of 25
7 

PRIOR INTERIM FEE APPLICATIONS 

Date Filed 

[Docket No.] 

Application 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket No.] 

Fees Allowed 

and Paid 

Expenses 

Allowed and 

Paid 

7/16/18 

Docket No. 

3566 

2/15/18 -

4/15/18 

$60,000.00 $19,509.35 Docket No. 

4200 

Allowed: 

$60,000.00 

Paid: 

$60,000.00 

Authorized to be 

paid: 

$60,000.00 

Allowed: 

$19,509.35 

Paid: 

$19,509.35 

Authorized to be 

paid: 

$19,509.35 

11/16/18 

Docket No. 

4321 

4/16/18 -

9/15/18 

$150,000.00 $4,210.16 Docket No. 

5654 

Allowed: 

$150,000.00 

Paid: 

$150,000.00 

Authorized to be 

paid: 

$150,000.00 

Allowed: 

$4,210.16 

Paid: 

$4,210.16 

Authorized to be 

paid: 

$4,210.16 

3/18/19 

Docket No. 

5819 

9/16/18 -

1/15/19 

$120,000.00 $0.00 Docket No. 

7670 

Allowed: 

$120,000.00 

Paid: 

$120,000.00 

Authorized to be 

paid: 

$120,000.00 

N/A 

7/15/19 

Docket No. 

8002 

1/16/19 -

5/15/19 

$120,000.00 $0.00 Docket No. 

8753 

Allowed: 

$120,000.00 

Paid: 

$120,000.00 

Authorized to be 

paid: 

$120,000.00 

N/A 

11/15/19 

Docket No. 

9216 

5/16/19- 

9/15/19 

$95,000.00 $0.00 Docket No. 

12157 

Allowed: 

$95,000.00 

Paid: 

$95,000.00 

Authorized to be 

paid: 

$95,000.00 

N/A 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 10 of 25
8 

Date Filed 

[Docket No.] 

Application 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket No.] 

Fees Allowed 

and Paid 

Expenses 

Allowed and 

Paid 

3/16/20 

Docket No. 

12390 

9/16/19-

1/15/20 

$70,000.00 $0.00 Docket No. 

13824 

Allowed: 

$70,000.00 

Paid: 

$70,000.00 

Authorized to be 

paid: 

$70,000.00 

N/A 

7/15/20 

Docket No. 

13680 

1/16/20-

5/15/20 

$95,000.00 $0.00 Docket No. 

14925 

Allowed: 

$95,000.00 

Paid: 

$95,000.00 

Authorized to be 

paid: 

$95,000.00 

N/A 

11/16/20 

Docket No. 

15158 

5/16/20-

9/15/20 

$20,000.00 $0.00 Docket No. 

15971 

Allowed: 

$20,000.00 

Paid: 

$20,000.00 

Authorized to be 

paid: 

$20,000.00 

N/A 

3/15/21 

Docket No. 

16065 

9/16/20-

1/15/21 

$95,000.00 $0.00 Docket No. 

17646 

Allowed: 

$95,000.00 

Paid: 

$95,000.00 

Authorized to be 

paid: 

$95,000.00 

N/A 

7/15/21 

Docket No. 

17377 

1/16/2021-

5/15/2021 

$120,000.00 $0.00 Docket No. 

18371 

Allowed: 

$120,000.00 

Paid: 

$120,000.00 

Authorized to be 

paid: 

$120,000.00 

N/A 

Case:17-03283-LTS Doc#:22877 Filed:11/15/22 Entered:11/15/22 20:33:03 Desc: Main

Document Page 11 of 25
9 

Date Filed 

[Docket No.] 

Application 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket No.] 

Fees Allowed 

and Paid 

Expenses 

Allowed and 

Paid 

11/15/21 

Docket No. 

19236 

5/16/2021-

9/15/2021 

$70,000.00 $0.00 Docket No. 

19937 

Allowed: 

$70,000.00 

Paid: 

$70,000.00 

Authorized to be 

paid: 

$70,000.00 

N/A 

5/26/22 

Docket No. 

21036 

9/16/2021-

1/15/2022 

$20,000.00 $0.00 Docket No. 

21036 

Allowed: 

$20,000.00 

Paid: 

$20,000.00 

Authorized to be 

paid: 

$20,000.00 

N/A 

7/15/22 

Docket No. 

21516 

1/16/2021-

4/15/2022 

$15,000.00 $0.00 Docket No. 

______ 

Allowed: TBD N/A 

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

------------------------------------------------------------------------- X 

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

 as representative of : Case No. 17-BK-3283 (LTS) 

 : 

THE COMMONWEALTH OF PUERTO RICO, et al., : (Jointly Administered) 

 : 

Debtors.1 : 

------------------------------------------------------------------------- x 

FOURTEENTH INTERIM FEE APPLICATION OF KROMA ADVERTISING, INC., AS 

COMMUNICATIONS ADVISOR TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM APRIL 16, 2022 THROUGH AUGUST 15, 2022 

 

1

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

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

Rico (Bankruptcy Case No. 17-BK-3283- LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico 

Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284-LTS) (Last Four Digits of 

Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case 

No. 17-BK-3567-LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17-BK-3566-LTS) (Last 

Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case 

No. 17- BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-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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3 

SUPPORTING SCHEDULES 

SCHEDULE 1 MONTHLY STATEMENTS COVERED IN APPLICATION 

SCHEDULE 2 PROPOSED ORDER 

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To the Honorable United States District Judge Laura Taylor Swain: 

Kroma Advertising, Inc. (“Kroma”), communications advisor to Official Committee of 

Unsecured Creditors (the “Committee”),1 for its application (the “Application”), pursuant to 

sections 316 and 317 of the Puerto Rico Oversight, Management and Economic Stability Act 

of 2016 (“PROMESA”),2

 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”), and Rule 2016-1 of the Local 

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

“Local Rules”), for the interim allowance of compensation for professional services performed 

by Kroma for the period from April 16, 2022 through and including August 15, 2022 (the 

“Application Period”), and for reimbursement of its actual and necessary expenses incurred 

during the Application Period, respectfully represents: 

BACKGROUND 

1. 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 

 

1

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

COFINA. 

2

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

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Case, the ERS Title III Case, and the HTA Title III Case, the “Title III Cases”).3 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. 

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

Puerto Rico (the “U.S. Trustee”) appointed the Committee as the official committee for the 

Commonwealth [Docket No. 338]. 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 PREPA Title III Case. 

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

Compensation and Reimbursement of Expenses of Professionals (as amended, the “Interim 

Compensation Order”).4 On October 6, 2017, the Court entered 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. 

4. On January 25, 2018, the Committee selected Kroma as its communications 

advisor. On February 1, 2018, the Committee filed an application to retain and employ Kroma 

as communications advisor, effective February 1, 2018 [Docket No. 2325] (the “Retention 

Application”). By order of this Court entered February 22, 2018 [Docket No. 2572] (the 

 

3

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

Case. 

4

 The Interim Compensation Order was most recently amended on June 6, 2018 [Docket No. 3269]. 

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“Retention Order”), incorporated herein by this reference, Kroma’s retention as communications 

advisor to the Committee was approved effective as of February 1, 2018. 

5. The Retention Order authorized Kroma to be compensated on a monthly basis at a 

flat monthly rate of $30,000 and be 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 Kroma under this Order shall be an administrative expense of the Debtors.” In 

September 2019, Kroma and the Committee agreed, pursuant to an amendment to Kroma’s 

engagement letter, that Kroma’s flat monthly rate would be reduced from $30,000 to $5,000, 

effective as of August 16, 2019. Under the amendment, in the event the Committee determines, 

in its sole discretion, that in any particular month Kroma provides services in a materially higher 

amount than in previous months, the Committee may increase the monthly compensation to be 

received by Kroma for that particular month up to $30,000. 

6. On July 16, 2018, Kroma filed its first interim fee application with respect to the 

period from February 15, 2018 through April 15, 2018 [Docket No. 3566] (the “First Interim Fee 

Application”). The compensation requested in the First Interim Fee Application was allowed 

pursuant to this Court’s order awarding interim allowance of compensation entered on November 

9, 2018 [Docket No. 4200]. 

7. On November 16, 2018, Kroma filed its second interim fee application with 

respect to the period from April 16, 2018 through September 15, 2018 [Docket No. 4321] (the 

“Second Interim Fee Application”). The compensation requested in the Second Interim Fee 

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Application was allowed pursuant to this Court’s order awarding interim allowance of 

compensation entered on March 14, 2019 [Docket No. 5654]. 

8. On March 18, 2019, Kroma filed its third interim fee application with respect to 

the period from September 16, 2018 through January 15, 2019 [Docket No. 5819] (the “Third 

Interim Fee Application”). The compensation requested in the Third Interim Fee Application 

was allowed pursuant to this Court’s order awarding interim allowance of compensation entered 

on June 26, 2019 [Docket No. 7670]. 

9. On July 15, 2019, Kroma filed its fourth interim fee application with respect to 

the period from January 16, 2019 through May 15, 2019 [Docket No. 8002] (the “Fourth Interim 

Fee Application”). The compensation requested in the Fourth Interim Fee Application was 

allowed pursuant to this Court’s order awarding interim allowance of compensation entered on 

September 25, 2019 [Docket No. 8753]. 

10. On November 15, 2019, Kroma filed its fifth interim fee application with respect 

to the period from May 16, 2019 to September 15, 2019 [Docket No. 9216] (the “Fifth Interim 

Fee Application”). The compensation requested in the Fifth Interim Fee Application was allowed 

pursuant to this Court’s order awarding interim allowance of compensation entered on March 6, 

2020 [Docket No. 12157]. 

11. On March 16, 2020, Kroma filed its sixth interim fee application with respect to 

the period from September 16, 2019 through January 15, 2020 [Docket No. 12390] (the “Sixth 

Interim Fee Application”). The compensation requested in the Sixth Interim Fee Application 

was allowed pursuant to this Court’s order awarding interim allowance of compensation entered 

on July 24, 2020 [Docket No. 13824]. 

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12. On July 15, 2020, Kroma filed its seventh interim fee application with respect to 

the period from January 16, 2020 through May 15, 2020 [Docket No. 13680] (the “Seventh 

Interim Fee Application”). The compensation requested in the Seventh Interim Fee Application 

was allowed pursuant to this Court’s order awarding interim allowance of compensation entered 

on October 26, 2020 [Docket No. 14925]. 

13. On November 16, 2020, Kroma filed its eighth interim fee application with 

respect to the period from May 16, 2020 through September 15, 2020 [Docket No. 15158] (the 

“Eighth Interim Fee Application”). The compensation requested in the Eighth Interim Fee 

Application was allowed pursuant to this Court’s order awarding interim allowance of 

compensation entered on March 8, 2021 [Docket No. 15971]. 

14. On March 15, 2021, Kroma filed its ninth interim fee application with respect to 

the period from September 16, 2020 through January 15, 2021 [Docket No. 16065] (the “Ninth 

Interim Fee Application”). The compensation requested in the Ninth Interim Fee Application 

was allowed pursuant to this Court’s order awarding interim allowance of compensation entered 

on August 3, 2021 [Docket No. 17646]. 

15. On July 15, 2021, Kroma filed its tenth interim fee application with respect to the 

period from January 16, 2021 through May 15, 2021 [Docket No. 17377] (the “Tenth Interim 

Fee Application”). The compensation requested in the Tenth Interim Fee Application was 

allowed pursuant to this Court’s order awarding interim allowance of compensation entered on 

October 4, 2021 [Docket No. 18371]. 

16. On November 15, 2021, Kroma filed its eleventh interim fee application with 

respect to the period from May 16, 2021 through September 15, 2021 [Docket No. 19236] (the 

“Eleventh Interim Fee Application”). The compensation requested in the Eleventh Interim Fee 

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Application was allowed pursuant to this Court’s order awarding interim allowance of 

compensation entered on January 28, 2022 [Docket No. 19937]. 

17. On May 26, 2022, Kroma filed its twelfth interim fee application with respect to 

the period from September 16, 2021 through January 15, 2022 [Docket No. 21036] (the “Twelfth 

Interim Fee Application”). 

18. On July 15, 2022, Kroma filed its thirteenth interim fee application with respect to 

the period from January 15, 2022 through April 16, 2022 [Docket No. 21516] (the “Thirteenth 

Interim Fee Application”). 

19. This is Kroma’s Fourteenth interim fee application, covering the period from 

April 16, 2022 through August 15, 2022. All services for which compensation is requested were 

performed for or on behalf of the Committee. 

COMPENSATION AND REIMBURSEMENT REQUEST 

20. By this Application, Kroma seeks allowance of compensation for professional 

services rendered to the Committee during the Application Period in the aggregate amount of 

$20,000.00. 

21. The Committee has approved the amounts requested by Kroma for services 

performed and expenses incurred in each of the monthly statements submitted to, among others, 

the Oversight Board, AAFAF, the Fee Examiner, and the U.S. Trustee. 

22. To date, Kroma has received payments for services rendered during the 

Application Period in the amount of $13,500.00. With respect to the Application Period, Kroma 

is still awaiting payment of (i) $4,500.00, which represents, in total, 90% of its fees for services 

rendered from July 16, 2022 through August 15, 2022 and (ii) $2,000.00, which represents the 

10% “hold-back” portion of Kroma’s Application Period fees. In addition, Kroma is still 

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awaiting payment of $1,500.00, which represents the 10% “hold-back” portion of Kroma’s fees 

in connection with the prior application period. 

23. Other than payments made in accordance with the Interim Compensation Order, 

Kroma has received no payment and no promises of payment from any source for services 

rendered during the Application Period. By this Application, Kroma requests allowance of all 

fees and expenses incurred for services rendered during the Application Period. 

24. There is no agreement or understanding between Kroma and any other person, 

other than the employees and staff of Kroma, for the sharing of compensation to be received for 

services rendered in these cases. 

25. To the extent that monthly fee 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 Kroma has for any other reason not sought compensation or 

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

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

supplemental or future application. 

SUMMARY OF SERVICES 

26. During the Application Period, Kroma assisted and advised the Committee in a 

number of key areas. 

27. Kroma continued to assist the Committee with its communications strategy by, 

among other things, maintaining and updating the Committee’s website to keep unsecured 

creditors apprised of recent developments. 

28. In addition, Kroma provided the Committee with other valuable communications 

services, including but not limited to monitoring Puerto Rico media, providing translations of 

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press materials, and advising the Committee and its advisors with respect to public relations 

issues. Given ongoing media interest in restructuring matters and focus on the plans of 

adjustment for HTA and PREPA, this assistance was highly valuable during the Application 

Period. 

* * * 

29. The foregoing professional services were necessary and appropriate to the 

administration of the Title III Cases and were in the best interests of the Committee, the Debtors, 

the creditors, and other parties in interest. 

ACTUAL AND NECESSARY DISBURSEMENTS 

30. Kroma did not disburse any expenses during the period from April 16, 2022 

through August 15, 2022. 

REQUESTED COMPENSATION SHOULD BE ALLOWED 

31. 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: 

(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; 

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(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 . . . .” 

32. In the instant case, Kroma 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 herein 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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NOTICE 

33. In accordance with the Interim Compensation Order, Kroma 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. 

 [Remainder of page intentionally left blank.] 

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