Hearing Date: December 14, 2022 at 9:30 a.m. (AST)

Objection Deadline: November 22, 2022 at 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)

NOTICE OF HEARING OF FIRST INTERIM FEE APPLICATION OF 

CONTINENTAL PLLC AS SPECIAL LITIGATION COUNSEL TO THE 

OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES 

RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD OF 

FEBRUARY 1, 2022 THROUGH MAY 31, 2022 

PLEASE TAKE NOTICE that a hearing on the annexed First Interim Fee Application 

of Continental PLLC, as Special Litigation Counsel to Official Committee of Unsecured 

Creditors, for Services Rendered and Reimbursement of Expenses for Period of February 1, 2022 

through May 31, 2022 (the “Application”), filed by Continental PLLC (“Continental”), as special 

litigation counsel to the Official Committee of Unsecured Creditors (the “Committee”)

2

, pursuant 

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

to section 1103(a)(1) of the Bankruptcy Code, made applicable to these cases by section 301 of 

the Puerto Rico Oversight, Management and Economic Stability Act of 2016 or “PROMESA,” 

will be held before the Honorable Laura Taylor Swain, United States District 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 December 14, 2022 at 9:30 a.m. 

(AST) (the “Hearing”).

PLEASE TAKE FURTHER NOTICE that any response or objection (“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 on or before November 22, 2022 at 4:00 p.m. (AST) (the 

“Objection Deadline”).

PLEASE TAKE FURTHER NOTICE that if (a) no objection is timely filed and served 

in accordance with the Interim Compensation Order and Case Management Procedures, and (b) 

all issues raised by the Fee Examiner are consensually resolved, the relief requested may be granted 

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3

without a hearing.

Copies of all documents filed in these Title III cases are available (a) free of charge by 

visiting https://cases.primeclerk.com/puertorico or by calling +1 (844) 822-9231, and (b) on the 

Court’s website at https://www.prd.uscourts.gov, subject to the procedures and fees set forth 

therein.

Dated: October 27, 2022

/s/ John Arrastia

John Arrastia, Esq. (Pro Hac Vice)

CONTINENTAL PLLC

255 Alhambra Cir, Suite 640 

Coral Gables, FL 33134

Tel: 305-677-2707

JArrastia@ContinentalPLLC.com

Special Claims Counsel to the Official Committee of 

Unsecured Creditors 

/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

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4

Hearing Date: December 14, 2022 at 9:30 a.m. (AST)

Objection Deadline: November 22, 2022 at 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.3

_____________________________________________/

PROMESA

Title III

Case No. 17 BK 3283-LTS

(Jointly Administered)

FIRST INTERIM FEE APPLICATION OF CONTINENTAL PLLC, AS SPECIAL 

LITIGATION COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES

FOR THE PERIOD OF FEBRUARY 15, 2022 THROUGH MAY 31, 2022

SUMMARY COVER SHEET

Name of applicant: Continental PLLC (“Continental”)

Authorized to provide professional 

services to:

Official Committee of Unsecured Creditors of 

all Title III Debtors (other than PBA and 

COFINA) (the “Committee”)4

Date of retention: March 18, 2022, effective as of February 14, 2022

[Docket No. 20407]

3 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).

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

COFINA.

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5

Period for which compensation and 

reimbursement are sought:

February 14, 2022 through and including 

May 31, 2022 (the “Application Period”)

Amount of interim compensation 

sought as actual, reasonable, and 

necessary:

$249,241.505

Amount of interim expense 

reimbursement sought as actual, 

reasonable, and necessary:

$63.96

Are your fee or expense totals different 

from the sum of previously-served 

monthly statements for the Application 

Period?

No.

Blended rate in this Application for all 

attorneys: $440.04/hour6

Blended rate in this Application for all 

timekeepers: $426.42/hour

Total time expended for fee application 

preparation during the Application 

Period:

7.9

Total compensation requested for fee 

application preparation during the 

Application Period:

$2,034.50

Number of professionals included

in this Application: 5

If applicable, number of 

professionals in this Application 

not included in a staffing plan 

approved by the client:

N/A

If applicable, difference between fees 

budgeted and compensation sought for 

the Application Period:

($202,636.11): less than the budgeted fees

Are any timekeeper’s hourly rates 

higher than those approved or disclosed 

at retention? 

None.

5 The full amount of fees incurred by Continental during the Application Period total $249,241.50. Continental agreed 

taking a voluntary fee reduction equal to 20% in the amount of $49,848.30 and, thereby, seeks allowance and payment 

of fees in the amount of $199,393.20.

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

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

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6

Total compensation approved by 

interim order to date:

N/A

Total expenses approved by 

interim order to date:

N/A

Total allowed compensation paid to 

date:

$249,241.50

Total allowed expenses paid to date: $63.96

Total compensation sought in this 

Application already paid pursuant to a 

monthly compensation order but not 

yet allowed:

$249,241.50

Total expenses sought in this 

Application already paid pursuant to a 

monthly compensation order but not 

yet allowed.

$63.96

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7

SUMMARY OF PRIOR MONTHLY FEE STATEMENTS FOR THE COMPENSATION

PERIOD FROM FEBRUARY 15, 2022 THROUGH MAY 31, 2022

Date Period 

Covered

Total Fees 20% 

Discount

Fees 

Requested

(90%)

Holdback 

(10%)

Expenses 

Requested

Fees Paid Expenses 

Paid

03/23/22 Feb.

2022 $47,196.50 $9,439.30 $33,981.48 $3,775.72 $0.00 $33,981.48 $0.00

05/04/22 March

2022

$23,435.00 $4,687.00 $16,873.20 $1,874.80 $63.96 $16,873.20 $63.96

05/12/22 April

2022

$47,473.50 $9,494.70 $34,180.92 $3,797.88 $0.00 $34,180.92 $0.00

06/30/22 May

2022

$131,136.50 $26,227.30 $94,418.28 $10,490.92 $0.00 $94,418.28 $0.00

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8

Summary of Amounts Requested to be Paid

Total Unpaid Fees: $19,939.327

Total Unpaid Expenses: $0

Total 10% Holdback on Fees: $19,939.32

Reimbursement for 29% Tax Withholding: N/A

Reimbursement for 1.5% Government Contribution: N/A

Less expenses voluntarily reduced: N/A

Total Amount Requested to be Paid in Fees and Expenses for this period: $19,939.32

7 The total unpaid fees sought are net fees after application of the voluntary 20% discount provided by Continental. 

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9

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 JOHN ARRASTIA 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 D-1 BUDGETS

EXHIBIT D-2 STAFFING PLANS

EXHIBIT E SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

 CATEGORY

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: December 14, 2022 at 9:30 a.m. (AST)

Objection Deadline: November 22, 2022 at 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.8

_____________________________________________/

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

FIRST INTERIM APPLICATION OF CONTINENTAL PLLC, SPECIAL LITIGATION 

COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR 

ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES 

FOR THE PERIOD FROM FEBRUARY 15, 2022 THROUGH MAY 31, 2022

To The Honorable United States District Judge Laura Taylor Swain:

Continental PLLC (“Continental”), special litigation counsel to the Official Committee of 

Unsecured Creditors (the “Committee”),9for its first interim application (the “First Interim 

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 

8 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).

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

COFINA.

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11

2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules” or “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 Continental for the period from February 15, 2022 through and including 

May 31, 2022 (the “Application Period”), and for reimbursement of its actual and necessary 

expenses incurred during the Application Period. In support of the Application, Continental 

submits the Certification of John Arrastia (the “Arrastia 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 First

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

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

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

2. This First Interim Application is consistent with the 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, Continental requests a waiver for cause shown of any requirements not met by 

this First Interim Application.

10

3. This First Interim Application has been prepared in accordance with the Guidelines 

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

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

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

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12

compliance with the Local Guidelines. 

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”).

11 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] appointing the Committee as the official committee of unsecured creditors. 

6. On July 10, 2017, the Committee filed an Application for Order Pursuant to 

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

and Retention of Paul Hastings LLP as Counsel to Official Committee of Unsecured Creditors, 

Effective as of June 26, 2017 Requesting the Entry of an Order Authorizing the Retention and 

Employment of Paul Hastings LLP (“Paul Hastings”) as Counsel for the Committee [Docket No. 

610]. By order of this Court entered August 10, 2017 [Docket No. 999] (the “Paul Hastings 

Retention Order”), Paul Hastings’ retention as counsel to the Committee was approved effective 

as of June 26, 2017.

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

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7. 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. Continental’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.

8. On January 18, 2022, the Court entered the Order and Judgment Confirming 

Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, 

The Employees Retirement System of the Government of the Commonwealth of Puerto Rico, and 

the Puerto Rico Public Buildings Authority [Docket No. 19813] (“Confirmation Order”), which 

confirmed the Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth 

of Puerto Rico, et al. [Docket No. 19784] (the “Plan”). The Effective Date of the Plan occurred on 

March 15, 2022. Pursuant to §90.1 of the Plan, and as a result of the appeals of the confirmation 

order, the Committee will remain in existence in the Commonwealth and ERS cases until the 

confirmation order becomes a Final Order. The Plan did not affect the continued existence of the 

Committee in the PREPA and HTA cases.

B. Retention of Continental 

9. On April 30, 2019, the Committee filed an application to retain and employ the law 

firm of Genovese Joblove & Battista, P.A. (“GJB”) as special litigation and conflicts counsel. 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].

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10. Effective as of February 14, 2022, John Arrastia, Jesus Suarez, and Angelo Castaldi 

(collectively, the “Attorneys”)—three of the GJB attorneys who had been primarily responsible 

for the representation of the Committee as special litigation counsel and conflicts counsel—formed 

and joined the Continental law firm. To ensure continuity of representation and to minimize 

expenses the Committee would have to incur in connection with having unfamiliar attorneys 

represent the Committee, the Committee approved Continental’s substitution the Title III Cases, 

effective as of February 14, 2022. 

11. On February 28, 2022, Continental filed the Application for Order Pursuant to 

Bankruptcy Code Section 1103(A) and Local Bankruptcy Rule 2014-1(E) Authorizing Employment 

and Retention Of Continental PLLC as Substitute Special Litigation Counsel to Official Committee 

Of Unsecured Creditors, Effective as of February 14, 2022 (the “Continental Application”) 

[Docket Entry No. 20222].

12. By order of this Court entered March 18, 2022 [Docket No. 20407] (the “Retention 

Order”), the Continental Application was approved effective as of February 14, 2022. The terms 

of the retention of Continental are identical in all material respects to the retention of GJB and are 

no less favorable to the Committee. 

13. The retention of Continental (and the Attorneys) as special litigation counsel and 

conflicts counsel remains necessary and appropriate because the Committee desired to retain a firm 

with expertise in asserting claims against existing defendants and potential adverse parties that 

present a conflict to the Committee’s primary counsel, Paul Hastings.

14. Continental’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 Continental, as counsel to 

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15

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.”

15. The Retention Order authorized Continental 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 Continental shall be an 

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

consented to the Debtors’ payment of Continental’s allowed fees and expenses.

C. Interim Compensation and Fee Examiner Orders

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

Compensation and Reimbursement of Expenses of Professionals [Docket No. 1150].

17. 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.

18. 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].

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

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket

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16

No. 1715].

20. 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.

21. 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”).

22. 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].

23. On June 6, 2018, the Court entered the Interim Compensation Order [Doc. No. 

3269], and in accordance therewith, Continental 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”).

24. Pursuant to the 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.

25. 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”).

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26. 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].

27. In addition to the Monthly Fee Statements, the Interim Compensation Order 

directed professionals to seek interim allowance and payment of compensation (including the 10% 

held back from Monthly Fee Statements) and expense reimbursement at 120-day intervals (each 

an “Interim Fee Period”) by filing with the Court and serving on the Notice Parties an application 

for approval and allowance of all compensation and reimbursement of expenses relating to services 

rendered and expenses incurred during the preceding Interim Fee Period (see Interim 

Compensation Order at ¶2(f)).

COMPENSATION AND REIMBURSEMENT REQUEST

First Interim Application for Interim Compensation

28. This is the First Interim Application for interim compensation for Continental. 

29. By this First Interim Application, Continental seeks an order authorizing (a) 

allowance of interim compensation for professional services rendered to the Committee during the 

Application Period in the aggregate amount of $249,241.50 and (b) allowance of reimbursement 

of actual and necessary expenses incurred by Continental in the aggregate amount of $63.96. These 

amounts were for legal services provided to the Committee in connection with the Commonwealth 

Title III case.

30. During the Application Period, Continental attorneys and paraprofessionals 

expended a total of 584.5 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. 

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31. The Committee has approved the amounts requested by Continental for services 

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

as outlined in the Interim Compensation Order.

32. During the Application Period, Continental submitted four (4) Monthly Fee 

Statements. The first Monthly Fee Statement for the period from February 1, 2022 to February 28, 

2022 was submitted and served on the Notice Parties on March 23, 2022 (the “First Monthly Fee 

Statement”) a copy of which is attached as Schedule 2. The objection deadline for the First 

Monthly Fee Statement was April 2, 2022. 

33. A second Monthly Fee Statement for the period from March 1, 2022 to March 31, 

2021 was submitted and served on the Notice Parties on May 4, 2022 (the “Second Monthly Fee 

Statement”) a copy of which is attached as Schedule 2. The objection deadline for the Second 

Monthly Fee Statement was May 14, 2022. 

34. A third Monthly Fee Statement for the period from April 1, 2022 to April 30, 2022

was submitted and served on the Notice Parties on May 12, 2022 (the “Third Monthly Fee 

Statement”), a copy of which is attached as Schedule 2. The objection deadline for the Third 

Monthly Fee Statement was May 23, 2022. 

35. A fourth Monthly Fee Statement for the period from May 1, 2022 to May 31, 2022

(the “Fourth Monthly Fee Statement”), was submitted to the Committee on May 12, 2022, a copy 

of which is attached as Schedule 2. The objection deadline for the Fourth Monthly Fee Statement 

was July 10, 2022. 

36. As of the date of the filing of this First Interim Application, Continental has 

received only 90% of the payments for services rendered during the Application Period. There 

remains a 10% hold back in the amount of $19,939.32. 

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

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

rates totaling $49,848.30. For details regarding the waived fees, please see the Certification of 

John Arrastia filed concurrently.

38. By this First Interim Application, Continental requests allowance of all fees and 

expenses incurred for services rendered during the Application Period. At this time, Continental

seeks 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 Continental 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 Continental’s fees and expenses. 

39. There is no agreement or understanding between Continental and any other person 

other than the attorneys, employees, and staff of Continental, for the sharing of compensation to 

be received for services rendered in these cases.

40. Continental maintains computerized records, in the form of monthly statements, of

the time spent by all Continental’s attorneys and paraprofessionals in connection with its 

representation of the Committee. The monthly statements are in the same form regularly used by 

Continental to bill its clients for services rendered and include the date that the services were 

rendered, a detailed, and 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.

41. The fees charged by Continental in the Title III Case are billed in accordance with 

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

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

III Case are comparable to the rates Continental charges for professional and paraprofessional 

services rendered in comparable non-bankruptcy related matters. 

42. Continental’s rates are set at a level designed to fairly compensate Continental for 

the work of its attorneys and paraprofessionals to cover fixed and routine overhead expenses. 

Continental 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, Continental 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, Continental’s endeavors 

to set the hourly rates for its attorneys and paraprofessionals at levels comparable to or below those 

of its principal competitor firms.

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

every year Continental 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.

44. Continental’s professional services during the Application Period required an 

aggregate expenditure of 584.50 recorded hours by Continental’s attorneys and paraprofessionals, 

broken down as follows: partners (265.1 hours), associates (293.3 hours), and paraprofessionals 

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(26.1 hours). During the Application Period, Continental’s billing rates for attorneys rendering 

services in this matter ranged from $315.00 to $575.00 per hour. 

45. 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 First Interim Application, or Continental has for any other reason not sought

compensation or reimbursement with respect to such services or expenses, Continental reserves 

the right to request additional compensation for such services, and reimbursement of such 

expenses, in a supplemental or future application.

46. 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 contains the Certification of John Arrastia

• Exhibit B contains disclosures regarding “customary and comparable 

compensation.”

• Exhibit C contains a summary of Continental’s timekeepers included in this First 

Interim Application.

• Exhibit D contains the (a) budgets and (b) staffing plans for Continental’s services 

during the Application Period.

• Exhibit D-1 contains the budgets for the Application Period.

• Exhibit D-2 contains the staffing plans for 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 a 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 Continental’s 

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monthly statements.

• Exhibit F contains a breakdown of compensation and expense reimbursement 

requested by Continental and by whether the services 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 First Interim 

Application.

• Schedule 3 includes the proposed order approving this First Interim Application.

SUMMARY OF SERVICES PERFORMED BY CONTINENTAL DURING THE 

APPLICATION PERIOD

47. This First Interim Application is Continental’s first interim application for

compensation in the Debtors’ Title III Cases. Set forth below is a description of the professional 

services rendered by Continental during the Application Period broken down by project category.12

The following services described are not intended to be a comprehensive summary of the work

performed by Continental. Detailed descriptions of all services rendered by Continental can be 

found in the detailed time records reflecting the services performed by Continental’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 by 

reference.

48. During this Application Period, Continental 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”), and with

12 The description of services in this Application is limited to those matters in which Continental provided five (5) or 

more hours of service during the Application Period.

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Casillas, Santiago & Torres, LLC (“CST”), Local Counsel to the Official Committee of Unsecured 

Creditors (the “Committee”), in handling numerous matters that were of critical importance to the 

interests of the Debtors and their creditors, particularly with respect to the Committee’s efforts to 

protect the benefits secured for general unsecured creditors of the Commonwealth. Continental

worked with these firms to eliminate unnecessary duplication and allocate tasks in an efficient 

manner. In order to minimize duplication, Continental 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. Continental has continued to track deadlines, organized 

documents, and review the Title III Case dockets to maintain its litigation tracking spreadsheets 

current. In addition, Continental has reviewed various motions, applications, scheduling orders and 

other pleadings submitted to the Court in connection with the pending action and related adversary 

proceedings. 

49. Specifically, Continental has continued to monitor the progress of the proceedings 

and advise the Committee as appropriate, and represent the Committee in those actions, including 

without limitation, claims of PREPA against fuel oil suppliers and laboratories to avoid certain 

fraudulent transfers and contractual claims. During the Application Period Continental 

collaborated with CST related to the Fuel Oil Litigation (Adv. P. No. 388). This included a review 

of pleadings and undertaking substantial effort to respond to a number of exhaustive dispositive 

motions filed in Fuel Oil Litigation and analysis of local law issues that arose in the Fuel Oil 

Litigation during the Application Period. 

50. During the Application Period, Continental collaborated with and assisted cocounsel on various matters related to claims filed against PREPA, while continuing to analyze the 

general unsecured claims pool. 

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51. During the Application Period, Continental continued to assist counsel for the 

Committee and advise the Committee on all issues bearing on the rights of unsecured creditors in 

the Title III cases and taken proactive steps to protect the rights of unsecured creditors, including 

by: (i) reviewing the Oversight Board’s reports concerning the designation and status of claims in 

connection with the alternative dispute resolution process and administrative claims reconciliation 

process; (ii) collaborating with other Committee advisors and counsel to the Special Claims 

Committee of the Oversight Board to dismiss adversary proceedings that were resolved as part of 

the Commonwealth Plan; (iii) attending Committee meetings and communicating regularly with 

Committee members regarding ongoing matters in the Title III cases; and (iv) monitoring hearings, 

pleadings filed, and orders entered in the Title III cases and related adversary proceedings.

52. As special litigation and conflicts counsel to the Committee, Continental 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. 

53. As such, Continental 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 Continental was carefully assigned to appropriate professionals or paraprofessionals 

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

whenever possible, Continental sought to minimize the costs of Continental’s services to the 

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

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of the assignments. In addition, a small group of the same Continental attorneys was utilized for 

the vast majority of the work in these Title III cases to minimize the costs of intra-Continental

communication and education about the cases. Notably, as a general matter, no more than two 

Continental attorneys attended the various hearings held during the Application Period, thereby 

minimizing the time billed on these hearings. 

54. In sum, Continental respectfully submits that the services for which it seeks 

compensation in this First Interim 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, Continental’s charges for professional services performed and expenses incurred are 

reasonable under applicable standards. 

55. For all these reasons, Continental respectfully requests that the Court grant this First 

Interim Application and allow interim compensation for professional services performed and 

reimbursement for expenses as requested.

56. For ease of reference and transparency purposes, Continental created several matter 

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

Matter ID Matter Name

101 Commonwealth of Puerto Rico

102 PREPA Adversary Litigation

103 ERS Adversary Litigation

104 HTA Adversary Litigation

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

ID 101)

(a) Case Administration (Task Code B110)

 Fees: $1,970.50 Total Hours: 9.50

57. During the Application Period, Continental reviewed and developed general case 

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

meetings with Paul Hastings, Proskauer Rose, Brown Rudnick, and CST. In order to efficiently 

track deadlines, organize documents, and manage work streams, Continental 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, Continental held routine internal team

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

current status of the Title III cases and to manage work assignments and deadlines, while ensuring 

efficiencies and avoiding duplication and unnecessary overlap. In addition, Continental continued 

implementing interim and long-term strategies to maximize recoveries for general unsecured 

creditors. During the Application Period, Continental attended telephone conferences, and weekly 

meetings, and other communications with the Committee, including preparation for such calls and 

meetings in order to maintain the Committee informed of the various developments in the 

proceedings being handled by Continental. 

(b) Pleadings Review (Task Code B113)

 Fees: $19,687.50 Total Hours: 62.50

58. During the Application Period, Continental monitors the case docket for the Title 

III cases and applicable adversary proceedings. All 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 

Continental is serving as special litigation counsel to the Committee. 

(c) Fee/Employment Applications/Budgeting (Continental) (Task Code B160)

Fees: $21,461.00 Total Hours: 53.00

59. During the Application Period, Continental prepared, among other things, the 

Continental Employment Application and related Motions and Orders.

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60. During the Application Period, Continental prepared four (4) monthly fee statements 

for services rendered during the months of February, March, April and May 2022. Continental also 

reviewed reports and correspondence from the Fee Examiner and engaged in discussions with the 

Fee Examiner and his counsel to address questions regarding Continental’s compensation. 

61. During the Application Period, Continental prepared monthly budgets and staffing 

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

Continental prepared monthly budgets for February, March, April and May 2022, as required by 

the Fee Examiner and Interim Fee Orders. In addition, On May 13, 2022, Continental filed its First 

Supplemental Declaration Regarding the Retention of Continental as Special Litigation and 

Conflicts Counsel to the Official Committee of Unsecured Creditors in accordance Pursuant to the 

Order Approving List of Material Interested Parties Pursuant to The Puerto Rico Recovery 

Accuracy In Disclosures Act [ECF No. 204671] (the “PRRADA Order”) and the Puerto Rico 

Recovery Accuracy in Disclosures Act, Pub. L. No. 117-82 (“PRRADA”), and the disclosure 

requirements of rule 2014(a) of the Federal Rules of Bankruptcy Procedure. [ECF No. 20776]. 

(d) General Litigation (Task Code B191)

 Fees: $44,894.50 Total Hours: 106.40

62. During the Application Period, Continental’s professionals reviewed and analyzed 

obligations of professionals under the Puerto Rico Recovery Accuracy in Disclosure Act and the 

Court’s related orders, and in conjunction with that analysis prepared and supplemented its 

disclosures. 

63. During this Application Period and prior to the March 15, 2022 effective day of the 

Plan, Continental has continued its representation as special litigation and conflicts counsel to the 

Committee in connection with various adversary proceedings associated with the Title III cases. 

Continental monitored various appeals of the Confirmation Order in preparation or anticipation of 

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the effective date of the confirmed plan and its provisions concerning the transition of avoidance

actions. Continental also continued to represent the Committee with respect to avoidance actions 

prior to the effective date, and in preparation for the post-effective date transition of the Avoidance 

Actions Trust. This foregoing work included post-effective date efforts, including (without 

limitation) attending to the execution of tolling agreements and ensuring continued viability of 

tolled claims, preparing avoidance actions and advising complaints against tolled parties who had 

yet to extend tolling agreements, monitoring significant filings or appeals concerning potential 

impacts to litigation claims; and reviewing disclosures and bond information relevant to viable 

litigation claims. Continental aided Paul Hastings and CST in various tasks, such as outreach 

efforts, preparation of communiques for the Committee, and research and analysis of legal issues 

in connection with claims assessment, contracts law, and the litigation trust; all this in association 

with the implementation of the Commonwealth’s Plan and the execution of the Committee’s 

strategy as these Title III litigations continue. Continental has also provided, from time-to-time, 

additional assistance to Committee counsel with respect to litigation matters within Continental’s 

subject matter expertise, but in no way duplicative of the work performed by other counsel on 

these matters

64. During the Application Period, Continental reviewed and analyzed the background 

of the case, reviewed associated pleadings and documents and calendared omnibus hearings and 

deadlines associated with proposed litigation for which it was retained. Continental reviewed and 

analyzed procedures orders regarding hearings, objections and pleadings filed. Continental

reviewed agendas for omnibus hearings scheduled during the Application Period and attended 

hearings whenever necessary. 

II. PREPA (Matter ID 102)

65. During the Application Period, Continental continued to monitor the case and 

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review pleadings, orders, hearings, briefing schedules, and objections filed in the main PREPA 

case and omnibus adversary proceedings. Additionally, Continental, reviewed pending tolling 

agreement deadlines. 

(a) General Litigation (Task Code B191)

Fees: $149,116.00 Total Hours: 328.40

66. During the Application Period, Continental reviewed and analyzed various 

pleadings filed in the PREPA matter in additional to monitoring pending tolling agreement 

deadlines and tracking expiration deadlines of same. Continental paralegals prepared, reviewed 

and analyzed services and notices. Continental continued its representation of the Committee in 

an adversary case pursuing the claims of PREPA against fuel oil suppliers and laboratories to avoid 

certain fraudulent transfers and other claims [Adv. Pro. No. 19-388-LTS]. Continental devoted 

substantial effort to perform legal services on behalf of the Committee with respect to the Fuel Oil 

Litigation. By way of brief example, the Committee and Special Claims Committee filed their 

second amended adversary complaint on February 28, 2022 against a collection of some of the 

largest fuel suppliers in the world, and certain fuel-testing laboratories. During the Application 

Period, these various defendants then filed several extensive motions to dismiss, which involved 

complex issues of law. These motions also demanded substantial coordination with the Special 

Claims Committee, and significant research attendant to commencing the process to ultimately

respond to such motions.

67. In addition, during the Application Period, Continental expended significant efforts 

with Brown Rudnick preparing and procuring tolling agreements with various potential litigation 

targets including the preparation of draft complaints for certain litigation targets.

III. ERS (Matter ID 103)

68. During the Application Period, Continental continued to monitor the case and 

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review pleadings, orders, hearings, briefing schedules, and objections filed in the main ERS case 

and omnibus adversary proceedings. Additionally, Continental has reviewed and analyzed motions 

regarding briefing and litigation schedules; pending discovery and pleadings related to the bonds 

issued by ERS. Continental has also spent time reviewing and calendaring deadlines and hearings 

related to the ERS litigation.

69. In addition, Continental continued its work representing the Committee in 

connection with the ERS Bond adversaries [Adv. Proc. Nos. 19-356, 19-357, 19-359, 19-361 and 

19-367]. Continental represents the Committee with respect to Stipulation of Dismissal of ERS 

actions and prepared the papers concerning same. Continental reviewed and analyzed Fourth 

Amended Plan Supplement as it relates to litigation claims. 

IV. HTA (Matter ID 104)

(a) General Litigation (Task Code B191)

 Fees: $2,842.50 Total Hours: 6.6

70. During the Application period, Continental has been involved and continued to 

monitor adversary proceeding challenging liens asserted by certain holders of HTA bonds [Adv. 

Proc. No. 19-364]. Continental also spent time reviewing and calendaring deadlines and hearings 

related to the HTA litigation. In addition, Continental aided Paul Hastings and CST in various 

tasks, such as preparation of memoranda for the Committee, and research and analysis of local law 

in connection with special revenues and preclusions. All this in association with the upcoming 

proposed Plan of Adjustment and related proceedings.

ATTENDANCE AT HEARINGS

71. 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”), Continental provides the 

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

• John Arrastia and Angelo Castaldi virtually attended the March 23-24, 2022 

omnibus hearings.

REPORT ON MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND 

COMMITTEE 

72. As requested by the Fee Examiner, Continentalsets forth below the status of various 

proceedings and motions jointly commenced by the Oversight Board or its Special Claims 

Committee, on the one hand, and the Committee, on the other hand, pursuant to stipulation for 

joint prosecution of causes of action or claims objections 

• Adversary Proceedings Against Fuel Oil Defendants and Other Proceedings: 

Continental represents the Committee with respect to the claims against numerous 

fuel oil suppliers and laboratories of PREPA to avoid certain fraudulent transfers 

[Adv. Pro. No. 19-388-LTS].

• Garden-Variety Avoidance Actions: Prior to the March 15, 2022 effective date of 

the Plan (and during this Application Period), Continental represented the 

Committee in serval avoidance actions as special litigation counsel. Under the 

Commonwealth plan of adjustment, the claims were transferred to the Avoidance 

Actions Trust during the Application Period and Avoidance Action Trustee 

effectively took over the prosecution of the garden variety avoidance actions and 

underwriter claims.

• Adversary Proceeding Against Underwriters, etc.: Prior to the March 15, 2022 

effective date of the Plan (and during this Application Period), Continental 

represented the Committee with respect to the adversary proceeding against various 

underwriters and other parties involved in the issuance of Commonwealth bonds 

[Adv. Proc. No. 19-280]. Moreover, pursuant to the Commonwealth Plan, the 

underwriter litigation was transferred to the Avoidance Actions Trust. On the 

effective date of the Commonwealth Plan, the underwriter litigation was transferred 

to the Avoidance Actions Trust. Continental continues to handle the underwriter 

litigation as counsel to the Avoidance Actions Trustee alongside CST. 

• GO Bond Claim Objections: Upon the effective date of the Commonwealth Plan, 

the GO Bond Claim Objection were resolved in accordance with the 

Commonwealth Plan.

73. The sub-budgets and staffing plans with respect to the jointly pursued matters 

described above are included as part of Exhibit D-1 and Exhibit D-2, respectively.

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ACTUAL AND NECESSARY DISBURSEMENTS

74. As set forth in Exhibit E-2, Continental disbursed $63.96 as expenses incurred in 

providing professional services during the Application Period.

75. Continental believes the rates for charges incurred are at or below market rates that 

the majority of law firms charge clients for such services. In addition, Continental 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

76. 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;

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;

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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.

77. In the instant case, Continental respectfully submits that the services for which it 

seeks compensation in this First Interim 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.

78. 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, Continental sought to minimize the costs of Continental’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 Continental attorneys was utilized for the 

vast majority of the work in order to minimize the costs of intra-Continental communication and 

education about the Title III Cases. As demonstrated by this First Interim Application, Continental

spent its time economically and without unnecessary duplication. Accordingly, approval of the 

compensation sought is warranted.

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NOTICE

79. In accordance with the Interim Compensation Order, Continental will provide 

notice of this First Interim 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 First Interim Application will be served on all parties that 

have filed a notice of appearance in the Title III Cases.

CONCLUSION

WHEREFORE, Continental respectfully requests entry of an order, substantially in the 

form attached hereto as Schedule 3, (i) allowing interim compensation for professional services 

rendered during the Application Period in the amount of $249,241.50, representing 100% of the 

fees billed during the Application Period (not including Continental’s voluntary fee reduction 

equal to 20% in the amount of $49,848.30) and reimbursement of $63.96, 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 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 Continental’s 

right to seek such further compensation and/or payment for the full value of services performed 

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35

and expenses incurred, and (iv) granting Continental such other and further relief as is just.

Dated: October 27, 2022.

/s/ John Arrastia

John Arrastia, Esq. (Pro Hac Vice)

CONTINENTAL PLLC

255 Alhambra Cir, Suite 640 

Coral Gables, FL 33134

Tel: 305-677-2707

JArrastia@ContinentalPLLC.com

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36

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 JOHN ARRASTIA, ESQ. IN SUPPORT OF THE FIRST

INTERIM FEE APPLICATION OF CONTINENTAL PLLC, AS SPECIAL LITIGATION 

COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR 

SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD 

FROM FEBRUARY 15, 2022 THROUGH MAY 31, 2022

I, John Arrastia, certify that the following is true to the best of my knowledge information, 

and belief:

1. I am an attorney and shareholder of Continental PLLC (“Continental”), with two

offices in Florida located at 255 Alhambra Circle, Suite 640, Coral Gables, Florida 33134 

(“Miami”); and 101 North Monroe Street, Suite 750, Tallahassee, Florida 32301 (“Tallahassee”), 

and one office located in Washington, D.C. at 1747 Pennsylvania Avenue, NW, Ste. 875, 

Washington, D.C. 20006 (“Washington, D.C.”). 

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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37

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 Continental. The facts 

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

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

Continental 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 Second Amended Order Setting Procedures for Interim 

Compensation and Reimbursement of Expenses of Professionals entered June 6, 2018 (the “Interim 

Compensation Order”), this Certification is made with respect to the Seventh Interim Application 

of Continental PLLC, as Special Litigation Counsel to Official Committee of Unsecured Creditors,

for Services Rendered and Reimbursement of Expenses for the Period from June 1, 2021 through 

September 30, 2021 (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 Continental generally (taking into consideration 

that Continental 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 

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

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38

percentages) and billed in accordance with the Engagement Letter and Retention Order; and (c) in 

providing a reimbursable services, Continental does not make a profit on that service, whether the 

service is performed by Continental in-house or through a third party.

6. In accordance with the Engagement Letter and Retention Order, Continental agreed 

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

$49,848.30 in the First Interim Application. Continental seeks allowance of all of its fees incurred 

during the Application Period in the amount of $249,241.50, to the extent such amount has not 

been paid before the hearing scheduled on this First Interim Application. 

7. Continental 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, 

Continental 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 $49,848.30.

Question: If the fees sought in this First Interim 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 First Interim 

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 

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39

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 First Interim Application includes approximately 7.9 hours and 

associated fees of approximately $2,034.50 related to preparing, 

reviewing, and revising Continental’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 27th day of October 2022.

/s/ John Arrastia

John Arrastia, Esq. (Pro Hac Vice)

CONTINENTAL PLLC

255 Alhambra Cir, Suite 640 

Coral Gables, FL 33134

Tel: 305-677-2707

JArrastia@ContinentalPLLC.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

CONTINENTAL

BLENDED 

HOURLY RATE1

CONTINENTAL

BLENDED 

HOURLY RATE

(AFTER 20%

REDUCTION)2

Partner

$611.91 $529.51 $423.60

Counsel N/A N/A N/A

Associate $392.56 $359.70 $287.76

All timekeepers 

aggregated $506.26 $441.25 $353.00

1 The calculation of Continental’s Blended Hourly Rate does not take into account Continental’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 First Interim 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 Billed

Number of 

Rate 

Increases 

Since Case 

Inception

In this 

Application

Arrastia, John Partner Litigation 1996 $59,972.50 104.3 $575.00 0

Suarez, Jesus 

M.

Partner Bankruptcy 2008 $80,400.00 160.8 $500.00 0

 Total Partner: 265.1

Castaldi, 

Angelo M. Associate Litigation 2015 $80,962.50 215.9 $375.00 0

Alvarez,

Carlos E. Associate Litigation 2018 $24,381.00 77.4 $315.00 0

 Total Associate: 293.3

Gray, Heather Paralegal $3,523.50 26.1 $135.00 0

Total Paraprofessional: 26.1

Total: $249,241.50 584.5

Blended Rate: $426.42

Blended Rate Excluding

Paraprofessionals:

$440.04

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EXHIBIT D

BUDGET AND STAFFING PLAN

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EXHIBIT D-1

BUDGETS FOR:

February 2022

March 2022

April 2022

May 2022

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EXHIBIT D-1

BUDGETS

Period Covered: February 15, 2022 - February 28, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

February

2022

B100 Administration 0

B110 Case Administration 10

B112 General Creditor Inquiries 0

B113 Pleadings Review 15

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 10

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 2

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 10

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 250

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

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B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 323

TOTAL FEES: $166,367.61

MINUS 20%

REDUCTION: $33,273.52

TOTAL FEES:

(NET OF REDUCTION) $133,094.09

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ADDITIONAL FEBRUARY 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: February 15, 2022 through February 28, 2022 

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee Retirement 

System (ERS) and the Puerto Rico Electric Power Authority Company (PREPA)

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

Period February 15, 2022 

through February 28, 2022

B180 Avoidance Actions 8

Total hours 8

On July 12, 2019, the court also approved procedures establishing a framework for streamlined 

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

actions through a voluntary mediation process.

B. Omnibus Objection of Oversight Board and Committee to 2012-2014 GO Bond 

Claims [Docket No. 4784] (the “Omnibus GO Claims Objection”) 

On March 10, 2020, the Court stayed the Omnibus GO Claim Objection pending a decision on 

confirmation of the Commonwealth plan of adjustment. 

C. Adversary Proceedings Challenging Liens Asserted by Holders of GO Bonds (“GO 

Lien Challenges”) 

On March 10, 2020, the Court stayed the GO Lien Challenges pending a decision on confirmation 

of the Commonwealth plan of adjustment. 

D. Adversary Proceeding Against Underwriters, Etc. 

Continental represents the Committee with respect to the adversary proceeding against various 

underwriters and other parties involved in the issuance of Commonwealth bonds [Adv. Proc. No. 

19-280]. On March 10, 2020, the Court stayed the underwriter litigation pending a decision on 

confirmation of the Commonwealth plan of adjustment. 

E. Other Stayed Co-Plaintiff Adversary Proceedings 

Per Judge Swain’s March 10, 2020 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment.

• Eight adversary proceedings seeking to recover fraudulent transfers made on account 

of GO bonds that were not validly issued [Adv. Proc. No. 19-281, Adv. Proc. No. 19-

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282, Adv. Proc. No. 19-283, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Four adversary proceedings challenging liens asserted by certain holders of HTA bonds 

[Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. Proc. 

No. 19-365]. 

Per Judge Swain’s April 28, 2021 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment. 

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

[Adv. Proc. No. 19-366 and Adv. Proc. No. 19-367] and six adversary proceedings 

regarding ultra vires issues with respect to ERS Bonds [Adv. Proc. No. 19-355, Adv. 

Proc. No. 19- 356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-

359, and Adv. Proc. No. 19-361].

F. Contested Matters 

Continental 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. Continental anticipates 

its involvement in these matters as it relates to conflict issues.

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Period Covered: March 1, 2022 - March 31, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

March 2022

B110 Administration 0

B110 Case Administration 15

B112 General Creditor Inquiries 0

B113 Pleadings Review 12

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 5

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 2

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 25

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 110

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 22

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

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B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 207

TOTAL FEES: $96,255 

MINUS 20%

REDUCTION:

$19,251 

TOTAL FEES:

(NET OF REDUCTION) $77,004 

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ADDITIONAL MARCH 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: March 1, 2022 through March 31, 2022 

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee Retirement 

System (ERS) and the Puerto Rico Electric Power Authority Company (PREPA)

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

Period March 1, 2022 

through March 31, 2022

B180 Avoidance Actions 2

Total hours 2

B. Omnibus Objection of Oversight Board and Committee to 2012-2014 GO Bond 

Claims [Docket No. 4784] (the “Omnibus GO Claims Objection”) 

As the effective date of the Commonwealth plan of adjustment (March 15, 2022), the Omnibus 

GO Claims Objections are resolved.

C. Adversary Proceedings Challenging Liens Asserted by Holders of GO Bonds (“GO 

Lien Challenges”) 

As the effective date of the Commonwealth plan of adjustment (March 15, 2022), the Omnibus 

GO Claims Objections are resolved.

D. Adversary Proceeding Against Underwriters, Etc. 

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over the 

underwriter litigation.

E. Other Stayed Co-Plaintiff Adversary Proceedings 

Per Judge Swain’s March 10, 2020 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment.

• Eight adversary proceedings seeking 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, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Four adversary proceedings challenging liens asserted by certain holders of HTA bonds 

[Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. Proc. 

No. 19-365]. 

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Per Judge Swain’s April 28, 2021 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment. 

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

[Adv. Proc. No. 19-366 and Adv. Proc. No. 19-367] and six adversary proceedings 

regarding ultra vires issues with respect to ERS Bonds [Adv. Proc. No. 19-355, Adv. 

Proc. No. 19- 356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-

359, and Adv. Proc. No. 19-361].

F. Contested Matters 

Continental represented 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. 

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Period Covered: April 1, 2022 - April 30, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

April 2022

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 5

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 5

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 2

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 70

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 7

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

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B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 111

TOTAL FEES: $51,615

MINUS 20% REDUCTION: $10,323

TOTAL FEES:

(NET OF REDUCTION) $41,292

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ADDITIONAL APRIL 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: April 1, 2022 through April 30, 2022 

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee Retirement 

System (ERS) and the Puerto Rico Electric Power Authority Company (PREPA)

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over the 

prosecution of the garden-variety avoidance actions.

B. Omnibus Objection of Oversight Board and Committee to 2012-2014 GO Bond 

Claims [Docket No. 4784] (the “Omnibus GO Claims Objection”) 

As the effective date of the Commonwealth plan of adjustment (March 15, 2022), the Omnibus 

GO Claims Objections are resolved.

C. Adversary Proceedings Challenging Liens Asserted by Holders of GO Bonds (“GO 

Lien Challenges”) 

As the effective date of the Commonwealth plan of adjustment (March 15, 2022), the Omnibus 

GO Claims Objections are resolved.

D. Adversary Proceeding Against Underwriters, Etc. 

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over the 

underwriter litigation.

E. Other Stayed Co-Plaintiff Adversary Proceedings 

Per Judge Swain’s March 10, 2020 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment.

• Eight adversary proceedings seeking 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, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Four adversary proceedings challenging liens asserted by certain holders of HTA bonds 

[Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. Proc. 

No. 19-365]. 

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Per Judge Swain’s April 28, 2021 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment. 

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

[Adv. Proc. No. 19-366 and Adv. Proc. No. 19-367] and six adversary proceedings 

regarding ultra vires issues with respect to ERS Bonds [Adv. Proc. No. 19-355, Adv. 

Proc. No. 19- 356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-

359, and Adv. Proc. No. 19-361].

F. Contested Matters 

Continental represented 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. 

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Period Covered: May 1, 2022 - May 31, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

May 2022

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 15

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 15

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 2

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 235

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 7

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

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B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 296

TOTAL FEES: $137,640

MINUS 20%

REDUCTION: $27,528

TOTAL FEES:

(NET OF REDUCTION) $110,112

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ADDITIONAL MAY 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: May 1, 2022 through May 31, 2022 

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee Retirement 

System (ERS) and the Puerto Rico Electric Power Authority Company (PREPA)

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee has taken taking over 

the prosecution of the garden variety avoidance actions.

B. Omnibus Objection of Oversight Board and Committee to 2012-2014 GO Bond 

Claims [Docket No. 4784] (the “Omnibus GO Claims Objection”) 

As the effective date of the Commonwealth plan of adjustment (March 15, 2022), the Omnibus 

GO Claims Objections have been resolved.

C. Adversary Proceedings Challenging Liens Asserted by Holders of GO Bonds (“GO 

Lien Challenges”) 

As the effective date of the Commonwealth plan of adjustment (March 15, 2022), the GO Lien 

Challenges are resolved.

D. Adversary Proceeding Against Underwriters, Etc. 

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over the 

underwriter litigation.

E. Other Stayed Co-Plaintiff Adversary Proceedings 

Per Judge Swain’s March 10, 2020 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment.

• Eight adversary proceedings seeking 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, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Four adversary proceedings challenging liens asserted by certain holders of HTA bonds 

[Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. Proc. 

No. 19-365]. 

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Document Page 58 of 160
Per Judge Swain’s April 28, 2021 stay order, the following adversary proceedings (in which the 

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) also remained 

stayed pending a decision on confirmation of the Commonwealth plan of adjustment. 

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

[Adv. Proc. No. 19-366 and Adv. Proc. No. 19-367] and six adversary proceedings 

regarding ultra vires issues with respect to ERS Bonds [Adv. Proc. No. 19-355, Adv. 

Proc. No. 19- 356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-

359, and Adv. Proc. No. 19-361].

F. Contested Matters 

Continental represented 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. Continental anticipates 

its involvement in these matters as it relates to conflict issues.

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EXHIBIT D-2

STAFFING PLAN 

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Document Page 60 of 160
Period Covered: February 15, 2022 through February 28, 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 02/15/22 

through 02/28/22

Average hourly rate 

for 03/01/22 through 

03/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

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Period Covered: March 1, 2022 through March 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 03/01/22 

through 03/31/22

Average hourly rate 

for 04/01/22 through 

04/30/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

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Period Covered: April 1, 2022 through April 30, 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 04/01/22 

through 04/30/22

Average hourly rate 

for 02/01/22 through 

05/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

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Period Covered: May 1, 2022 through May 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 05/01/22 

through 05/31/22

Average hourly rate 

for 05/01/22 through 

05/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

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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

February

2022

March

2022

April

2022

May

2021 TOTAL 

B100 Administration 0 0 .8 .7 1.5

B110 Case Administration 5.20 2.90 .80 1.50 10.40

B112 General Creditor

Inquiries 0 0 0 0 0

B113 Pleadings Review 7.0 14.10 15.0 26.40 62.5

B120 Asset Analysis and

Recovery 0 0 0 0 0

B130 Asset Disposition 0 0 0 0 0

B140 Relief from Stay/Adequate 

Protection Proceedings 0 0 0 0 0

B150 Meetings of Creditors’

Committee and Communications

with Creditors

.40 .90 1.0 1.60 3.90

B155 Court Hearings (including

Preparation for Court Hearings) 0 0 0 0 0

B160 Employment / Fee 

Applications (CONTINENTAL)

34.5 2.0 3.4 13.1 53.0

B161 Budgeting (Case) 0 0 0 0 0

B165 Employment / Fee

Application (Other Professionals) 0 0 0 0 0

B170 Fee and Employment

Objections 0 0 0 0 0

B180 Avoidance Action Analysis 0 0 0 0 0

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B181 Preference Analysis and 

Recovery Action 0 0 0 0 0

B185 Assumption / Rejection of 

Leases and Contracts 0 0 0 0 0

B190 Other Contested Matters 

 (including GDB restructuring) 0 0 0 0 0

B191 General Litigation 62.70 34.10 89.10 257.10 443.00

B195 Non-Working Travel 0 0 0 0 0

B210 Debtors’ Financial 

 Information 

 and Operations/Fiscal Plan

0 0 0 0 0

B220 Employee Benefits / 

 Pensions

0 0 0 0 0

B230 Financing / Cash 

 Collections

0 0 0 0 0

B231 Security Document 

 Analysis

0 0 0 0 0

B260 Meetings/Communications 

with Debtors/ Oversight Board .2 .1 0 .7 1

B261 Investigations 0 0 0 0 0

B310 Claims Administration 

 and Objections

0 0 0 0 0

B312 Objections to Claims 0 0 0 0 0

B320 Plan and Disclosure

 Statement

0 1.0 1.6 3.1 5.7

B321 Business Plan 0 0 0 0 0

B410 General Bankruptcy 

 Advice and Opinions

0 0 0 0 0

B420 Restructurings 0 0 0 0 0

TOTAL HOURS: 112.4 55.1 111.70 304.8 584.0

TOTAL FEES: $47,196.50 $23,435.00 $47,473.50 $131,136.50 $249,241.5

0

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MINUS 20%

REDUCTION: $9,439.30 $4,687.00 $9,494.70 $26,227.30 $49,848.30

TOTAL FEES:

(NET OF REDUCTION) $37,757.20 $18,748.00 $37,978.80 $104,909.20 $199,393.20

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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 101)

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

B100 Administration .80 $460.00

B110 Case Administration 9.5 $1,970.50

B113 Pleadings Review 62.50 $19,687.50

B120 Asset Analysis and Recovery 0 $0

B150 Meeting of Creditors 3.10 $1,685.00

B155 Court Hearings 0 $0

B160 Employment / Fee Applications (CONTINENTAL) 53.00 $21,461.00

B161 Budgeting (Case) 0 $0

B191 General Litigation 106.40 $44,894.50

B260 Meetings and Communications with Board .3 $172.50

B300 Claims and Plan 0 $0

L150 Budgeting .6 $81.00

TOTAL 236.20 $90,412.00

PREPA (Matter ID 102)

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

B100 Administration .7 $350.00

B110 Case Administration .9 $473.50

B113 Pleadings Review 0 $0

B120 Asset Analysis and Recovery 0 0

B150 Meeting of Creditors .8 $460.00

B155 Court Hearings 0 $0

B160 Employment / Fee Applications (CONTINENTAL) 0 $0

B161 Budgeting (Case) 0 $0

B191 General Litigation 328.40 $149,116.00

B260 Meetings and Communications with Board .7 $402.50

B300 Claims and Plan 0 $0

L150 Budgeting 0 $0

TOTAL 332.90 $90,412.0

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ERS (Matter ID 103)

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

B100 Administration 0 $0

B110 Case Administration 0 $0

B113 Pleadings Review 0 $0

B120 Asset Analysis and Recovery 0 $0

B150 Meeting of Creditors 0 $0

B155 Court Hearings 0 $0

B160 Employment / Fee Applications (CONTINENTAL) 0 $0

B161 Budgeting (Case) 0 $0

B191 General Litigation 1.60 $800.00

B260 Meetings and Communications with Board 0 $0

B300 Claims and Plan 0 $0

L150 Budgeting 0 $0

TOTAL 1.60 $800.00

HTA (Matter ID 104)

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

B100 Administration 0 $0

B110 Case Administration 0 $0

B113 Pleadings Review 0 $0

B120 Asset Analysis and Recovery 0 $0

B150 Meeting of Creditors 0 $0

B155 Court Hearings 0 $0

B160 Employment / Fee Applications (CONTINENTAL) 0 $0

B161 Budgeting (Case) 0 $0

B191 General Litigation 6.60 $2,842.50

B260 Meetings and Communications with Board 0 $0

B300 Claims and Plan 1.3 $747.50

L150 Budgeting 0 $0

TOTAL 12.60 $6,292.50

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EXHIBIT E-2

SUMMARY OF EXPENSE REIMBURSEMENTS REQUESTED BY

CATEGORY

Category Amount

Travel Expenses – Airfare $0

Travel Expenses – Lodging $0

Travel Expenses - Taxi / Ground Transportation $0

Travel Expenses – Parking $0

Meals (while working on Committee matters) $0

Court call $0

Long Distance Phone Calls $0

Process Service Fee $0

Messenger $0

Computer Search $0

Articles and Publications $0

Court Reporting Services $0

In-house Black and White Reproduction Charges $0

Outside Photocopies $0

Outside Professional Services $0

Postage/Express Mail $63.96

Data Management/Web Hosting $0

Miscellaneous- Website Domain and Maintenance $0

TOTAL $63.96

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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

February 2022 Fee Statement

March 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) $38,828.00 $7,765.60 $27,956.16 $0.00 $27,956.16

Total for PREPA

(all outside of Puerto Rico) $7,506.00 $1,501.20 $5,404.32 $0.00 $5,404.32

Total for ERS

(all outside of Puerto Rico) $0.00 $0.00 $0.00 $0.00 $0.00

Total for HTA

(all outside of Puerto Rico) $862.50 $172.50 $621.00 $0.00 $621.00

 Grand Total $47,196.50 $9,439.30 $33,891.48 $0.00 $33,891.48

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) $17,280.00 $3,456.00 $12,441.60 $63.96 $12,505.56

Total for PREPA

(all outside of Puerto Rico) $5,867.50 $1,173.50 $4,224.60 $0.00 $4,224.60

Total for ERS

(all outside of Puerto Rico) $172.50 $34.50 $124.20 $0.00 $124.20

Total for HTA

(all outside of Puerto Rico) $115.00 $23.00 $82.80 $0.00 $82.80

 Grand Total $23,435.00 $4,687.00 $16,873.20 $0.00 $16,873.20

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April 2022 Fee Statement

May 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) $12,006.00 $2,401.20 $8,644.32 $0.00 $8,644.32

Total for PREPA

(all outside of Puerto Rico) $34,247.50 $6,849.50 $24,658.20 $0.00 $24,658.20

Total for ERS

(all outside of Puerto Rico) $0.00 $0.00 $0.00 $0.00 $0.00

Total for HTA

(all outside of Puerto Rico)

 

$1,220.00 $244.00 $878.40 $0.00 $878.40

 Grand Total $46,473.50 $9,949.70 $34,180.92 $0.00 $34,180.92

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) $22,298.00 $4,459.60 $16,054.56 $0.00 $16,054.56

Total for PREPA

(all outside of Puerto Rico) $104,116.00 $20,823.20 $74,963.52 $0.00 $74,963.52

Total for ERS

(all outside of Puerto Rico) $627.50 $125.50 $451.80 $0.00 $451.80

Total for HTA

(all outside of Puerto Rico) $4,095.00 $819.00 $2,948.40 $0.00 $2,948.40

 Grand Total $131,136.50 $26,227.30 $94,418.28 $0.00 $94,418.28

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SCHEDULE 1

LIST OF PROFESSIONALS BY MATTER

Official Comm. of Unsecured Creditors of Commonwealth of PR (Matter ID 101)

Name Title or Position Department, Group, or

Section

Arrastia, John Partner Litigation

Suarez, Jesus M. Partner Bankruptcy

Castaldi, Angelo M. Associate Litigation/Bankruptcy

Alvarez, Carlos E. Associate Litigation

Gray, Heather Paralegal Litigation/Bankruptcy

PREPA (Matter ID 102)

Name Title or Position Department, Group, or

Section

Arrastia, John Partner Litigation

Suarez, Jesus M. Partner Bankruptcy

Castaldi, Angelo M. Associate Litigation/Bankruptcy

Alvarez, Carlos E. Associate Litigation

Gray, Heather Paralegal Litigation/Bankruptcy

ERS (Matter ID 103)

Name Title or Position Department, Group, or

Section

Arrastia, John Partner Litigation

Castaldi, Angelo M. Associate Litigation/Bankruptcy

Gray, Heather Paralegal Litigation/Bankruptcy

HTA (Matter ID 104)

Name Title or Position Department, Group, or

Section

Arrastia, John Partner Litigation

Castaldi, Angelo M. Associate Litigation/Bankruptcy

Gray, Heather Paralegal Litigation/Bankruptcy

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SCHEDULE 2

MONTHLY STATEMENTS COVERED IN APPLICATION

(Attached)

DATE PERIOD 

COVERED

TOTAL 

FEES

20% 

DISCOUNT

FEES 

REQUESTED 

(90%)

HOLDBACK

(10%)

EXPENSES 

REQUESTED

03/23/22 February

2022

$47,196.50 $9,439.30 $33,981.48 $3,775.72 $0.00

05/04/22 March

2022

$23,435.00 $4,687.00 $16,873.20 $1,874.80 $63.96

05/12/22 April

2022

$47,473.50 $9,494.70 $34,180.92 $3,797.88 $0.00

06/30/22 May

2022

$131,136.50 $26,227.30 $94,418.28 $10,490.92 $0.00

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We appreciate your business. Thank you. Page 1 of

9

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

March 04, 2022

PROMESA / UCC

Invoice Number: 141

Invoice Period: 02-12-2022 - 02-28-2022

Payment Terms: Upon Receipt

RE: Commonwealth of Puerto Rico

Time Details

Date Professional Task Hours Rate Amount

B110 - Case Administration

02-15-2022 Carlos Alvarez B110 - Case Administration 1.60 315.00 504.00

confer with team concerning case alerts on Prime Clerk, familiarize with various adversary

proceeding cases creating alerts systems for open cases, reach out to Prime Clerk to set up alerts

for avoidance actions (1.6)

02-15-2022 Angelo Castaldi B110 - Case Administration 1.30 375.00 487.50

Comprehensive review and analysis of the Court's Fourteenth (and redlined Fifteenth) Order

Further Amending Case Management Procedures, and correlative review of Bankruptcy Rule 2002

02-15-2022 Heather Gray B110 - Case Administration 2.20 135.00 297.00

Prepare and file Notices of Appearance in all adversary an main cases for J. Arrastia and J. Suarez.

5.10 1,288.50

B113 - Pleadings Review

02-16-2022 Carlos Alvarez B113 - Pleadings Review 1.70 315.00 535.50

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal

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We appreciate your business. Thank you. Page 2 of

9

Date Professional Task Hours Rate Amount

B113 - Pleadings Review

02-17-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal

02-18-2022 Carlos Alvarez B113 - Pleadings Review 1.30 315.00 409.50

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal.

02-22-2022 Carlos Alvarez B113 - Pleadings Review 1.30 315.00 409.50

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal

02-23-2022 Carlos Alvarez B113 - Pleadings Review 0.90 315.00 283.50

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal

02-24-2022 Carlos Alvarez B113 - Pleadings Review 0.20 315.00 63.00

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal

02-25-2022 Carlos Alvarez B113 - Pleadings Review 1.20 315.00 378.00

Receive, review, and analyze case filings and prepare status report and circulate for review by all

attorneys and calendaring of deadlines by paralegal

7.00 2,205.00

B150 - Meetings of and Communications with Creditors

02-23-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

575.00 No Charge

Prepare client status update (.2)

02-23-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.40 575.00 230.00

Attend periodic litigation strategy and case call

0.40 230.00

B160 - Fee/Employment Application

02-12-2022 Angelo Castaldi B160 - Fee/Employment Application 2.10 375.00 787.50

Prepare application to employ and affidavit of J. Arrastia in support of the same.

02-13-2022 Angelo Castaldi B160 - Fee/Employment Application 0.90 375.00 337.50

Prepare and revise declaration of D. Mack and proposed order concerning Continental PLLC

employment application.

02-13-2022 Angelo Castaldi B160 - Fee/Employment Application 1.70 375.00 637.50

Prepare exhaustive and comprehensive Schedule to accompany Arrastia declaration, which

Schedule itemized thousands of interested persons for purposes of firm conflict check.

02-13-2022 Angelo Castaldi B160 - Fee/Employment Application 0.80 375.00 300.00

Revise application to employ and affidavit of J. Arrastia in support of the same.

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We appreciate your business. Thank you. Page 3 of

9

Date Professional Task Hours Rate Amount

B160 - Fee/Employment Application

02-14-2022 Angelo Castaldi B160 - Fee/Employment Application 3.60 375.00 1,350.00

Prepare and revise over 70 notices of appearance for filing in cases in which Continental attorneys

have made an appearance.

02-14-2022 Jesus Suarez B160 - Fee/Employment Application 1.60 500.00 800.00

Work on retention application, preparation of notices of appearance.

02-14-2022 Carlos Alvarez B160 - Fee/Employment Application 2.40 315.00 756.00

Review, revise, and edit over 70 NOAs for filling; confer and strategize with team on same.

02-15-2022 Angelo Castaldi B160 - Fee/Employment Application 0.40 375.00 150.00

Revise application to employ Continental.

02-15-2022 Angelo Castaldi B160 - Fee/Employment Application 1.60 375.00 600.00

Detailed and exhaustive preparation and revision of 300-page Schedule to declaration of J.

Arrastia, which includes appearances in more than 70 cases

02-15-2022 Angelo Castaldi B160 - Fee/Employment Application 0.80 375.00 300.00

Revise declaration of J. Arrastia, D. Mack, and proposed order.

02-15-2022 Carlos Alvarez B160 - Fee/Employment Application 3.20 315.00 1,008.00

Confer with team concerning revisions to multiple NOAs, revise same to prepare for filing (1.8); ;

revisions, proof read, and edits to proposed order, application to employ, D. Mack Declaration, and

Arrastia Declaration, confer and strategize with team on same (1.4).

02-15-2022 Jesus Suarez B160 - Fee/Employment Application 3.10 500.00 1,550.00

Work on employment application for Continental as Special Litigation Counsel and Conflicts

Counsel to UCC (2.3); attention on substitution of counsel and filing of appearances (.8)

02-16-2022 Jesus Suarez B160 - Fee/Employment Application 1.40 500.00 700.00

Attention to conflicts and revision of Arrastia Declaration in support of employment of Continental.

02-16-2022 Angelo Castaldi B160 - Fee/Employment Application 0.20 375.00 75.00

Telephone communication with office of local counsel.

02-16-2022 Angelo Castaldi B160 - Fee/Employment Application 1.20 375.00 450.00

Review and analyze list of thousands of "interested" persons, and pseudonymous litigation targets,

and prepare further revisions to retention application.

02-17-2022 Angelo Castaldi B160 - Fee/Employment Application 0.60 375.00 225.00

Prepare revisions to application to employ, proposed order, and Arrastia declaration.

02-17-2022 Jesus Suarez B160 - Fee/Employment Application 0.70 500.00 350.00

Revise employment application of Continental.

02-18-2022 Jesus Suarez B160 - Fee/Employment Application 0.80 500.00 400.00

Conference with local counsel concerning filing and service of application and follow up concerning

same.

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Date Professional Task Hours Rate Amount

B160 - Fee/Employment Application

02-21-2022 Angelo Castaldi B160 - Fee/Employment Application 0.40 375.00 150.00

Prepare additional revisions to employment application and Declaration of D. Mack.

02-23-2022 Angelo Castaldi B160 - Fee/Employment Application 1.30 375.00 487.50

Prepare draft informative motion.

02-23-2022 John Arrastia B160 - Fee/Employment Application 0.40 575.00 230.00

Prepare proposed budget

02-24-2022 Angelo Castaldi B160 - Fee/Employment Application 0.20 375.00 75.00

Revise and finalize declaration of D. Mack in support of employment application.

02-25-2022 Jesus Suarez B160 - Fee/Employment Application 0.80 500.00 400.00

Work on informative motions regarding change of firm.

02-25-2022 Angelo Castaldi B160 - Fee/Employment Application 0.30 375.00 112.50

Revise informative motion concerning retention of Continental.

02-25-2022 Angelo Castaldi B160 - Fee/Employment Application 1.10 375.00 412.50

Revise application to employ and corresponding exhibits.

02-25-2022 Angelo Castaldi B160 - Fee/Employment Application 0.20 375.00 75.00

Draft notice of hearing and refer to applicable case management procedures further to same.

02-28-2022 Angelo Castaldi B160 - Fee/Employment Application 0.70 375.00 262.50

Revise application to employ and corresponding exhibits, and attend to multiple communications

with local counsel concerning the same.

02-28-2022 Angelo Castaldi B160 - Fee/Employment Application 1.30 375.00 487.50

Finalize informative motions for filing in each case in which firm attorneys have previously appeared.

02-28-2022 Jesus Suarez B160 - Fee/Employment Application 0.70 500.00 350.00

Review issues concerning service of employment application (.3) and revise informative motions (.4)

34.50 13,819.00

B191 - General Litigation

02-14-2022 Jesus Suarez B191 - General Litigation 1.40 500.00 700.00

Receive and review correspondence from T. Axelrod concerning dismissal of certain claw back

actions (.3); follow-up review of requested dismissals (.7); and development of proposed response

regarding same (.4)

02-15-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

02-16-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Review correspondence to tolled parties (.2); attend to additional tolling agreements (.2)

02-16-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Confer and strategize internally concerning ongoing litigation items in Commonwealth and PREPA

cases and related adversary proceedings.

02-17-2022 Jesus Suarez B191 - General Litigation 2.40 500.00 1,200.00

Review issues concerning transfer of databases and discovery to UCC in connection with

confirmation of plan and creation of creditor trust (1.6); special attention to issues relating to

insolvency (.8)

02-18-2022 John Arrastia B191 - General Litigation 1.70 575.00 977.50

Review correspondence to tolled parties (.1); attention to tolling agreements (.1); confer with SCC

regarding filing Complaints of tolling agreements not received (.2); review Memorandum regarding

Plan Implementation (.2); analyze issues regarding potential Complaints against parties that have

not executed tolling agreements (.4); review Motion to Appoint Mediator (.6); review Order [DE

2717] (.1)

02-18-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Attend to myriad communications concerning tolling agreements and extensions thereof.

02-19-2022 John Arrastia B191 - General Litigation 0.70 575.00 402.50

Confer with counsel for tolled party regarding extension to tolling agreement (.1); Review

correspondence from SCC and materials relating to Underwriter-related claims )(.6)

02-21-2022 Angelo Castaldi B191 - General Litigation 2.70 375.00 1,012.50

02-21-2022 Angelo Castaldi B191 - General Litigation 0.60 375.00 225.00

Review and analysis litigation analysis distributed by counsel for SCC.

02-21-2022 Angelo Castaldi B191 - General Litigation 1.40 375.00 525.00

Review of ongoing correspondence concerning particular tolling defendant and communications

concerning extension of tolling agreement, and analyze potential claims against the same

defendant.

02-22-2022 Angelo Castaldi B191 - General Litigation 2.10 375.00 787.50

Preparation of draft adversary complaint against tolled defendant.

02-22-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Reviewed and prepared tolling agreements for execution, and review of / attend to communications

concerning the same .

02-22-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review Joinder to Motion for Mediation (.1); Review extension of tolling agreement (.1);

02-22-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review Case Management Order [20190] (.1)

02-23-2022 Jesus Suarez B191 - General Litigation 1.80 500.00 900.00

Continued attention to plan litigation and appeals concerning potential impact to litigation claims to

be transferred to avoidance action trust.

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Date Professional Task Hours Rate Amount

B191 - General Litigation

02-23-2022 Angelo Castaldi B191 - General Litigation 3.60 375.00 1,350.00

Continued preparation of draft adversary complaint against tolled defendant.

02-23-2022 John Arrastia B191 - General Litigation 0.70 575.00 402.50

Review Bond Disclosures by GO Bondholders (.3); Review Disclosures by Ad HOC PREPA

bondholders (.4)

02-23-2022 John Arrastia B191 - General Litigation 1.90 575.00 1,092.50

Prepare elements of draft complaint against party with expiring agreement (1.1); Research case file

regarding potential defendant (.8)

02-24-2022 John Arrastia B191 - General Litigation 3.20 575.00 1,840.00

Prepare draft complaint as to remaining party without extension to tolling agreement in anticipation

of expiration of tolling (2.1); Review draft complaint (.6); Review correspondence to non-tolled party

(.1); Confer with SCC (.2.); Communicate with committee regarding status of tolled parties (.2)

02-24-2022 Angelo Castaldi B191 - General Litigation 3.20 375.00 1,200.00

Review and analyze source documentation concerning relationship defendant-entities, and review

source documents concerning bond issuances in furtherance of drafting amended complaint.

02-24-2022 Angelo Castaldi B191 - General Litigation 6.80 375.00 2,550.00

Preparation of draft adversary complaint against tolled defendant.

02-24-2022 Jesus Suarez B191 - General Litigation 1.80 500.00 900.00

02-24-2022 Heather Gray B191 - General Litigation 0.40 135.00 54.00

Calendar Omnibus Hearings in Order Further Amending Case Management Procedures [DE

20190].

02-25-2022 Heather Gray B191 - General Litigation 0.10 135.00 13.50

Calendar deadline in Order [DE 138].

02-25-2022 Jesus Suarez B191 - General Litigation 1.90 500.00 950.00

 (.6); additional review

of issues concerning transfer of adversary proceedings to creditor trust and related insolvency

analysis and litigation materials (1.3)

02-25-2022 Angelo Castaldi B191 - General Litigation 1.80 375.00 675.00

Review and analyze redlines to adversary complaint proposed by counsel to the SCC and prepare

further revisions to same.

02-25-2022 John Arrastia B191 - General Litigation 0.80 575.00 460.00

Review correspondence from tolled party (.1); Confer with SCC regarding tolling (.2); Review

comments from SCC regarding draft complaint against untolled party (.4); Attention to tolling

agreement executed (.1)

02-28-2022 Jesus Suarez B191 - General Litigation 2.30 500.00 1,150.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Review issues concerning insolvency analysis as it related to transfer of avoidance actions to

creditor trust.

02-28-2022 Jesus Suarez B191 - General Litigation 0.80 500.00 400.00

Attention to litigation concerning stay of confirmation order and appeals with respect to impact on

litigation claims to be transferred to litigation trust.

02-28-2022 Heather Gray B191 - General Litigation 1.80 135.00 243.00

File Informative Motions in all adversary and main cases (1.6); confer with co-counsel paralegal

regarding logistics of paper service of same (.2)

48.30 21,170.50

B260 - Meeting with FOMB and SCC

02-22-2022 John Arrastia B260 - Meeting with FOMB and SCC 575.00 No Charge

Confer with SCC regarding status of tolled parties and potential litigation (.2)

02-23-2022 John Arrastia B260 - Meeting with FOMB and SCC 0.20 575.00 115.00

Confer with SCC regarding drafting complaint in absence of tolling agreement

0.20 115.00

Total 38,828.00

Time Summary

Task Hours Amount

B110 - Case Administration 5.10 1,288.50

B113 - Pleadings Review 7.00 2,205.00

B150 - Meetings of and Communications with Creditors 0.40 230.00

B160 - Fee/Employment Application 34.50 13,819.00

B191 - General Litigation 48.30 21,170.50

B260 - Meeting with FOMB and SCC 0.20 115.00

Total Fees 38,828.00

Total for this Invoice 38,828.00

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Client Statement of Account

As of 03-07-2022

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 38,828.00 38,828.00

HTA 862.50 862.50

PREPA 7,506.00 7,506.00

Total Amount to Pay 47,196.50

Commonwealth of Puerto Rico

Transactions

Date Transaction Applied Invoice Amount

03-04-2022 Invoice 141 38,828.00

Balance 38,828.00

Open Invoices and Credits

Date Transaction Amount Applied Balance

03-04-2022 Invoice 141 38,828.00 38,828.00

Balance 38,828.00

HTA

Open Invoices and Credits

Date Transaction Amount Applied Balance

03-04-2022 Invoice 142 862.50 862.50

Balance 862.50

PREPA

Open Invoices and Credits

Date Transaction Amount Applied Balance

03-04-2022 Invoice 143 7,506.00 7,506.00

Balance 7,506.00

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PROMESA / UCC

March 04, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 141

Invoice Period: 02-12-2022 - 02-28-2022

REMITTANCE COPY

RE: Commonwealth of Puerto Rico

Fees 38,828.00

Total for this Invoice 38,828.00

Previous Balance 8,368.50

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 38,828.00 38,828.00

HTA 862.50 862.50

PREPA 7,506.00 7,506.00

Total Amount to Pay 47,196.50

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

Balance 47,196.50

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

March 04, 2022

PROMESA / UCC

Invoice Number: 142

Invoice Period: 02-17-2022 - 02-28-2022

Payment Terms: Upon Receipt

RE: HTA

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

02-25-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review materials regarding Budget and Fiscal Plan certifications

0.20 115.00

B300 - Claims and Plan

02-17-2022 John Arrastia B300 - Claims and Plan 1.30 575.00 747.50

Review Memorandum regarding HTA Plan Issues.

1.30 747.50

Total 862.50

Time Summary

Task Hours Amount

B191 - General Litigation 0.20 115.00

B300 - Claims and Plan 1.30 747.50

Total Fees 862.50

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Total for this Invoice 862.50

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Client Statement of Account

As of 03-07-2022

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 38,828.00 38,828.00

HTA 862.50 862.50

PREPA 7,506.00 7,506.00

Total Amount to Pay 47,196.50

Commonwealth of Puerto Rico

Transactions

Date Transaction Applied Invoice Amount

03-04-2022 Previous Balance 38,828.00

Balance 38,828.00

Open Invoices and Credits

Date Transaction Amount Applied Balance

03-04-2022 Invoice 141 38,828.00 38,828.00

Balance 38,828.00

HTA

Transactions

Date Transaction Applied Invoice Amount

03-04-2022 Invoice 142 862.50

Balance 862.50

Open Invoices and Credits

Date Transaction Amount Applied Balance

03-04-2022 Invoice 142 862.50 862.50

Balance 862.50

PREPA

Open Invoices and Credits

Date Transaction Amount Applied Balance

03-04-2022 Invoice 143 7,506.00 7,506.00

Balance 7,506.00

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PROMESA / UCC

March 04, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 142

Invoice Period: 02-17-2022 - 02-28-2022

REMITTANCE COPY

RE: HTA

Fees 862.50

Total for this Invoice 862.50

Previous Balance 46,334.00

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 38,828.00 38,828.00

HTA 862.50 862.50

PREPA 7,506.00 7,506.00

Total Amount to Pay 47,196.50

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

Balance 47,196.50

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

March 04, 2022

PROMESA / UCC

Invoice Number: 143

Invoice Period: 02-14-2022 - 02-28-2022

Payment Terms: Upon Receipt

RE: PREPA

Time Details

Date Professional Task Hours Rate Amount

B110 - Case Administration

02-14-2022 Heather Gray B110 - Case Administration 0.10 135.00 13.50

Calendar Status Report deadline [DE 133].

0.10 13.50

B113 - Pleadings Review

02-19-2022 John Arrastia B113 - Pleadings Review 575.00 No Charge

Review and analyze Motion to Appoint Mediator and Impose Deadlines [DE 2716/7] (.6)

0.00 0.00

B191 - General Litigation

02-15-2022 John Arrastia B191 - General Litigation 1.60 575.00 920.00

Review source documents relative to Inspectorate Claims and Amended Complaint from SCC (1.4);

review court order [DE 134] (.1); confer with SCC regarding Inspectorate claims (.1)

02-16-2022 Jesus Suarez B191 - General Litigation 0.70 500.00 350.00

Attention to expiring tolling agreements and potential to file new claims.

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Date Professional Task Hours Rate Amount

B191 - General Litigation

02-16-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Confer with Inspectorate Counsel regarding good faith meet and confer materials (.2); confer with

local counsel regarding review of source materials (.3); confer with SCC regarding communication

to SCC (.1)

02-17-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Confer with counsel for Inspectorate on additional information (.1).

02-17-2022 Jesus Suarez B191 - General Litigation 1.40 500.00 700.00

Attention to amendment of complaint and issues concerning revised briefing schedule.

02-18-2022 John Arrastia B191 - General Litigation 0.80 575.00 460.00

Confer with opposing counsel on agreement on Motion for Leave to Amend and Briefing Schedule (.

3); confer with SCC (.3); strategize with A. Castaldi (.1); review Non-Opposition (.1)

02-22-2022 Angelo Castaldi B191 - General Litigation 1.40 375.00 525.00

Reviewed "statement" filed by defendants in 19-388 concerning Plaintiffs' motion for leave to

amend and related correspondence from defendants' counsel, and prepare proposed order and

briefing schedule concerning said motion for leave to amend.

02-22-2022 Jesus Suarez B191 - General Litigation 0.60 500.00 300.00

Confer and strategize with J. Arrastia regarding case status and upcoming discovery.

02-22-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Confer and strategize with J. Suarez regarding case status and upcoming discovery.

02-22-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review proposed order and briefing schedule (.3); Confer with SCC (.1);

02-23-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Confer with SCC regarding Draft Motion and Order on Briefing Schedule (.1); Confer with L.

Rappaport regarding Order (.1); Review Objection to AHG Motion to Compel Mediation (.2)

02-23-2022 Jesus Suarez B191 - General Litigation 1.40 500.00 700.00

Review objection strategy with respect to Bondholder Mediation Motion as it relates to pending

litigation against fuel oil suppliers and provide comment.

02-23-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Attend to strategy regarding PREPA Bondholder Motion regarding mediation

02-23-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Revise proposed order concerning leave to amend, and communicate internally and with counsel

for SCC and defendants concerning the same.

02-24-2022 Angelo Castaldi B191 - General Litigation 1.30 375.00 487.50

In case no. 19-388, draft informative motion and proposed briefing order consistent with order at

Dkt No. 138, and attend to multiple communications with SCC and, separately, defendants' counsel

concerning the same.

02-24-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Review order granting leave to File Second Amended Complaint and proposed order

02-25-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Confer with opposing counsel on motion and proposed order on briefing schedule

02-25-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review FOMB Objection to Mediation Motion

02-25-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Revise informative motion and corresponding proposed briefing schedule, and attend to

communications with counsel concerning the same

02-28-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review 2019 statement of Ad Hoc Bondholders

02-28-2022 John Arrastia B191 - General Litigation 575.00 No Charge

Review Fuel Line Lenders Joinder to Appoint Mediator )(.1); Review 2019 statement of Fuel Line

Lenders (.3); Review FOMB Opposition to Motion for Mediation (.4)

02-28-2022 Jesus Suarez B191 - General Litigation 1.30 500.00 650.00

Review objections to Motion to Compel Bondholder Mediation with respect to issues impacting

litigation against fuel oil suppliers.

14.20 7,080.00

B300 - Claims and Plan

02-21-2022 Angelo Castaldi B300 - Claims and Plan 1.10 375.00 412.50

Review and analyze filings concerning PREPA's RSA and status of PREPA plan of adjustment.

1.10 412.50

Total 7,506.00

Time Summary

Task Hours Amount

B110 - Case Administration 0.10 13.50

B113 - Pleadings Review 0.00 0.00

B191 - General Litigation 14.20 7,080.00

B300 - Claims and Plan 1.10 412.50

Total Fees 7,506.00

Total for this Invoice 7,506.00

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PROMESA / UCC

March 04, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 143

Invoice Period: 02-14-2022 - 02-28-2022

REMITTANCE COPY

RE: PREPA

Fees 7,506.00

Total for this Invoice 7,506.00

Previous Balance 279,387.11

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 54,389.63 54,389.63

ERS 675.80 675.80

HTA 4,710.30 4,710.30

PREPA 227,117.38 227,117.38

Total Amount to Pay 286,893.11

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 (27,956.16) 10,871.84

03-04-2022 Invoice 142 HTA 862.50 (621.00) 241.50

03-04-2022 Invoice 143 PREPA 7,506.00 (5,404.32) 2,101.68

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 (12,505.56) 4,838.40

04-14-2022 Invoice 168 ERS 172.50 (124.20) 48.30

04-14-2022 Invoice 169 HTA 115.00 (82.80) 32.20

04-14-2022 Invoice 170 PREPA 5,867.50 (4,224.60) 1,642.90

05-09-2022 Invoice 217 HTA 1,220.00 (878.40) 341.60

05-09-2022 Invoice 218 PREPA 34,247.50 (24,658.20) 9,589.30

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 (8,644.32) 3,361.68

06-13-2022 Invoice 246 Commonwealth of Puerto Rico 22,298.00 22,298.00

06-13-2022 Invoice 247 ERS 627.50 627.50

06-13-2022 Invoice 248 HTA 4,095.00 4,095.00

06-13-2022 Invoice 249 PREPA 104,116.00 104,116.00

07-11-2022 Invoice 253 Commonwealth of Puerto Rico 13,019.71 13,019.71

07-11-2022 Invoice 254 PREPA 109,667.50 109,667.50

Balance 286,893.11

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WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

April 14, 2022

PROMESA / UCC

Invoice Number: 167

Invoice Period: 03-01-2022 - 03-31-2022

Payment Terms: Upon Receipt

RE: Commonwealth of Puerto Rico

Time Details

Date Professional Task Hours Rate Amount

B110 - Case Administration

03-04-2022 Heather Gray B110 - Case Administration 0.30 135.00 40.50

Calendar deadlines in Order Setting Briefing Schedule [DE 144].

03-08-2022 John Arrastia B110 - Case Administration 0.20 575.00 115.00

Review US Trustee's Response to MIP (.2)

03-17-2022 Heather Gray B110 - Case Administration 0.80 135.00 108.00

Begin preparation of service of documents by U.S. mail re: [DE 20388] and [20368]

03-18-2022 Heather Gray B110 - Case Administration 1.60 135.00 216.00

Complete mailing of documents/paper service re: [DE 20388] & [20368].

2.90 479.50

B113 - Pleadings Review

03-01-2022 Carlos Alvarez B113 - Pleadings Review 0.80 315.00 252.00

Receive, review, and analyze case filings to prepare weekly status report to all attorneys.

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Date Professional Task Hours Rate Amount

B113 - Pleadings Review

03-02-2022 Carlos Alvarez B113 - Pleadings Review 0.30 315.00 94.50

Receive, review, and analyze case filings and continue to prepare weekly status report.

03-04-2022 Carlos Alvarez B113 - Pleadings Review 2.10 315.00 661.50

Receive, review, and analyze numerous case filings filed in the Main Case and adversary

proceedings and to weekly status report for March 1 to March 4; prepare folder of numerous

pleadings referenced in status report.

03-07-2022 Carlos Alvarez B113 - Pleadings Review 1.90 315.00 598.50

Receive, review, and analyze case numerous pleadings and other filings filed March 5, 6, and 7,

and finalize weekly status report for February 28 to March 4, and circulate for review by all

attorneys and calendaring of deadlines by paralegal.

03-09-2022 Carlos Alvarez B113 - Pleadings Review 0.90 315.00 283.50

Receive, review, and analyze case daily filings and prepare status report (0.6); confer with A.

Castaldi concerning objections to retention of Continental and check docket for objections to

application for retention of Continental PLLC (0.3)

03-11-2022 Carlos Alvarez B113 - Pleadings Review 1.90 315.00 598.50

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys.

03-14-2022 Carlos Alvarez B113 - Pleadings Review 2.10 315.00 661.50

Receive, review, and analyze case numerous pleadings and finalize weekly status report for March

5 to March 14, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

03-21-2022 Carlos Alvarez B113 - Pleadings Review 0.80 315.00 252.00

Receive, review, and analyze case numerous pleadings and other filings and finalize weekly status

report for March 15 to March 21, and circulate for review by all attorneys and calendaring of

deadlines by paralegal.

03-22-2022 Carlos Alvarez B113 - Pleadings Review 0.80 315.00 252.00

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys.

03-28-2022 Carlos Alvarez B113 - Pleadings Review 0.70 315.00 220.50

Receive, review, and analyze case numerous pleadings and other filings and finalize weekly status

report for March 22to March 28, and circulate for review by all attorneys and calendaring of

deadlines by paralegal.

03-29-2022 Carlos Alvarez B113 - Pleadings Review 0.60 315.00 189.00

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys.

03-30-2022 Carlos Alvarez B113 - Pleadings Review 0.80 315.00 252.00

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys.

03-31-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys.

14.10 4,441.50

B150 - Meetings of and Communications with Creditors

03-07-2022 John Arrastia B150 - Meetings of and Communications with 0.20 575.00 115.00

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Date Professional Task Hours Rate Amount

B150 - Meetings of and Communications with Creditors

Creditors

Confer with client regarding post confirmation litigation

03-09-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.40 575.00 230.00

Confer with Committee regarding case issues and pending litigation

03-22-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.30 575.00 172.50

Bi Weekly meeting with client regarding pending issues and strategy

0.90 517.50

B160 - Fee/Employment Application

03-01-2022 John Arrastia B160 - Fee/Employment Application 0.40 575.00 230.00

Review Joint Motion on Order Amending Procedures for Submitting Compensation [20245] (.4);

03-03-2022 John Arrastia B160 - Fee/Employment Application 0.20 575.00 115.00

Confer with Fee Examiner

03-07-2022 John Arrastia B160 - Fee/Employment Application 0.40 575.00 230.00

Finalize fee statements in conformity with Fee Examiner guidelines

03-10-2022 John Arrastia B160 - Fee/Employment Application 0.10 575.00 57.50

Review certificate of no objection to employment

03-21-2022 John Arrastia B160 - Fee/Employment Application 0.80 575.00 460.00

Prepare April budget

03-24-2022 John Arrastia B160 - Fee/Employment Application 0.10 575.00 57.50

Correspondence circulating Budget

2.00 1,150.00

B191 - General Litigation

03-02-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Review and analyze update of A. Bongartz concerning plan implementation and case status.

03-03-2022 Angelo Castaldi B191 - General Litigation 0.90 375.00 337.50

Detailed review and analysis of joint motion concerning interim compensation procedures and the

attending proposed (and redlined) order thereto.

03-03-2022 Carlos Alvarez B191 - General Litigation 0.60 315.00 189.00

Confer and strategize with team concerning proposed order on payment of professionals (0.2);

review and analysis of motion and proposed order on same (0.4).

03-03-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Review Opinion and Order denying Motion for Stay Pending Appeal [DE 20249] (.6); Review

correspondence from UCC regarding proposed notice of dismissal and transfer of avoidance action

(.2)

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Date Professional Task Hours Rate Amount

B191 - General Litigation

03-03-2022 Jesus Suarez B191 - General Litigation 0.90 500.00 450.00

Review plan confirmation issues with respect to actions where Continental is counsel of record and

provide comments concerning same.

03-04-2022 Jesus Suarez B191 - General Litigation 4.20 500.00 2,100.00

Review issues concerning confidentiality order compliance concerning files transferred by DGC to

UCC (.8); review files transmitted by DGC (3.4)

03-04-2022 Angelo Castaldi B191 - General Litigation 1.20 375.00 450.00

Conduct due diligence concerning implementation of plan and effective date of said plan.

03-07-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Attend to MIP List and proposed motion

03-07-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Strategize regarding post confirmation litigation issues

03-07-2022 Jesus Suarez B191 - General Litigation 0.50 500.00 250.00

Review issues and provide input to J. Arrastia concerning post-confirmation litigation issues

03-08-2022 Jesus Suarez B191 - General Litigation 1.70 500.00 850.00

Attention to status of confirmation order (.7), review issues raised by DGC in transferring materials

to trust. (1)

03-08-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review Response to FOMB Motion for Order Approving List of MIP

03-10-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Draft certificate of no objection and review case management procedures in conjunction therewith.

03-10-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Research case file regarding counsel for Underwriter Defendants from case files (no notices of

appearance were filed)(.4)

03-10-2022 Jesus Suarez B191 - General Litigation 1.20 500.00 600.00

Attention to plan confirmation issues issues with respect to actions where Continental is counsel of

record, monitor filings for consistency with agreements and litigation plan, and provide comments

concerning same.

03-11-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Prepare, revise, and finalize correspondence to counsel for Underwriter Defendants (.4)

03-11-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review Motion regarding GO Bonds [DE 20304])(.2)

03-14-2022 Jesus Suarez B191 - General Litigation 0.70 500.00 350.00

 (.3) and review materials on

sharesite (.4) re underwriter litigation.

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Date Professional Task Hours Rate Amount

B191 - General Litigation

03-14-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review order Regarding Procedures (.1)

03-15-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Prepare draft informative motion for Omnibus

03-15-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Review of court procedures concerning omnibus hearings and prepare informative motion.

03-15-2022 Angelo Castaldi B191 - General Litigation 1.40 375.00 525.00

Review and analyze plan and confirmation order concerning provisions concerning establishment of

effective date, and, provisions governing the creation of the avoidance actions trust, and further

review of claims subject to transfer to said trust.

03-16-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Review of Commonwealth docket and revise proposed order on Continental employment

application and motion to inform concerning the same.

03-18-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Correspondence with SCC regarding dismissals of clawback actions

03-22-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Review Order Regarding MIP List (.2); Review FOMB Status Report (.2)' Review AAFAF Status

Report (.2)

03-23-2022 Angelo Castaldi B191 - General Litigation 1.30 375.00 487.50

Attend omnibus hearing before the Honorable Judge Swain.

03-26-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review Informative Motion of Matters Resolved by the Amended Plan

03-28-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Review various voluntary dismissals.

03-28-2022 Angelo Castaldi B191 - General Litigation 0.60 375.00 225.00

Begin review and analysis of 112-page informative motion concerning matters resolved by plan (DE

20445).

03-28-2022 Jesus Suarez B191 - General Litigation 1.20 500.00 600.00

Review court filings concerning dismissed adversaries and implementation of plan for consistency

with plan and agreement (.8); review AAFAF status report concerning implementation of plan for

consistency with plan and agreement as it relates to adversary proceedings where Continental is

counsel of records (.4)

03-29-2022 Angelo Castaldi B191 - General Litigation 0.70 375.00 262.50

Review and analysis of 112-page informative motion concerning matters resolved by plan (DE

20445).

03-31-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Review and receive Order on urgent motion of Special Claims Committee of Financial Oversight

and Management Board for Puerto Rico and Official Committee of Unsecured Creditors in

Compliance with Litigation Case Management and Settlement Approval Procedures Order, and

notices of voluntary dismissal filed by the SCC in the main PROMESA case

03-31-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Preliminary review of Motion of Financial Oversight and Management Board for Puerto Rico

Requesting Order Approving Proposed List of Material Interested Parties Pursuant to the Puerto

Rico Recovery Accuracy in Disclosures Act

22.80 10,634.00

B260 - Meeting with FOMB and SCC

03-08-2022 John Arrastia B260 - Meeting with FOMB and SCC 0.10 575.00 57.50

Confer with SCC regarding post confirmation litigation strategy

03-08-2022 John Arrastia B260 - Meeting with FOMB and SCC 575.00 No Charge

Confer with SCC regarding obtaining stay of underwriter litigation post-confirmation (.2)

0.10 57.50

Total 17,280.00

Time Summary

Task Hours Amount

B110 - Case Administration 2.90 479.50

B113 - Pleadings Review 14.10 4,441.50

B150 - Meetings of and Communications with Creditors 0.90 517.50

B160 - Fee/Employment Application 2.00 1,150.00

B191 - General Litigation 22.80 10,634.00

B260 - Meeting with FOMB and SCC 0.10 57.50

Total Fees 17,280.00

Expenses

Expense Description Amount

E108 - Postage For service of documents by U.S. Mail 63.96

Total Expenses 63.96

Total for this Invoice 17,343.96

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PROMESA / UCC

April 14, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 167

Invoice Period: 03-01-2022 - 03-31-2022

REMITTANCE COPY

RE: Commonwealth of Puerto Rico

Fees 17,280.00

Expenses 63.96

Total for this Invoice 17,343.96

Previous Balance 53,351.50

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 56,171.96 56,171.96

ERS 172.50 172.50

HTA 977.50 977.50

PREPA 13,373.50 13,373.50

Total Amount to Pay 70,695.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

Balance 70,695.46

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

April 14, 2022

PROMESA / UCC

Invoice Number: 168

Invoice Period: 03-01-2022 - 03-31-2022

Payment Terms: Upon Receipt

RE: ERS

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

03-15-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review Fourth Amended Plan Supplement as it relates to litigation claims

0.30 172.50

Total 172.50

Time Summary

Task Hours Amount

B191 - General Litigation 0.30 172.50

Total Fees 172.50

Total for this Invoice 172.50

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PROMESA / UCC

April 14, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 168

Invoice Period: 03-01-2022 - 03-31-2022

REMITTANCE COPY

RE: ERS

Fees 172.50

Total for this Invoice 172.50

Previous Balance 70,522.96

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 56,171.96 56,171.96

ERS 172.50 172.50

HTA 977.50 977.50

PREPA 13,373.50 13,373.50

Total Amount to Pay 70,695.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

Balance 70,695.46

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

April 14, 2022

PROMESA / UCC

Invoice Number: 169

Invoice Period: 03-01-2022 - 03-31-2022

Payment Terms: Upon Receipt

RE: HTA

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

03-14-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review Supplemental Reply [DE 20331](.1)

03-16-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review Amended and Restated Stipulation and Agreed Order on Disputed Funds [DE 20366] (.1)

0.20 115.00

Total 115.00

Time Summary

Task Hours Amount

B191 - General Litigation 0.20 115.00

Total Fees 115.00

Total for this Invoice 115.00

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PROMESA / UCC

April 14, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 169

Invoice Period: 03-01-2022 - 03-31-2022

REMITTANCE COPY

RE: HTA

Fees 115.00

Total for this Invoice 115.00

Previous Balance 70,580.46

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 56,171.96 56,171.96

ERS 172.50 172.50

HTA 977.50 977.50

PREPA 13,373.50 13,373.50

Total Amount to Pay 70,695.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

Balance 70,695.46

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

April 14, 2022

PROMESA / UCC

Invoice Number: 170

Invoice Period: 03-01-2022 - 03-31-2022

Payment Terms: Upon Receipt

RE: PREPA

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

03-01-2022 John Arrastia B191 - General Litigation 0.70 575.00 402.50

Review Ad Hoc Group to Appoint Mediator and impose Deadlines [DE 20226] (.3); Review National

Public Reply in Support of Mediation [DE 20227] (.1); Review Response of Assured to Motion to

Appoint Mediator and Impose Deadlines (.1); Attend to research regarding legislative and

executive aspects of PREPA restructuring (.2)

03-02-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Review and analyze Reply in support of the Urgent Motion of the Ad Hoc Group of PREPA

Bondholders Pursuant to Section 312 of PROMESA and Section 105 of the Bankruptcy Code to

Appoint a Mediator and Impose Deadlines for a PREPA Plan of Adjustment.

03-07-2022 Jesus Suarez B191 - General Litigation 2.10 500.00 1,050.00

Research and conduct additional diligence concerning Inspectorate (1.3) and attention to request

for review of invoices and limit to claims (.8).

03-08-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review Order Denying Motion to Appoint Mediator for PREPA Plan of Adjustment

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Date Professional Task Hours Rate Amount

B191 - General Litigation

03-15-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review legal research regarding pending claims

03-16-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review Order Amending Scope of March 18, 2022 Status Report [DE 20357] (.1)

03-18-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review Status Report Regarding mediation (.1); Review court order regarding mediation (.1)

03-18-2022 Jesus Suarez B191 - General Litigation 0.60 500.00 300.00

Review additional issues concerning PREPA 9019, mediation and plan process as it relates to Fuel

Oil litigation.

03-25-2022 Jesus Suarez B191 - General Litigation 1.20 500.00 600.00

Additional research concerning issues raised by Inspectorate with respect to amended complaint (.

7); and request from dismissal of certain counts, review Count 18 concerning same (.5).

03-28-2022 Jesus Suarez B191 - General Litigation 0.70 500.00 350.00

Additional research concerning Count 18 of the complaint, including analysis of elements of claims

and development of potential amendment.

03-29-2022 Jesus Suarez B191 - General Litigation 1.80 500.00 900.00

Factual development of issues advanced by Inspectorate concerning concerning testing of fuel oil,

methods and invoices attached to Complaint..

03-31-2022 Jesus Suarez B191 - General Litigation 1.40 500.00 700.00

Prepare for and participate in conference with Brown Rudnick concerning Inspectorate meet and

confer in connection with motion to dismiss in Fuel Oil Litigation.

03-31-2022 Angelo Castaldi B191 - General Litigation 1.20 375.00 450.00

Prepare for and participate in conference call with opposing counsel concerning pending issues in

19-280

10.80 5,345.00

B320 - Plan and Disclosure Statement (including Business Plan)

03-08-2022 Jesus Suarez B320 - Plan and Disclosure Statement (including 

Business Plan)

0.70 500.00 350.00

Review impact of termination of RSA on litigation matters (.4) and research issues related to same (.

3)

03-08-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

0.30 575.00 172.50

Review materials relating to PR Government's termination of PREPA RSA

1.00 522.50

Total 5,867.50

Time Summary

Task Hours Amount

B191 - General Litigation 10.80 5,345.00

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Task Hours Amount

B320 - Plan and Disclosure Statement (including Business Plan) 1.00 522.50

Total Fees 5,867.50

Total for this Invoice 5,867.50

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PROMESA / UCC

April 14, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 170

Invoice Period: 03-01-2022 - 03-31-2022

REMITTANCE COPY

RE: PREPA

Fees 5,867.50

Total for this Invoice 5,867.50

Previous Balance 64,827.96

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 56,171.96 56,171.96

ERS 172.50 172.50

HTA 977.50 977.50

PREPA 13,373.50 13,373.50

Total Amount to Pay 70,695.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

Balance 70,695.46

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

May 09, 2022

PROMESA / UCC

Invoice Number: 217

Invoice Period: 04-01-2022 - 04-30-2022

Payment Terms: Upon Receipt

RE: HTA

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

04-22-2022 Angelo Castaldi B191 - General Litigation 0.80 375.00 300.00

Review of draft HTA plan.

0.80 300.00

B320 - Plan and Disclosure Statement (including Business Plan)

04-20-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

0.40 575.00 230.00

Review draft Title III Plan update

04-23-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

1.20 575.00 690.00

Review draft Title III Plan

1.60 920.00

Total 1,220.00

Time Summary

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Task Hours Amount

B191 - General Litigation 0.80 300.00

B320 - Plan and Disclosure Statement (including Business Plan) 1.60 920.00

Total Fees 1,220.00

Total for this Invoice 1,220.00

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PROMESA / UCC

May 09, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 217

Invoice Period: 04-01-2022 - 04-30-2022

REMITTANCE COPY

RE: HTA

Fees 1,220.00

Total for this Invoice 1,220.00

Previous Balance 116,948.96

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 68,177.96 68,177.96

ERS 172.50 172.50

HTA 2,197.50 2,197.50

PREPA 47,621.00 47,621.00

Total Amount to Pay 118,168.96

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

Balance 118,168.96

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

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Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

May 09, 2022

PROMESA / UCC

Invoice Number: 218

Invoice Period: 04-01-2022 - 04-30-2022

Payment Terms: Upon Receipt

RE: PREPA

Time Details

Date Professional Task Hours Rate Amount

B110 - Case Administration

04-19-2022 John Arrastia B110 - Case Administration 0.80 575.00 460.00

Confer with A. Bongartz regarding PRADDA and MIP (.1); Review receipt of updated MIP list (.4);

Further preparation of MIP analysis to comport with Court Order (.3)

0.80 460.00

B150 - Meetings of and Communications with Creditors

04-13-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.20 575.00 115.00

Email to Committee regarding tolling issues

04-19-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.20 575.00 115.00

Email to Committee regarding proposed filings

04-19-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.20 575.00 115.00

Meeting with Committee regarding pending items

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Date Professional Task Hours Rate Amount

B150 - Meetings of and Communications with Creditors

04-20-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.20 575.00 115.00

Confer with Committee regarding revision to complaint

0.80 460.00

B191 - General Litigation

04-01-2022 Jesus Suarez B191 - General Litigation 1.30 500.00 650.00

Review and prepare for conference call with inspectorate concerning limitation of claims, and

potential amendment to complaint.

04-06-2022 Jesus Suarez B191 - General Litigation 1.40 500.00 700.00

B191 - General Litigation - Review issues concerning transfer of adversary proceedings from

PREPA estate to avoidance action trust and research potential remedies.

04-07-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

Review of prior orders in 19-388 concerning Vitol counterclaims and prepare for / attend telephone

conference with SCC counsel concerning the same.

04-07-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review draft mediation statement (.2); Confer with L. Despins (.1)

04-07-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review mediation update

04-07-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Confer with SCC regarding Vitol Status Report (.1); Review court order (.1)

04-07-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Confer with L. Despins

04-07-2022 Jesus Suarez B191 - General Litigation 1.50 500.00 750.00

Review issues concerning VITOL counterclaim, briefing schedule, and conference call with Brown

Rudnick (.8). Attention to upcoming issues regarding status report (.4) and motion to dismiss

briefing (.3)

04-08-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Review correspondence from Vitol defendants (.1); Review order appointing mediation team (.1);

Review draft status report regarding Vitol (.2)

04-08-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review order appointing mediation team (.1); Review draft status report (.1)

04-11-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review draft status report (.2); Confer with J. Suarez and A. Castaldi (.1)

04-11-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Review revisions to status report draft (.1); Confer with Vitol defendants (.1); Confer with SCC

counsel on draft (.1)

1.10 550.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

04-11-2022 Jesus Suarez B191 - General Litigation 500.00

Provide comments to VITOL status report (.5); confer with SCC (.3) and VITOL (.5); 

(.7)

04-13-2022 Jesus Suarez B191 - General Litigation 0.90 500.00 450.00

B191 - General Litigation- (.4); review

issues regarding status report and VITOL counter-claim (.5)

04-13-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Attend to tolling extension agreements and related communications with counsel for the SCC

04-13-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Confer with SCC regarding tolling issues

04-14-2022 Angelo Castaldi B191 - General Litigation 3.80 375.00 1,425.00

Receive and review service orders that we recently received from PREPA

04-14-2022 Jesus Suarez B191 - General Litigation 1.70 500.00 850.00

Review correspondence regarding PREPA Bondholders and mediation with respect to anticipated

litigation issues in Fuel Oil Case (.8); review materials concerning litigation claims and production of

service orders from PREPA (.9)

04-15-2022 Jesus Suarez B191 - General Litigation 0.80 500.00 400.00

.

04-19-2022 Angelo Castaldi B191 - General Litigation 2.80 375.00 1,050.00

Attend to communications from SCC counsel concerning, and attend to review of, recentlyproduced PREPA records.

04-19-2022 John Arrastia B191 - General Litigation 1.90 575.00 1,092.50

Review service orders provided by SCC (.9); Review correspondence from SCC (.1); Strategize

and legal research regarding resolution (.6); Analyze (.3)

04-20-2022 John Arrastia B191 - General Litigation 0.80 575.00 460.00

Confer with SCC on Inspectorate invoices (.3); Strategize (.3); Confer with opposing counsel (.2)

04-20-2022 Jesus Suarez B191 - General Litigation 2.20 500.00 1,100.00

 (.8); review matters

concerning amendment of adversary complaint (.9)

04-20-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Telephone conference with counsel for the Special Claims Committee.

04-20-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

.

04-20-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Conference call with counsel for Inspectorate.

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Date Professional Task Hours Rate Amount

B191 - General Litigation

04-20-2022 Jesus Suarez B191 - General Litigation 0.40 500.00 200.00

Conference with SCC counsel regarding avoidance actions.

04-20-2022 Jesus Suarez B191 - General Litigation 0.60 500.00 300.00

Prepare for and participate in conference call with counsel for Inspectorate.

04-21-2022 Jesus Suarez B191 - General Litigation 1.30 500.00 650.00

Research and analysis concerning Puerto Rico constitutional issues regarding contract registration

requirements in connection with requests from Inspectorate, others for dismissal or limitation of

claims.

04-21-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Review of recently entered default judgments / memorandum opinions concerning LPRA and

Puerto Rico law analyses.

04-21-2022 Angelo Castaldi B191 - General Litigation 1.70 375.00 637.50

Review prior 12(b) briefing of Vitol defendants in Case No. 19-388.

04-21-2022 Angelo Castaldi B191 - General Litigation 2.80 375.00 1,050.00

Review of Puerto Rico case law and constitutional / statutory provisions concerning contract

registration requirements and associated remedies

04-21-2022 John Arrastia B191 - General Litigation 0.90 575.00 517.50

Review draft motion (.3); Revise draft motion (.6)

04-22-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Confer with opposing counsel regarding motion (.1); Finalize motion and order (.2)

04-22-2022 Jesus Suarez B191 - General Litigation 3.30 500.00 1,650.00

 (.8); begin review of matters anticipated to be raised in

briefings on motions to dismiss and attention to briefing schedule (1.9)

04-22-2022 Jesus Suarez B191 - General Litigation 0.40 500.00 200.00

04-22-2022 John Arrastia B191 - General Litigation 1.40 575.00 805.00

Continued attention to review of PRADDA and MIP lists in conformity with Court Order

04-25-2022 John Arrastia B191 - General Litigation 1.60 575.00 920.00

Continued attention to review of PRADDA and MIP lists in conformity with Court Order

04-25-2022 Jesus Suarez B191 - General Litigation 2.10 500.00 1,050.00

Attention to requests from briefing parties for extension of time to file motions (.3); review issues

anticipated in motions to dismiss (.4); review filings and begin outlining process for review and

identification of issues (1.4)

04-25-2022 Angelo Castaldi B191 - General Litigation 3.60 375.00 1,350.00

Conduct legal research concerning principles of Puerto Rico law relating to illegal or improper

consideration and corresponding code provisions

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Date Professional Task Hours Rate Amount

B191 - General Litigation

04-26-2022 Jesus Suarez B191 - General Litigation 6.50 500.00 3,250.00

Review ALTOL disclosure statement (.2); Review VITOL 12b6 Motion (1.3); Altol answer to SAAC

and consider need to strike certain defenses (.9); review ALTOL motion for extension of time to file

12b6 motion notwithstanding answer and research related to same (.3); review notice of filing and

request for judicial notice of papers filed by several adversary defendants and review case law cited

related to same (.7); review Defendants 12(b)(6) in omnibus filed by various adversary defendants

(1.8); review VITOL motion to dismiss complaint (1.3)

04-26-2022 Angelo Castaldi B191 - General Litigation 2.40 375.00 900.00

Begin review of Rule 12 motions filed on Apr. 25 and authorities cited therein

04-26-2022 John Arrastia B191 - General Litigation 3.80 575.00 2,185.00

Review Answer, Joinder, Motion for Extension, and various Motions to Dismiss filed in 19-280 (3.8);

04-26-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Multiple communications with opposing counsel regarding issues in filing and agreement to provide

enlargement: Further communications as to filing

04-27-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review court order (.1); Communicate with Alchem counsel regarding meet and confer obligations (.

1)

04-27-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Confirm all tolling agreements are executed

04-27-2022 John Arrastia B191 - General Litigation 1.40 575.00 805.00

Attention to review of PRADDA and MIP lists in conformity with Court Order

04-27-2022 Jesus Suarez B191 - General Litigation 4.10 500.00 2,050.00

Review standard for striking defenses in D.PR/First Circuit (.6); review motions for extension of time

to file answer (.2); review motion for joinder filed by ALTOL and consider standard regarding same (.

3); research standard for blanket joinder (.5); attention to common interest between defense groups

and potential requirements for disclosure concerning same (.4); begin outlining response to

Defense Group MTD (2.1)

04-28-2022 John Arrastia B191 - General Litigation 0.80 575.00 460.00

Continued attention to review of PRADDA and MIP lists in conformity with Court Order

04-28-2022 John Arrastia B191 - General Litigation 0.30 575.00 172.50

Strategize and legal research in anticipation of meet and confer (.2); Meet and confer with Alchem

counsel (.2)

04-29-2022 John Arrastia B191 - General Litigation 1.20 575.00 690.00

Further analysis and review of Trafigura motion to dismiss

04-29-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Legal research and analysis regarding pleading standard for affirmative defenses in anticipation of

motion to strike (.6)

2.10 1,207.50

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Date Professional Task Hours Rate Amount

B191 - General Litigation

04-29-2022 John Arrastia B191 - General Litigation 575.00

Additional review and analysis of Inspectorate motion to dismiss

68.50 33,327.50

Total 34,247.50

Time Summary

Task Hours Amount

B110 - Case Administration 0.80 460.00

B150 - Meetings of and Communications with Creditors 0.80 460.00

B191 - General Litigation 68.50 33,327.50

Total Fees 34,247.50

Total for this Invoice 34,247.50

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PROMESA / UCC

May 09, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 218

Invoice Period: 04-01-2022 - 04-30-2022

REMITTANCE COPY

RE: PREPA

Fees 34,247.50

Total for this Invoice 34,247.50

Previous Balance 83,921.46

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 68,177.96 68,177.96

ERS 172.50 172.50

HTA 2,197.50 2,197.50

PREPA 47,621.00 47,621.00

Total Amount to Pay 118,168.96

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

Balance 118,168.96

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

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Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

May 10, 2022

PROMESA / UCC

Invoice Number: 220

Invoice Period: 04-01-2022 - 04-30-2022

Payment Terms: Upon Receipt

RE: Commonwealth of Puerto Rico

Time Details

Date Professional Task Hours Rate Amount

B100 - Administration

04-12-2022 John Arrastia B100 - Administration 0.80 575.00 460.00

Review PRADDA Order

0.80 460.00

B113 - Pleadings Review

04-01-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for March 29 to

March 31, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

04-04-2022 Carlos Alvarez B113 - Pleadings Review 1.80 315.00 567.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for April 5 to

March 14, and circulate for review by all attorneys (1.4); prepare status update, confer from team

on same (0.4).

04-05-2022 Carlos Alvarez B113 - Pleadings Review 0.30 315.00 94.50

Receive, review, and analyze numerous filings to prepare weekly status report to all attorneys (0.3).

04-07-2022 Carlos Alvarez B113 - Pleadings Review 0.30 315.00 94.50

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Date Professional Task Hours Rate Amount

B113 - Pleadings Review

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys

(0.3).

04-08-2022 Carlos Alvarez B113 - Pleadings Review 0.90 315.00 283.50

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys.

04-11-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for April 1 to

April 11, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

04-13-2022 Carlos Alvarez B113 - Pleadings Review 0.70 315.00 220.50

Receive, review, and analyze numerous filings to prepare weekly status report to all attorneys.

04-14-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze numerous filings to prepare weekly status report to all attorneys (0.4).

04-15-2022 Carlos Alvarez B113 - Pleadings Review 1.60 315.00 504.00

Receive, review, and analyze numerous filings to prepare weekly status report to all attorneys (1.6).

04-18-2022 Carlos Alvarez B113 - Pleadings Review 0.20 315.00 63.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for April 12 to

April 17, and circulate for review by all attorneys and calendaring of deadlines by paralegal (0.2).

04-19-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze numerous filings to prepare weekly status report to all attorneys (0.4).

04-21-2022 Carlos Alvarez B113 - Pleadings Review 0.60 315.00 189.00

Receive, review, and analyze case numerous filings to prepare weekly status report to all attorneys

(0.6).

04-22-2022 Carlos Alvarez B113 - Pleadings Review 1.60 315.00 504.00

Receive, review, and analyze numerous pleadings for weekly status report to all attorneys.

04-25-2022 Carlos Alvarez B113 - Pleadings Review 1.70 315.00 535.50

Receive, review, and analyze numerous pleadings and finalize weekly status report for April 18 to

April 24, and circulate for review by all attorneys and calendaring of deadlines by paralegal (1.7)

04-27-2022 Carlos Alvarez B113 - Pleadings Review 2.20 315.00 693.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for April 25 to

April 27, and circulate for review by all attorneys and calendaring of deadlines by paralegal (2.2).

04-28-2022 Carlos Alvarez B113 - Pleadings Review 1.10 315.00 346.50

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

04-29-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

15.00 4,725.00

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Date Professional Task Hours Rate Amount

B150 - Meetings of and Communications with Creditors

04-19-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.20 575.00 115.00

Confer with Committee regarding substitution of parties

0.20 115.00

B160 - Fee/Employment Application

04-08-2022 Heather Gray B160 - Fee/Employment Application 1.10 135.00 148.50

Prepare and disseminate Continental PLLC's February 2022 Monthly Fee Objection Statement.

04-12-2022 John Arrastia B160 - Fee/Employment Application 0.10 575.00 57.50

Finalize Fee Objection Letter

04-12-2022 John Arrastia B160 - Fee/Employment Application 0.70 575.00 402.50

Prepare budget

04-14-2022 John Arrastia B160 - Fee/Employment Application 0.70 575.00 402.50

Revise and finalize fee statement in conformity with Fee Examiner Guidelines

04-15-2022 John Arrastia B160 - Fee/Employment Application 0.80 575.00 460.00

Prepare budget for professional fees.

3.40 1,471.00

B191 - General Litigation

04-03-2022 Jesus Suarez B191 - General Litigation 1.20 500.00 600.00

Conduct due diligence concerning implementation of plan and effective date of said plan.

04-03-2022 Angelo Castaldi B191 - General Litigation 0.80 375.00 300.00

Research issues concerning implementation of plan and provide direction concerning next steps.

04-05-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Review of internal memorandum circulated by A. Bongartz and associated materials.

04-05-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review email memorandum regarding claims reconciliation

04-06-2022 Heather Gray B191 - General Litigation 2.40 135.00 324.00

Begin drafting of 186 Notices of Appearance in the adversary proceedings for J. Arrastia, J. Suarez

and A. Castaldi, including party research on Prime Clerk.

04-07-2022 Heather Gray B191 - General Litigation 1.20 135.00 162.00

Continued preparation of Notices of Appearance in the adversary proceedings.

04-08-2022 Angelo Castaldi B191 - General Litigation 0.60 375.00 225.00

Review various Orders and corresponding filings concerning PRADDA requirements.

04-12-2022 Angelo Castaldi B191 - General Litigation 1.40 375.00 525.00

Review of appellate court proceedings and material filings concerning appeal of the Court's

confirmation order.

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Date Professional Task Hours Rate Amount

B191 - General Litigation

04-12-2022 Angelo Castaldi B191 - General Litigation 0.60 375.00 225.00

Review of filings concerning PRADDA disclosures.

04-12-2022 Heather Gray B191 - General Litigation 0.70 135.00 94.50

Finalize and file Motion to Substitute Avoidance Action Trustee as Plaintiff [DE 24]

04-12-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review order on mediators

04-13-2022 Heather Gray B191 - General Litigation 1.10 135.00 148.50

Additional revisions to the Notices of Appearance to be filed in adversary proceedings.

04-14-2022 Heather Gray B191 - General Litigation 3.10 135.00 418.50

Finalize and file all Notices of Appearance in adversary proceedings for J. Arrastia, J. Suarez and

A. Castaldi.

04-15-2022 Heather Gray B191 - General Litigation 0.20 135.00 27.00

Prepare and mail paper service of DE 24 in Adv. Proc. 19-00276.

04-18-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Appear at Committee conference call concerning HTA plan negotiations.

04-20-2022 Heather Gray B191 - General Litigation 2.30 135.00 310.50

Preparation of Response to Order to Show Cause in various adversary proceedings and prepare

for filing.

04-22-2022 Angelo Castaldi B191 - General Litigation 0.80 375.00 300.00

Review of finalized list of materially interested persons.

04-25-2022 Angelo Castaldi B191 - General Litigation 1.30 375.00 487.50

Analyze confirmation order and subsequent filings concerning litigations resolved by Plan and said

order, and review and provide comments to draft notice of dismissal concerning some of said

litigations

04-25-2022 John Arrastia B191 - General Litigation 1.20 575.00 690.00

Review draft notice of dismissal format (.2); Strategize (.3); Review case file (.3); Confer with A.

Castaldi (.2); Confer with A. Bongartz (.2)

04-27-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review notice of procedures

19.80 5,235.00

Total 12,006.00

Time Summary

Task Hours Amount

B100 - Administration 0.80 460.00

B113 - Pleadings Review 15.00 4,725.00

B150 - Meetings of and Communications with Creditors 0.20 115.00

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Task Hours Amount

B160 - Fee/Employment Application 3.40 1,471.00

B191 - General Litigation 19.80 5,235.00

Total Fees 12,006.00

Total for this Invoice 12,006.00

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PROMESA / UCC

May 10, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 220

Invoice Period: 04-01-2022 - 04-30-2022

REMITTANCE COPY

RE: Commonwealth of Puerto Rico

Fees 12,006.00

Total for this Invoice 12,006.00

Previous Balance 106,162.96

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 68,177.96 68,177.96

ERS 172.50 172.50

HTA 2,197.50 2,197.50

PREPA 47,621.00 47,621.00

Total Amount to Pay 118,168.96

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

Balance 118,168.96

WIRE TRANSFER INFORMATION

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: CONTINENTAL PLLC

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Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

June 13, 2022

PROMESA / UCC

Invoice Number: 246

Invoice Period: 05-01-2022 - 05-31-2022

Payment Terms: Upon Receipt

RE: Commonwealth of Puerto Rico

Time Details

Date Professional Task Hours Rate Amount

B110 - Case Administration

05-02-2022 Heather Gray B110 - Case Administration 0.30 135.00 40.50

Review of daily litigation summary prepared by C. Alvarez, including calendaring, and updating

electronic case file.

05-06-2022 Heather Gray B110 - Case Administration 0.30 135.00 40.50

Review of daily litigation summary prepared by C. Alvarez, including calendaring, and updating

electronic case file.

05-11-2022 Heather Gray B110 - Case Administration 0.30 135.00 40.50

Review of daily litigation summary prepared by C. Alvarez, including calendaring, and updating

electronic case file.

05-16-2022 Heather Gray B110 - Case Administration 0.30 135.00 40.50

Review of daily litigation summary prepared by C. Alvarez, including calendaring, and updating

electronic case file.

05-31-2022 Heather Gray B110 - Case Administration 0.30 135.00 40.50

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Date Professional Task Hours Rate Amount

B110 - Case Administration

Review of daily litigation summary prepared by C. Alvarez, including calendaring, and updating

electronic case file.

1.50 202.50

B113 - Pleadings Review

05-02-2022 Carlos Alvarez B113 - Pleadings Review 1.30 315.00 409.50

Receive, review, and analyze numerous pleadings and finalize weekly status report for April 28 to

May 2, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

05-03-2022 Carlos Alvarez B113 - Pleadings Review 0.80 315.00 252.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-06-2022 Carlos Alvarez B113 - Pleadings Review 2.60 315.00 819.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for May 3 to

May 6, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

05-09-2022 Carlos Alvarez B113 - Pleadings Review 1.60 315.00 504.00

Confer with team concerning calendaring on omnibus hearing and relate deadlines; organize and

calendar same; (0.4)

receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys. (1.2)

05-10-2022 Carlos Alvarez B113 - Pleadings Review 1.80 315.00 567.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-11-2022 Carlos Alvarez B113 - Pleadings Review 1.30 315.00 409.50

Receive, review, and analyze numerous pleadings and finalize weekly status report for May 7 to

May 11, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

05-12-2022 Carlos Alvarez B113 - Pleadings Review 1.70 315.00 535.50

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-13-2022 Carlos Alvarez B113 - Pleadings Review 0.90 315.00 283.50

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-16-2022 Carlos Alvarez B113 - Pleadings Review 2.10 315.00 661.50

Receive, review, and analyze numerous pleadings and finalize weekly status report for May 12 to

May 15, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

05-17-2022 Carlos Alvarez B113 - Pleadings Review 0.60 315.00 189.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-18-2022 Carlos Alvarez B113 - Pleadings Review 0.80 315.00 252.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

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Date Professional Task Hours Rate Amount

B113 - Pleadings Review

05-19-2022 Carlos Alvarez B113 - Pleadings Review 2.90 315.00 913.50

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-20-2022 Carlos Alvarez B113 - Pleadings Review 2.20 315.00 693.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-23-2022 Carlos Alvarez B113 - Pleadings Review 1.60 315.00 504.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for May 16 to

May 22, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

05-24-2022 Carlos Alvarez B113 - Pleadings Review 0.30 315.00 94.50

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-25-2022 Carlos Alvarez B113 - Pleadings Review 0.40 315.00 126.00

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-30-2022 Carlos Alvarez B113 - Pleadings Review 2.90 315.00 913.50

Receive, review, and analyze numerous pleadings for weekly status report to be reviewed by all

attorneys.

05-31-2022 Carlos Alvarez B113 - Pleadings Review 0.60 315.00 189.00

Receive, review, and analyze numerous pleadings and finalize weekly status report for May 23 to

May 31, and circulate for review by all attorneys and calendaring of deadlines by paralegal.

26.40 8,316.00

B150 - Meetings of and Communications with Creditors

05-04-2022 Jesus Suarez B150 - Meetings of and Communications with 

Creditors

1.30 500.00 650.00

Prepare for and participate in committee call.

05-18-2022 John Arrastia B150 - Meetings of and Communications with 

Creditors

0.30 575.00 172.50

Attend bi-weekly committee meeting and present on issues

1.60 822.50

B160 - Fee/Employment Application

05-03-2022 Heather Gray B160 - Fee/Employment Application 0.60 135.00 81.00

Prepare for J. Arrastia's review, the draft of Continental PLLC's March 2002 monthly fee statement,

including preparation of invoices in various matters, and calculation of discounted fees.

05-03-2022 John Arrastia B160 - Fee/Employment Application 0.90 575.00 517.50

Communicate with Hacienda regarding registration (.4); Confer with AAFAF regarding supplier id (.

2); Review and analyze post PRRADA fee submission proceedures (.3)

05-04-2022 Heather Gray B160 - Fee/Employment Application 0.30 135.00 40.50

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Date Professional Task Hours Rate Amount

B160 - Fee/Employment Application

Finalize and disseminate Continental PLLC's March 2002 monthly fee statement, including final

invoices in various matters, and calculation of discounted fees.

05-05-2022 John Arrastia B160 - Fee/Employment Application 0.20 575.00 115.00

Confer with counsel for La Hacienda regarding registration.

05-06-2022 Angelo Castaldi B160 - Fee/Employment Application 0.70 375.00 262.50

Review PRRADA requirements and corresponding MIP list.

05-09-2022 Angelo Castaldi B160 - Fee/Employment Application 0.80 375.00 300.00

Review of PRRADA requirements, associated Order of the Court, and disclosures by certain partiesin-interest.

05-10-2022 John Arrastia B160 - Fee/Employment Application 1.60 575.00 920.00

Work on draft declaration regarding PRRADA and MIPs.

05-11-2022 Heather Gray B160 - Fee/Employment Application 0.60 135.00 81.00

Prepare for J. Arrastia's review, the draft of Continental PLLC's April 2002 monthly fee statement,

including preparation of invoices in various matters, and calculation of discounted fees.

05-11-2022 John Arrastia B160 - Fee/Employment Application 0.70 575.00 402.50

Continued preparation of draft declaration regarding PRRADA and MIPs.

05-11-2022 Jesus Suarez B160 - Fee/Employment Application 0.90 500.00 450.00

Revise MIP/PRRADA disclosures.

05-12-2022 Heather Gray B160 - Fee/Employment Application 0.30 135.00 40.50

Finalize and disseminate Continental PLLC's April 2002 monthly fee statement, including final

invoices in various matters, and calculation of discounted fees.

05-13-2022 Jesus Suarez B160 - Fee/Employment Application 1.60 500.00 800.00

Review MIP list and PRADDA Disclosures and provide comments.

05-16-2022 Heather Gray B160 - Fee/Employment Application 1.10 135.00 148.50

Prepare draft of Continental PLLC's March 2022 Monthly Fee Objection Statement, including

summary of amounts due, for J. Arrastia's review.

05-16-2022 John Arrastia B160 - Fee/Employment Application 1.10 575.00 632.50

Finalize fee statements and circulate (.4); Prepare budget for Committee (.7)

05-23-2022 Heather Gray B160 - Fee/Employment Application 0.60 135.00 81.00

Confer with J. Arrastia re: Continental PLLC's March 2022 Monthly Fee Objection Statement,

including summary of amounts due, and disseminate for payment.

05-26-2022 Heather Gray B160 - Fee/Employment Application 1.10 135.00 148.50

Prepare draft of Continental PLLC's April 2022 Monthly Fee Objection Statement, including

summary of amounts due, for J. Arrastia's review.

13.10 5,021.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

05-03-2022 Jesus Suarez B191 - General Litigation 3.40 500.00 1,700.00

Continued work on response to motion to dismiss omnibus (2.3) and specific attention to VITOL

issues (1.1)

05-04-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review draft stipulation of dismissal

05-05-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review notice of dismissal (.2); Strategize with A. Castaldi (.2)

05-05-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review procedures order

05-05-2022 John Arrastia B191 - General Litigation 2.10 575.00 1,207.50

Review of additional MIP list in conformity with PRADDA obligations

05-06-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review email to dismissal parties in various adversary proceedings

05-06-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review email to dismissal parties in various adversary proceedings

05-13-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Review of update concerning Act 80 negotiations and corresponding letter concerning same.

05-16-2022 Angelo Castaldi B191 - General Litigation 3.10 375.00 1,162.50

Draft objection to urgent motion filed by Citi.

05-16-2022 John Arrastia B191 - General Litigation 3.10 575.00 1,782.50

Review docket regarding Citi disclosures (.1); Confer with client (.2); Strategize (.4); Research case

file (.7); Legal research and analysis (.6); Strategize with A. Castaldi and J.Suarez (.3) Prepare

objection to Citi's request for extension to file PRRADA disclosures (.8)

05-16-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review agenda

05-17-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review AAFAF status report (.1); Review FOMB status Report (.1)

05-17-2022 John Arrastia B191 - General Litigation 0.90 575.00 517.50

Finalize objection to urgent motion filed by Citi: Confer with Committee

05-17-2022 Jesus Suarez B191 - General Litigation 0.80 500.00 400.00

Work on objection to urgent motion filed by Citi in connection with disclosures.

05-18-2022 Angelo Castaldi B191 - General Litigation 0.30 375.00 112.50

In advance of omnibus hearing, review of AAFAF and FOMB status reports.

05-31-2022 Jesus Suarez B191 - General Litigation 0.30 500.00 150.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Review litigation summary from C. Alvarez and attention to upcoming deadlines, issues.

15.50 7,855.00

L150 - Budgeting

05-03-2022 Heather Gray L150 - Budgeting 0.30 135.00 40.50

Disseminate Continental PLLC's May 2002 Budget, and confer with J. Arrastia regarding same.

05-23-2022 Heather Gray L150 - Budgeting 0.30 135.00 40.50

Circulate Continental PLLC's June 2002 Budget, and confer with J. Arrastia regarding same.

0.60 81.00

Total 22,298.00

Time Summary

Task Hours Amount

B110 - Case Administration 1.50 202.50

B113 - Pleadings Review 26.40 8,316.00

B150 - Meetings of and Communications with Creditors 1.60 822.50

B160 - Fee/Employment Application 13.10 5,021.00

B191 - General Litigation 15.50 7,855.00

L150 - Budgeting 0.60 81.00

Total Fees 22,298.00

Total for this Invoice 22,298.00

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PROMESA / UCC

June 13, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 246

Invoice Period: 05-01-2022 - 05-31-2022

REMITTANCE COPY

RE: Commonwealth of Puerto Rico

Fees 22,298.00

Total for this Invoice 22,298.00

Previous Balance 227,007.46

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 90,475.96 90,475.96

ERS 800.00 800.00

HTA 6,292.50 6,292.50

PREPA 151,737.00 151,737.00

Total Amount to Pay 249,305.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

06-13-2022 Invoice 246 Commonwealth of Puerto Rico 22,298.00 22,298.00

06-13-2022 Invoice 247 ERS 627.50 627.50

06-13-2022 Invoice 248 HTA 4,095.00 4,095.00

06-13-2022 Invoice 249 PREPA 104,116.00 104,116.00

Balance 249,305.46

WIRE TRANSFER INFORMATION

Beneficiary Bank: City National Bank of Florida

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

Beneficiary Bank ABA: 066004367 

Beneficiary Bank SWIFT: CNBFUS3M 

Beneficiary Name: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

June 13, 2022

PROMESA / UCC

Invoice Number: 247

Invoice Period: 05-01-2022 - 05-31-2022

Payment Terms: Upon Receipt

RE: ERS

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

05-04-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Review email correspondence regarding stipulations of dismissal and draft notice; Review revisions

05-06-2022 John Arrastia B191 - General Litigation 0.20 575.00 115.00

Review correspondence to counsel regarding dismissal (.2); Confer and strategize with A. Castaldi

(.2)

05-06-2022 Angelo Castaldi B191 - General Litigation 0.60 375.00 225.00

Review / revise stipulation of dismissal concerning ERS actions, communicate internally and

externally with counsel for the SCC concerning the same (.4); Confer and strategize with J. Arrastia

(.2)

05-16-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Review comments to stipulation of dismissal

1.30 627.50

Total 627.50

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Time Summary

Task Hours Amount

B191 - General Litigation 1.30 627.50

Total Fees 627.50

Total for this Invoice 627.50

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PROMESA / UCC

June 13, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 247

Invoice Period: 05-01-2022 - 05-31-2022

REMITTANCE COPY

RE: ERS

Fees 627.50

Total for this Invoice 627.50

Previous Balance 248,677.96

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 90,475.96 90,475.96

ERS 800.00 800.00

HTA 6,292.50 6,292.50

PREPA 151,737.00 151,737.00

Total Amount to Pay 249,305.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

06-13-2022 Invoice 246 Commonwealth of Puerto Rico 22,298.00 22,298.00

06-13-2022 Invoice 247 ERS 627.50 627.50

06-13-2022 Invoice 248 HTA 4,095.00 4,095.00

06-13-2022 Invoice 249 PREPA 104,116.00 104,116.00

Balance 249,305.46

WIRE TRANSFER INFORMATION

Beneficiary Bank: City National Bank of Florida

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

Beneficiary Bank ABA: 066004367 

Beneficiary Bank SWIFT: CNBFUS3M 

Beneficiary Name: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

June 13, 2022

PROMESA / UCC

Invoice Number: 248

Invoice Period: 05-01-2022 - 05-31-2022

Payment Terms: Upon Receipt

RE: HTA

Time Details

Date Professional Task Hours Rate Amount

B191 - General Litigation

05-02-2022 Angelo Castaldi B191 - General Litigation 1.90 375.00 712.50

Receive and review HTA plan and disclosure statement filed by the FOMB.

05-03-2022 Jesus Suarez B191 - General Litigation 2.30 500.00 1,150.00

Review HTA plan relating to issues with pending litigation.

05-06-2022 Angelo Castaldi B191 - General Litigation 0.80 375.00 300.00

Review of plan and disclosure statement hearing schedule, committee redlines to HTA plan, and

other materials concerning the HTA plan.

05-16-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Receive and review amended HTA plan filed by the FOMB and litigation resolved thereby.

5.40 2,312.50

B320 - Plan and Disclosure Statement (including Business Plan)

05-04-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

0.40 575.00 230.00

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Date Professional Task Hours Rate Amount

B320 - Plan and Disclosure Statement (including Business Plan)

Review HTA Analysis

05-04-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

2.40 575.00 1,380.00

Review amended Title III Plan of Adjustment (1.1); Review Disclosure Statement (1.3)

05-04-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

0.10 575.00 57.50

Review order on briefing schedule on Plan

05-06-2022 John Arrastia B320 - Plan and Disclosure Statement (including 

Business Plan)

0.20 575.00 115.00

Review proposed order on Hearing for Disclosure statement

3.10 1,782.50

Total 4,095.00

Time Summary

Task Hours Amount

B191 - General Litigation 5.40 2,312.50

B320 - Plan and Disclosure Statement (including Business Plan) 3.10 1,782.50

Total Fees 4,095.00

Total for this Invoice 4,095.00

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PROMESA / UCC

June 13, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 248

Invoice Period: 05-01-2022 - 05-31-2022

REMITTANCE COPY

RE: HTA

Fees 4,095.00

Total for this Invoice 4,095.00

Previous Balance 245,210.46

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 90,475.96 90,475.96

ERS 800.00 800.00

HTA 6,292.50 6,292.50

PREPA 151,737.00 151,737.00

Total Amount to Pay 249,305.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

06-13-2022 Invoice 246 Commonwealth of Puerto Rico 22,298.00 22,298.00

06-13-2022 Invoice 247 ERS 627.50 627.50

06-13-2022 Invoice 248 HTA 4,095.00 4,095.00

06-13-2022 Invoice 249 PREPA 104,116.00 104,116.00

Balance 249,305.46

WIRE TRANSFER INFORMATION

Beneficiary Bank: City National Bank of Florida

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

Beneficiary Bank ABA: 066004367 

Beneficiary Bank SWIFT: CNBFUS3M 

Beneficiary Name: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

(305) 677-2707

June 13, 2022

PROMESA / UCC

Invoice Number: 249

Invoice Period: 05-01-2022 - 05-31-2022

Payment Terms: Upon Receipt

RE: PREPA

Time Details

Date Professional Task Hours Rate Amount

B100 - Administration

05-20-2022 Jesus Suarez B100 - Administration 0.40 500.00 200.00

Review status report prepared by C. Alvarez and attention to scheduling critical dates and confirm

response deadlines (.4)

05-25-2022 Jesus Suarez B100 - Administration 0.30 500.00 150.00

Review status report prepared by C. Alvarez and attention to scheduling critical dates and confirm

response deadlines (.3)

0.70 350.00

B191 - General Litigation

05-02-2022 Angelo Castaldi B191 - General Litigation 1.90 375.00 712.50

Review and analyze Rule 12 motion filed by Saybolt in 19-388, outline core arguments asserted

therein, and begin preliminary review of cited authorities therein.

05-02-2022 Angelo Castaldi B191 - General Litigation 0.80 375.00 300.00

Review of numerous standing orders and procedures orders applicable to adversary proceedings

before the Honorable Judge Swain and Judge Dein.

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Date Professional Task Hours Rate Amount

B191 - General Litigation

05-02-2022 Angelo Castaldi B191 - General Litigation 3.60 375.00 1,350.00

Review and analyze omnibus Rule 12 motion filed by all dendants in 19-388, outline core

arguments asserted therein, and begin preliminary review of cited authorities therein.

05-02-2022 Angelo Castaldi B191 - General Litigation 2.80 375.00 1,050.00

Review and analyze Rule 12 motion filed by Vitol in 19-388, outline core arguments asserted

therein, and begin preliminary review of cited authorities therein.

05-02-2022 Angelo Castaldi B191 - General Litigation 0.90 375.00 337.50

Review and analyze Rule 12 motion filed by Vitol in 19-388, outline core arguments asserted

therein, and begin preliminary review of cited authorities therein.

05-02-2022 John Arrastia B191 - General Litigation 4.80 575.00 2,760.00

Analyze Alchem filings ( .4); Strategize (.6 ); Prepare Motion to Strike Joinder ( 1.3); Review case

file (.4); Confer with SCC counsel and strategize (.2); Legal research and analysis (1.3); Prepare

Motion to Strike Affirmative Defenses or, alternatively, for more definite statement (.6)

05-02-2022 Jesus Suarez B191 - General Litigation 3.10 500.00 1,550.00

Review Altol answer and propose striking affirmative defenses (.7); review affirmative defense

standard (.9) and research related to same (1.5)

05-03-2022 John Arrastia B191 - General Litigation 3.10 575.00 1,782.50

Strategize with A. Castaldi regarding structuring arguments and preparing responses (.6);

Strategize regarding Atol responses and motions (.6); Review Court Order (.1); Continued

preparation of motion to strike (1.1); Review Inspectorate Motion to Dismiss analysis and issues (.7)

05-03-2022 Angelo Castaldi B191 - General Litigation 6.40 375.00 2,400.00

With respect to pleading and sufficiency arguments advanced by Vitol, review and analyze cited by

Vitol, conduct substantial legal research of additional authorities concerning said arguments, and

populate memo of counterarguments (5.8); Confer with J. Arrastia (.6)

05-03-2022 Angelo Castaldi B191 - General Litigation 3.90 375.00 1,462.50

With respect to statute of limitations arguments advanced by several defendants, review and

analyze cited by said defendants, conduct substantial legal research of additional authorities

concerning said arguments, and populate memo of counterarguments.

05-03-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Conduct legal research concerning tolling theories under Puerto Rico law.

05-03-2022 Angelo Castaldi B191 - General Litigation 1.20 375.00 450.00

Conduct legal research of prior orders of the Honorable Judge Swain concerning Rule 12(b)(6)

dismissals.

05-03-2022 Carlos Alvarez B191 - General Litigation 0.70 315.00 220.50

Conduct legal research on an affirmative defense, standard, and notice requirements.

05-04-2022 Carlos Alvarez B191 - General Litigation 3.60 315.00 1,134.00

Legal research and analysis, confer with and strategize with the team on next steps in research,

continue preparation of analysis (3.2); confer with J. Arrastia (.4)

1.30 487.50

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Date Professional Task Hours Rate Amount

B191 - General Litigation

05-04-2022 Angelo Castaldi B191 - General Litigation 375.00

Prepare and revise motion to strike motion to dismiss joinder and conduct related research.

05-04-2022 Angelo Castaldi B191 - General Litigation 2.60 375.00 975.00

Research concerning pleading requirements concerning and validity of affirmative defenses raised

by Alchem defendants.

05-04-2022 Angelo Castaldi B191 - General Litigation 0.90 375.00 337.50

Commence preparation of reply in further support of procedures motion, addressing various

objections raised.

05-04-2022 Angelo Castaldi B191 - General Litigation 0.70 375.00 262.50

Attend to project concerning contract registration of contracts by fuel service and laboratory service

providers.

05-04-2022 John Arrastia B191 - General Litigation 0.60 575.00 345.00

Review research regarding dismissals filed in AP 388

05-04-2022 John Arrastia B191 - General Litigation 1.60 575.00 920.00

Review legal research (.4); Confer with C. Alvarez regarding striking affirmative defenses (.4);

Review and revise draft motion to strike joinder (.4); Review comments from SCC (.1); Review

additional legal research regarding striking defenses (.3);

05-04-2022 John Arrastia B191 - General Litigation 2.10 575.00 1,207.50

Review and analyze each argument outline for each motion to dismiss

05-04-2022 Jesus Suarez B191 - General Litigation 2.70 500.00 1,350.00

Extensive research concerning VITOL claims in Rule 12 motion and development of response.

05-05-2022 Jesus Suarez B191 - General Litigation 3.70 500.00 1,850.00

Review research concerning PR tolling law, provide arguments in opposition (1.4); continued work

on Alchem affirmative defenses (2.3)

05-05-2022 Angelo Castaldi B191 - General Litigation 0.40 375.00 150.00

Review of records concerning Vitol contracts.

05-06-2022 John Arrastia B191 - General Litigation 0.10 575.00 57.50

Confer with opposing counsel

05-06-2022 Jesus Suarez B191 - General Litigation 3.40 500.00 1,700.00

Legal research and strategy with team on legal research and brief writing (1.6); formulate briefing

issues concerning ten year avoidance claim (1.8)

05-09-2022 Jesus Suarez B191 - General Litigation 3.30 500.00 1,650.00

Prepare materials on in pari delicto in connection with briefing on motions to dismiss (2.4), work on

same (.9)

05-09-2022 John Arrastia B191 - General Litigation 0.90 575.00 517.50

Review Court Order (.1); Analyze Vitol contracts relating to claims (.5); Review draft outlines from

A. Castaldi (.3)

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Date Professional Task Hours Rate Amount

B191 - General Litigation

05-09-2022 Angelo Castaldi B191 - General Litigation 2.40 375.00 900.00

Finalize detailed outline of arguments and counter-arguments in relation to Defendant’s omnibus

12(b)(6) motion, and strategize, coordinate, and communicate internally concerning the same

05-09-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Receive and review briefing schedule concerning Alchem and coordinate internally concerning the

same

05-10-2022 Angelo Castaldi B191 - General Litigation 2.40 375.00 900.00

Review case law and briefing on in pari delicto in Puerto Rico cases

05-10-2022 Angelo Castaldi B191 - General Litigation 2.40 375.00 900.00

Review case law and briefing on Kali Seafood case in Puerto Rico / First Circuit cases, and,

separately, materials applying LPRA § 3492(5)

05-10-2022 John Arrastia B191 - General Litigation 1.70 575.00 977.50

Review legal research regarding issues raised in motions to dismiss

05-10-2022 Jesus Suarez B191 - General Litigation 3.50 500.00 1,750.00

Review 12(b)(6) issues and review outline of legal matters (1.7); provide legal research concerning

development of ten year look back period claims (1.8).

05-11-2022 Jesus Suarez B191 - General Litigation 3.60 500.00 1,800.00

Prepare for and participate in strategy conference with SCC (1);work on motion to strike affirmative

defenses (2.6)

05-11-2022 Carlos Alvarez B191 - General Litigation 1.60 315.00 504.00

Confer and strategize with A. Castaldi concerning next steps in case and review and analysis of

prior answers filed by defendants in original actions; review and analysis of same; prepare redline

comparison of answers; share with A. Castaldi for review.

05-11-2022 Angelo Castaldi B191 - General Litigation 5.80 375.00 2,175.00

Prepare and revise motion to strike Alchem affirmative defenses

05-11-2022 Angelo Castaldi B191 - General Litigation 2.90 375.00 1,087.50

Conduct substantial legal research of First Circuit and D. P.R. case law concerning validity of

affirmative defenses, pleading requirements concerning the same, standards governing "boilerplate" defenses, remedies for replying parties, and related legal issues

05-11-2022 Angelo Castaldi B191 - General Litigation 0.80 375.00 300.00

Confer with co-plaintiffs' counsel and prepare for same

05-11-2022 John Arrastia B191 - General Litigation 2.70 575.00 1,552.50

Prepare for strategy conference with SCC regarding motions addressed to Complaint (.6); Confer

with SCC).5); Prepare motion to strike affirmative defenses (1.6)

05-12-2022 John Arrastia B191 - General Litigation 1.70 575.00 977.50

Review revised draft of motion to strike (.7) review SCC counsel comments (.2); Confer with SCC (.

1): Review Alchem filings in class actions (.6); Review correspondence to opposing counsel (.1)

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Date Professional Task Hours Rate Amount

B191 - General Litigation

05-12-2022 Angelo Castaldi B191 - General Litigation 4.80 375.00 1,800.00

Prepare and finalize extensive motion to strike affirmative defenses.

05-12-2022 Angelo Castaldi B191 - General Litigation 1.40 375.00 525.00

Detailed review and analysis of answers filed by Altol in class action case and in 19-388.

05-12-2022 Angelo Castaldi B191 - General Litigation 2.40 375.00 900.00

Prepare response to insolvency arguments contained in omnibus motion to dismiss filed in 19-388

and conduct related legal research concerning the same.

05-12-2022 Jesus Suarez B191 - General Litigation 3.40 500.00 1,700.00

Work on Motion to Dismiss briefing; research issues concerning 10 year lookback.

05-13-2022 Jesus Suarez B191 - General Litigation 2.80 500.00 1,400.00

Review issues relating to insolvency and ten year look back period.

05-13-2022 Angelo Castaldi B191 - General Litigation 0.20 375.00 75.00

Review letter from FOMB concerning PRPEA initiatives.

05-13-2022 Angelo Castaldi B191 - General Litigation 1.70 375.00 637.50

Prepare briefing concerning insolvency relating to 19-388.

05-15-2022 John Arrastia B191 - General Litigation 2.90 575.00 1,667.50

Confer with SCC regarding strategy concerning reply (.2); Legal research and analysis regarding

issues relating to reply to Alchem response to motion to strike joinder (.8); Revise draft reply (1.8)

05-15-2022 Jesus Suarez B191 - General Litigation 0.60 500.00 300.00

Attention to reply to Motion to Strike Affirmative Defenses.

05-16-2022 Jesus Suarez B191 - General Litigation 4.70 500.00 2,350.00

Review issues concerning pleading standards for trustee's in First Circuit (1.4); work on briefing in

connections with motions to dismiss (2.7); attention to Citi related issues (,6)

05-17-2022 Jesus Suarez B191 - General Litigation 3.20 500.00 1,600.00

Continued researrch and drafting in support of briefing on motions to dismiss.

05-17-2022 John Arrastia B191 - General Litigation 1.80 575.00 1,035.00

Review motion to file sur-reply (.1); Review and evaluate additional bases for recovery of all funds

paid pursuant to contract (1.7)

05-17-2022 John Arrastia B191 - General Litigation 1.30 575.00 747.50

Review research and analysis regarding in pari delicto arguments and defenses

05-18-2022 Angelo Castaldi B191 - General Litigation 2.70 375.00 1,012.50

Conduct preliminary legal research concerning standard of review and conduct review of current

deadlines concerning briefing and mediation.

05-19-2022 Angelo Castaldi B191 - General Litigation 1.60 375.00 600.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Review and analyze cases of the Puerto Rico courts applying in pari delicto doctrine.

05-19-2022 John Arrastia B191 - General Litigation 1.70 575.00 977.50

Strategize with A. Castaldi regarding omnibus motion to dismiss arguments (.6); Prepare outlines of

argument elements relating to procedure relating to all Rule 12 motions (1.1)

05-19-2022 Angelo Castaldi B191 - General Litigation 3.60 375.00 1,350.00

Review case law and briefing on motions to dismiss in recent First Circuit cases, and analyze /

consider strategy concerning formulation of response to omnibus motion to dismiss filed

collectively by laboratory and fuel supplier defendants.

05-19-2022 Angelo Castaldi B191 - General Litigation 5.30 375.00 1,987.50

Begin preparation and drafting of omnibus response to omnibus motion to dismiss.

05-19-2022 Jesus Suarez B191 - General Litigation 3.70 500.00 1,850.00

Continued work on draft response to omnibus motion to dismiss.

05-20-2022 Angelo Castaldi B191 - General Litigation 11.80 375.00 4,425.00

Prepare and draft omnibus response to omnibus motion to dismiss.

05-20-2022 Jesus Suarez B191 - General Litigation 3.40 500.00 1,700.00

Continued work on draft response to omnibus motion to dismiss.

05-23-2022 Jesus Suarez B191 - General Litigation 5.00 500.00 2,500.00

Review Altol reply (.4); continued work in support of briefing on Motion to dismiss (4.6)

05-23-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Review Sur-Reply by Alchem

05-23-2022 Angelo Castaldi B191 - General Litigation 10.30 375.00 3,862.50

Prepare and draft omnibus response to omnibus motion to dismiss.

05-23-2022 John Arrastia B191 - General Litigation 0.40 575.00 230.00

Review Sur-Reply by Alchem

05-24-2022 Angelo Castaldi B191 - General Litigation 7.20 375.00 2,700.00

Finalize initial preparation of 35+ page omnibus response to omnibus motion to dismiss.

05-24-2022 Angelo Castaldi B191 - General Litigation 0.70 375.00 262.50

Review of issues concerning IRS proof of claim and timing thereof.

05-24-2022 Angelo Castaldi B191 - General Litigation 1.40 375.00 525.00

Analyze / consider strategy concerning formulation of response to rule 12(b)(6) motion filed by Vitol

entities.

05-24-2022 Jesus Suarez B191 - General Litigation 3.60 500.00 1,800.00

Provide comments, research and revisions in support of omnibus response to motion to dismiss.

05-25-2022 Jesus Suarez B191 - General Litigation 2.90 500.00 1,450.00

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Date Professional Task Hours Rate Amount

B191 - General Litigation

Work on response to Vitol 12(b)(6) motion (2.1); review hidden defect case law and provide input (.

8)

05-25-2022 Angelo Castaldi B191 - General Litigation 5.30 375.00 1,987.50

Prepare and revise response to Rule 12(b)(6) motion filed by Vitol entities.

05-25-2022 Angelo Castaldi B191 - General Litigation 1.70 375.00 637.50

Review case law and related briefings in cases involving "hidden defect" issues under the L.P.R.A.

05-26-2022 Angelo Castaldi B191 - General Litigation 8.30 375.00 3,112.50

Prepare and revise response to Rule 12(b)(6) motion filed by Vitol entities.

05-26-2022 Jesus Suarez B191 - General Litigation 6.10 500.00 3,050.00

Continued research and support in connection with Vitol Rule 12(b)(6) motion (2.8); continued

research in support of response to omnibus motion and revisions to same (3.3).

05-26-2022 John Arrastia B191 - General Litigation 1.40 575.00 805.00

Continued analysis of Twombly arguments

05-26-2022 John Arrastia B191 - General Litigation 1.40 575.00 805.00

Review, analyze, and revise Draft Response to Omnibus Motion to Dismiss (1.3): Review order

regarding termination of mediation (.1)

05-27-2022 John Arrastia B191 - General Litigation 1.30 575.00 747.50

Review SCC draft response to Omnibus Motion to Dismiss and strategize

05-27-2022 Jesus Suarez B191 - General Litigation 4.90 500.00 2,450.00

Finalize review of draft response to Vitol 12(b)(6) motion and provide revisions concerning same

(3.6); finalize review of draft response to Omnibus MTD and provide revisions to same (1.3)

05-27-2022 Angelo Castaldi B191 - General Litigation 6.70 375.00 2,512.50

Finalize preparation of initial, 25+ page response to Vitol rule 12(b)(6) motion.

05-30-2022 Jesus Suarez B191 - General Litigation 2.40 500.00 1,200.00

Review and analysis of Brown Rudnick response to Omnibus Motions to Dismiss and review cited

case law with respect to 10 year transfers, follow-up research concerning same.

05-30-2022 Jesus Suarez B191 - General Litigation 0.70 500.00 350.00

Review PREPA mediation issues as it relates to impact on litigation claims, timing of briefing.

05-31-2022 Jesus Suarez B191 - General Litigation 3.30 500.00 1,650.00

Review Brown Rudnick draft response to Motion to Dismiss (.9); analyze sections not covered by

UCC revisions (1.6); and suggest additions (.8)

05-31-2022 Angelo Castaldi B191 - General Litigation 1.30 375.00 487.50

Detailed review of draft briefing prepare by co-plaintiffs' counsel

234.90 103,363.50

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Date Professional Task Hours Rate Amount

B260 - Meeting with FOMB and SCC

05-04-2022 John Arrastia B260 - Meeting with FOMB and SCC 0.30 575.00 172.50

Confer with SCC (2x)

05-15-2022 John Arrastia B260 - Meeting with FOMB and SCC 0.20 575.00 115.00

Confer with SCC on filings (multiple)

05-23-2022 John Arrastia B260 - Meeting with FOMB and SCC 0.20 575.00 115.00

Confer with SCC regarding factual aspects of motion

0.70 402.50

Total 104,116.00

Time Summary

Task Hours Amount

B100 - Administration 0.70 350.00

B191 - General Litigation 234.90 103,363.50

B260 - Meeting with FOMB and SCC 0.70 402.50

Total Fees 104,116.00

Total for this Invoice 104,116.00

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PROMESA / UCC

June 13, 2022

Continental PLLC

255 Alhambra Circle, Suite 640

Coral Gables, FL 33134

Invoice Number: 249

Invoice Period: 05-01-2022 - 05-31-2022

REMITTANCE COPY

RE: PREPA

Fees 104,116.00

Total for this Invoice 104,116.00

Previous Balance 145,189.46

Matter Invoices /

Credits

Trust Balance Due

Commonwealth of Puerto Rico 90,475.96 90,475.96

ERS 800.00 800.00

HTA 6,292.50 6,292.50

PREPA 151,737.00 151,737.00

Total Amount to Pay 249,305.46

Open Invoices and Credits

Date Transaction Matter Amount Applied Balance

03-04-2022 Invoice 141 Commonwealth of Puerto Rico 38,828.00 38,828.00

03-04-2022 Invoice 142 HTA 862.50 862.50

03-04-2022 Invoice 143 PREPA 7,506.00 7,506.00

04-14-2022 Invoice 167 Commonwealth of Puerto Rico 17,343.96 17,343.96

04-14-2022 Invoice 168 ERS 172.50 172.50

04-14-2022 Invoice 169 HTA 115.00 115.00

04-14-2022 Invoice 170 PREPA 5,867.50 5,867.50

05-09-2022 Invoice 217 HTA 1,220.00 1,220.00

05-09-2022 Invoice 218 PREPA 34,247.50 34,247.50

05-10-2022 Invoice 220 Commonwealth of Puerto Rico 12,006.00 12,006.00

06-13-2022 Invoice 246 Commonwealth of Puerto Rico 22,298.00 22,298.00

06-13-2022 Invoice 247 ERS 627.50 627.50

06-13-2022 Invoice 248 HTA 4,095.00 4,095.00

06-13-2022 Invoice 249 PREPA 104,116.00 104,116.00

Balance 249,305.46

WIRE TRANSFER INFORMATION

Beneficiary Bank: City National Bank of Florida

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

Beneficiary Bank ABA: 066004367 

Beneficiary Bank SWIFT: CNBFUS3M 

Beneficiary Name: CONTINENTAL PLLC

Beneficiary Account: 30000422605

For Confirmation of Wire Instructions, please call: JESUS M. SUAREZ (305)677-2707.

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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 FIRST INTERIM FEE APPLICATION OF 

CONTINENTAL PLLC AS SPECIAL LITIGATION COUNSEL TO 

OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR 

SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR

THE PERIOD FROM FEBRUARY 15, 2022 THROUGH MAY 31, 2022

Upon consideration of the First Interim Fee Application (the “First Interim Application”)

2

of Continental PLLC (“Continental”), 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 

compensation and reimbursement of expenses for the period from February 15, 2022 through May

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 shall have the meanings ascribed to them in the First Interim 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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31, 2022, the Court hereby FINDS AND DETERMINES that (i) the Court has jurisdiction to 

consider the First Interim 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 First Interim Application has been provided under the particular 

circumstances and no other or further notice need be provided; (iv) any objections to the First 

Interim Application having been resolved; (v) all persons with standing having been afforded the 

opportunity to be heard on the First Interim Application; and after due deliberation and sufficient 

cause appearing therefor, it is hereby ORDERED THAT:

1. The First Interim Application is granted on an interim basis.

2. Continental’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 $249,241.50 and $63.96, 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 Continental 

the outstanding fees in the amount of $19,939.32 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 Continental for its outstanding 

expenses in the amount of $0.00, 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.

5. Continental is authorized and empowered to take all necessary actions to implement 

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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).

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Dated:_____________, 2022.

 

_______________________________________

HON. LAURA TAYLOR SWAIN 

UNITED STATES DISTRICT JUDGE

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