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

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

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

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

 : 

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

 : 

Debtors.1

 : 

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

NOTICE OF HEARING ON SIXTEENTH INTERIM FEE APPLICATION OF PAUL 

HASTINGS LLP, AS COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM JUNE 1, 2022 THROUGH SEPTEMBER 30, 2022 

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

Application of Paul Hastings LLP, as Counsel to Official Committee of Unsecured Creditors, for 

Services Rendered and Reimbursement of Expenses for Period from June 1, 2022 through 

September 30, 2022 (the “Application”) filed by Paul Hastings LLP, pursuant 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 

 

1

 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number and the last four (4) 

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

(the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) 

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

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

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

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

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

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

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 1 of 58
2 

District Court for the District of Puerto Rico, in Room 3, 150 Carlos Chardón Street, Federal 

Building, Office 150, San Juan, Puerto Rico 00918-1767 on February 1, 2023 at 8:30 a.m. 

(ET) / 9:30 a.m. (AST) (the “Hearing”). 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[Remainder of page intentionally left blank.] 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 2 of 58
3 

PLEASE TAKE FURTHER NOTICE that, in accordance with the Interim 

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

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

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

Dated: November 15, 2022 /s/ Luc A. Despins .

PAUL HASTINGS LLP 

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

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

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

200 Park Avenue

New York, New York 10166

Telephone: (212) 318-6000

lucdespins@paulhastings.com

nicholasbassett@paulhastings.com

alexbongartz@paulhastings.com

Counsel to the Official Committee of Unsecured 

Creditors 

- and -

/s/ Juan J. Casillas Ayala

CASILLAS, SANTIAGO & TORRES LLC 

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

Israel Fernández Rodríguez, Esq. (USDC - PR 

225004) 

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

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

306008) 

PO Box 195075 

San Juan, PR 00919-5075 

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

jcasillas@cstlawpr.com 

ifernandez@cstlawpr.com 

jnieves@cstlawpr.com 

cfernandez@cstlawpr.com 

Local Counsel to the Official Committee of Unsecured 

Creditors 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 3 of 58
Hearing Date: February 1, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) 

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

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

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

 : 

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

 : 

Debtors.1

 : 

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

SIXTEENTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP, AS 

COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR 

SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR PERIOD 

FROM JUNE 1, 2022 THROUGH SEPTEMBER 30, 2022 

SUMMARY COVER SHEET 

Name of applicant: Paul Hastings LLP (“Paul Hastings”) 

Authorized to provide professional services 

to: 

Official Committee of Unsecured Creditors 

(the “Committee”)2

Date of retention: Order entered August 10, 2017, effective as of 

June 26, 2017 [Docket No. 999] 

Period for which compensation and 

reimbursement are sought: 

June 1, 2022 through and including September 

30, 2022 (the “Application Period”) 

 

1

 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number and the last four (4) 

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

(the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) 

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

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

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

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

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

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

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

2

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

COFINA. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 4 of 58
2 

Amount of interim compensation sought as 

actual, reasonable, and necessary: 

$1,145,246.50 / $916,197.203

Amount of interim expense reimbursement 

sought as actual, reasonable, and necessary: 

$7,356.79 

Are your fee or expense totals different 

from the sum of previously-served monthly 

statements for the Application Period? 

No. 

Total compensation approved by interim 

order to date: 

$72,198,846.12 

Total expenses approved by interim order to 

date: 

$2,482,703.65 

Total allowed compensation paid to date: $58,699,658.50 

Total allowed expenses paid to date: $2,482,703.65 

Blended rate in this Application for all 

attorneys: 

(a) $1,218 /hour; (b) $975 /hour4 

Blended rate in this Application for all 

timekeepers: 

(a) $1,136 /hour; (b) $909 /hour4

Compensation sought in this Application 

already paid pursuant to a monthly 

compensation order but not yet allowed: 

$658,917.60 

Expenses sought in this Application already 

paid pursuant to a monthly compensation 

order but not yet allowed: 

$5,578.21 

The total time expended for fee application 

preparation during the Application Period: 

Approximately 20.8 hours 

The total compensation requested for fee 

application preparation during the 

Application Period: 

Approximately $22,404.50 

 

3

 While Paul Hastings seeks allowance of all of its fees incurred during the Application Period, the firm only 

seeks payment, at this time, of fees in the amount of $916,197.20 (to the extent such amount has not been paid 

before the hearing scheduled on this Application), which is 80% of $1,145,246.50. By the time of the hearing 

on this Application, this amount should have long been paid by the Debtors pursuant to the Interim 

Compensation Order (as defined below), and Paul Hastings reserves its rights to seek relief from the Court to 

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

Interim Compensation Order. 

4

 The calculation of the blended hourly rates reflected in (a) does not take into account Paul Hastings’ agreement 

to reduce its fees by an amount equal to 20% of its total case fees, with the precise fees to be waived to attain 

the 20% reduction to be designated by Paul Hastings (in its sole discretion) in connection with the final fee 

application process. The impact of the 20% end of the case write-off on the blended hourly rates cannot be 

calculated at this time. However, for illustrative purposes only, we have reflected in (b) the blended hourly rate 

after accounting for the 20% reduction for all attorneys and for all timekeepers.

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 5 of 58
3 

Number of professionals included in this 

Application: 

13 

If applicable, number of professionals in 

this Application not included in a staffing 

plan approved by the client: 

1 

If applicable, difference between fees 

budgeted and compensation sought for the 

Application Period: 

Not applicable. 

Number of professionals billing fewer than 

15 hours to the case during the Application 

Period: 

4 

Are any timekeeper’s hourly rates higher 

than those approved or disclosed at 

retention? If yes, calculate and disclose the 

total compensation sought in this 

Application using the rates originally 

disclosed in the retention application: 

Yes.5 When calculated at the rates in effect 

during the initial fee period (June 26, 2017 

through September 30, 2017), total fees for the 

Application Period would have been 

$871,920.00 (compared to $1,145,246.50 

under the current rates). The rate adjustments 

reflect not only Paul Hastings’ across-theboard increases in its rate scale, but also step 

increases due to advancing seniority. While 

$273,326.50 of Paul Hastings’ fees for the 

Application Period are attributable to periodic 

changes in rates, $31,480.00 of this amount is 

attributable to step increases due to advancing 

seniority.6

 Thus, only $241,846.50 of the fees 

in the Application Period are attributable to 

changes in the firm’s rate scale since the date 

of retention. 

 

5

 As is customary, and as permitted pursuant to paragraph 2 of Paul Hastings’ retention order [Docket No. 999], 

every year Paul Hastings 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. As detailed in the notice filed on January 11, 2022 [Docket No. 

19736], Paul Hastings raised its rates for certain timekeepers working on the Puerto Rico matter as of February 

1, 2022, which adjustments apply across-the-board to all Paul Hastings clients. The Committee approved the 

rate adjustment on a timekeeper-by-timekeeper basis. As a courtesy to the Committee, Paul Hastings 

voluntarily agreed to reduce the hourly rate of Luc A. Despins (from $1,825 to $1,700.00 per hour) for the 

Application Period in the Puerto Rico matter (adjusted to reflect, on a pro forma basis, the 20% end-of-case 

reduction). 

6

 Under the U.S. Trustee’s Appendix B Guidelines, rate increases “exclude step increases historically awarded by 

the firm in the ordinary course to attorneys throughout the firm due to advancing seniority and promotion.” 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 6 of 58
4 

MONTHLY FEE REQUESTS TO DATE 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested Fees 

(80%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

20% Fee 

Holdback 

First Interim Fee Period (June 26, 2017 through September 30, 2017) 

8/25/17 6/26/17 - 

7/31/17 

$2,612,026.60 $128,519.42 $2,612,026.20 $128,519.42 $653,006.65 

10/20/17 8/1/17- 

8/31/17 

$2,742,786.60 ($35,965.44) $2,742,786.60 ($35,965.44) $685,696.65 

12/5/17 9/1/17 - 

9/30/17 

$2,121,569.60 $40,716.24 $2,121,569.60 $40,716.24 $530,392.40 

Total $7,476,382.80 $133,270.22 $7,476,382.40 $133,270.22 $1,869,095.70 

Second Interim Fee Period (October 1, 2017 through January 31, 2018) 

12/23/17 10/1/17 - 

10/31/17 

$915,475.60 $14,567.93 $915,475.60 $14,567.90 $228,868.90 

1/5/18 11/1/17 - 

11/30/17 

$1,445,414.80 $27,705.47 $1,445,414.80 $27,705.47 $361,353.70 

1/12/18 12/1/17 - 

12/31/17 

$1,467,883.60 $22,557.50 $1,467,883.60 $22,557.50 $366,970.90 

3/16/18 1/1/18 - 

1/31/18 

$1,824,040.207 $30,631.538 $1,822,932.20 $17,909.03 $455,733.05 

Total $5,652,814.20 $95,462.43 $5,651,706.20 $82,739.90 $1,412,926.55

Third Interim Fee Period (February 1, 2018 through May 31, 2018)

4/18/18 2/1/18 - 

2/28/18 

$2,015,455.20 $87,789.71 $2,015,455.20 $87,789.71 $503,863.80 

5/9/18 3/1/18 - 

3/31/18 

$2,416,111.40 $53,500.42 $2,416,111.40 $53,500.42 $604,027.85 

6/15/18 4/1/18 - 

4/30/18 

$1,355,344.60 $408,763.80 $1,355,344.60 $408,763.80 $339,320.15 

7/13/18 5/1/18 - 

5/31/18 

$1,152,043.00 $36,939.73 $1,152,043.00 $36,939.73 $288,010.75 

Total $6,938,954.20 $586,993.66 $6,938,954.20 $586,993.66 $1,735,222.55 

Fourth Interim Fee Period (June 1, 2018 through September 30, 2018)

9/6/18 6/1/18 - 

6/30/18 

$983,056.20 $45,319.10 $983,056.20 $45,319.10 $245,764.05 

 

7

 This amount reflects a credit of $13,507.00 for fee reductions pursuant to the order approving Paul Hastings’ 

First Interim Fee Application. 

8

 This amount reflects a credit of $21,926.16 for expense reductions pursuant to the order approving Paul 

Hastings’ First Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 7 of 58
5 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested Fees 

(80%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

20% Fee 

Holdback 

10/8/18 7/1/18 - 

7/31/18 

$1,061,831.60 $77,376.40 $1,061,831.60 $77,376.40 $265,457.90 

11/2/18 8/1/18 - 

8/31/18 

$1,288,866.00 $39,833.17 $1,288,866.00 $39,833.17 $322,216.50 

11/15/18 9/1/18 - 

9/30/18 

$1,302,462.40 $39,196.98 $1,302,462.40 $39,196.98 $325,615.60 

Total $4,636,216.20 $201,725.65 $4,636,216.20 $201,725.65 $1,159,054.05 

Fifth Interim Fee Period (October 1, 2018 through January 31, 2019)

12/19/18 10/1/18 – 

10/31/18 

$968,238.40 $17,300.41 $968,238.40 $17,300.41 $242,059.60 

01/07/19 11/1/18 – 

11/30/18 

$695,795.40 $9,071.96 $695,795.40 $9,071.96 $173,948.85 

02/20/19 12/1/18 – 

12/31/18 

$932,751.60 $24,110.50 $932,751.60 $24,110.50 $233,187.90 

03/15/10 1/1/19 – 

1/31/19 

$1,040,883.799 $38,921.4210 $1,040,883.79 $38,921.42 $260,220.95 

Total $3,637,669.19 $89,404.29 $3,637,669.19 $89,404.29 $909,417.30 

Sixth Interim Fee Period (February 1, 2019 through May 31, 2019)

06/13/19 2/1/19 – 

2/28/19 

$1,098,711.60 $30,746.31 $1,098,711.60 $30,746.31 $274,677.90 

06/13/19 3/1/19 – 

3/31/19 

$1,453,006.40 25,745.44 $1,453,006.40 $25,745.44 $363,251.60 

07/03/19 4/1/19 – 

4/30/19 

$1,852,132.00 $64,731.53 $1,852,132.00 $64,731.53 $463,033.00 

07/15/19 5/1/19 – 

5/31/19 

$2,143,294.80 $61,317.34 $2,143,294.80 $61,317.34 $535,823.70 

Total $6,547,144.80 $182,540.62 $6,547,144.80 $182,540.62 $1,636,786.20 

Seventh Interim Fee Period (June 1, 2019 through September 30, 2019)

08/21/19 6/1/19 – 

6/30/19 $1,841,416.6611 $300,689.64 $1,841,416.66 $300,689.64 $478,122.60 

 

9

 This amount reflects a credit of $158,129.01 for fee reductions pursuant to the order approving Paul Hastings’ 

Third and Fourth Interim Fee Applications. 

10 This amount reflects a credit of $6,033.82 for expense reductions pursuant to the order approving Paul 

Hastings’ Third and Fourth Interim Fee Applications. 

11 This amount reflects a credit of $88,842.17 for fee reductions pursuant to the order approving Paul Hastings’ 

Fifth Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 8 of 58
6 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested Fees 

(80%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

20% Fee 

Holdback 

09/27/19 7/1/19 – 

7/31/19 $1,955,942.80 $380,030.21 $1,955,942.80 $380,030.21 $488,985.70 

10/31/19 8/1/19 – 

8/31/19 $1,051,966.00 $127,240.87 $1,051,966.00 $127,240.87 $262,991.50 

11/14/19 9/1/19 – 

9/30/19 $1,052,167.20 $92,968.5512 $1,052,167.20 $92,968.55 $263,041.80 

Total $5,901,492.71 $900,929.27 $5,901,492.66 $900,929.27 $1,493,141.60 

Eighth Interim Fee Period (October 1, 2019 through January 31, 2020)

12/19/20 10/1/19 – 

10/31/19 

$1,911,593.40 $113,178.50 $1,911,593.40 $113,178.50 $477,898.35 

01/09/20 11/1/19 – 

11/30/19 

$830,350.40 $68,843.54 $830,350.40 $68,843.54 $207,587.60 

02/28/20 12/1/19 – 

12/31/19 

$8812,363.1713 $54,148.0314 $812,363.17 $54,148.03 $202,867.59 

03/13/20 1/1/20 – 

1/31/20 

$963,194.20 $44,734.48 $963,194.20 $44,734.48 $240,263.85 

Total $4,517,501.17 $280,904.55 $4,517,501.17 $280,904.55 $1,128,617.39 

Ninth Interim Fee Period (February 1, 2020 through May 31, 2020)

04/27/20 2/1/19 – 

2/29/20 

$1,537,133.80 $64,790.53 $1,537,133.80 $64,790.53 $384,283.45 

05/15/20 3/1/20 – 

3/31/20 

$1,230,017.80 $26,061.77 $1,230,017.80 $26,061.77 $307,504.45 

06/05/20 4/1/20 – 

4/30/20 

$665,122.80 $30,205.99 $665,122.80 $30,205.99 $166,280.70 

07/10/20 5/1/20 – 

5/31/20 

$398,858.80 $18,014.66 $398,858.80 $18,014.66 $99,714.70 

Total $3,831,133.20 $139,072.95 $3,831,133.20 $139,072.95 $957,783.30 

Tenth Interim Fee Period (June 1, 2020 through September 30, 2020) 

08/6/20 6/1/20 – 

6/30/20 

$331,160.8215 $8,379.4616 $331,160.82 $8,379.46 $82,790.20 

 

12 This amount reflects a credit of $606.96 for expense reductions pursuant to the order approving Paul Hastings’ 

Fifth Interim Fee Application. 

13 This amount reflects a credit of $145,627.04 for fee reductions pursuant to the order approving Paul Hastings’ 

Sixth Interim Fee Application. 

14 This amount reflects a credit of $227.93 for expense reductions pursuant to the order approving Paul Hastings’ 

Sixth Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 9 of 58
7 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested Fees 

(80%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

20% Fee 

Holdback 

09/14/20 7/1/20 – 

7/31/20 

$487,330.80 $66,532.00 $487,330.80 $66,532.00 $121,832.70 

10/10/20 8/1/20 – 

8/31/20 

$516,247.20 $34,799.52 $516,247.20 $34,799.52 $129,061.80 

11/2/20 9/1/20 – 

9/30/20 

$499,875.60 $39,927.12 $499,875.60 $39,927.12 $124,968.90 

Total $1,834,614.42 $149,638.10 $1,834,614.42 $149,638.10 $458,653.60 

Eleventh Interim Fee Period (October 1, 2020 through January 31, 2021)

12/12/20 10/1/20 – 

10/31/20 

$579,022.80 $9,489.60 $579,022.80 $9,489.60 $144,755.40 

01/8/21 11/1/20 –

11/30/20 

$290,754.00 $22,036.54 $290,754.00 $22,036.54 $72,688.50 

02/12/21 12/1/20 – 

12/31/20 

$417,523.60 $14,383.76 $417,523.60 $14,383.76 $104,380.90 

03/11/21 1/1/21 – 

1/31/21 

$202,174.00 $14,267.47 $202,174.00 $14,267.47 $50,543.50 

Total $1,489,474.40 $60,177.37 $1,489,474.40 $60,177.37 $372,368.60 

Twelfth Interim Fee Period (February 1, 2021 through May 31, 2021)

4/9/21 2/1/21 – 

2/28/21 

$216,458.1417 $24,926.47 $216,458.14 $24,926.47 $54,114.53 

5/7/21 3/1/21 – 

3/31/21 

$152,465.2418 $8,252.7519 $152,465.24 $8,252.75 $38,116.31 

6/25/21 4/1/21 - 

4/30/21 

$619,255.60 $35,459.58 $619,255.58 $35,459.58 $154,813.90 

7/9/21 5/1/21 – 

5/31/21 

$352,375.60 $9,950.81 $352,375.59 $9,950.81 $88,092.90 

Total $1,340,554.58 $78,589.61 $1,340,554.55 $78,589.61 $335,137.64 

 15 This amount reflects a credit of (a) $99,027.94 for fee reductions pursuant to the order approving Paul Hastings’ 

Seventh Interim Fee Application and (b) $73,343.54 for fee reductions pursuant to the order approving Paul 

Hastings’ Eighth Interim Fee Application. 

16 This amount reflects a credit of (a) $548.31 for expense reductions pursuant to the order approving Paul 

Hastings’ Seventh Interim Fee Application and (b) $99.18 for expense reductions pursuant to the order 

approving Paul Hastings’ Eighth Interim Fee Application. 

17 This amount reflects a credit of $78,764.83 for fee reductions pursuant to the order approving Paul Hastings’ 

Ninth Interim Fee Application. 

18 This amount reflects a credit of $162,080.45 for fee reductions pursuant to the order approving Paul Hastings’ 

Tenth Interim Fee Application. 

19 This amount reflects a credit of $170.77 for cost reductions pursuant to the order approving Paul Hastings’ 

Tenth Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 10 of 58
8 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested Fees 

(80%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

20% Fee 

Holdback 

Thirteenth Interim Fee Period (June 1, 2021 through September 30, 2021)

8/21/21 6/1/21 – 

6/30/21 

$622,676.8120 $50,044.06 $622,676.81 $50,044.06 $194,122.80 

9/17/21 7/1/21 – 

7/31/21 

$428,374.40 $10,110.73 $428,374.40 $10,110.73 $107,093.60 

10/25/21 8/1/21 – 

8/31/21 

$157,248.40 $932.25 $157,248.40 $932.25 $39,312.10 

11/12/21 9/1/21 – 

9/30/21 

$198,100.40 $2,855.11 $198,100.40 $2,855.11 $49,525.0 

Total $1,406,400.01 $63,942.15 $1,406,400.01 $63,942.15 $390,053.60 

Fourteenth Interim Fee Period (October 1, 2021 through January 31, 2022) 

12/17/21 10/1/21 – 

10/31/21 

$318,006.00 $1,536.22 $318,006.00 $1,536.22 $79,501.50 

1/6/22 11/1/21 – 

11/30/21 

$333,804.00 $8,207.39 $333,804.00 $8,207.39 $83,451.00 

1/27/22 12/1/21 – 

12/31/21 

$100,036.80 $560.40 $100,036.80 $560.40 $25,009.20 

2/24/22 1/1/22 – 

1/31/22 

$451,821.20 $6,228.00 $451,821.20 $6,228.00 $112,955.30 

Total $1,203,668.00 $16,532.01 $1,203,668.00 $16,532.01 $300,917.00 

Fifteenth Interim Fee Period (February 1, 2022 through May 31, 2022) 

4/15/22 2/1/22 – 

2/28/22 

$489,901.5021 $7,328.55 $489,901.50 $7,328.55 $122,475.38 

5/6/22 3/1/22 – 

3/31/22 

$567,123.20 $6,196.45 $567,123.20 $6,196.45 $141,780.80 

6/2/22 4/1/22 – 

4/30/22 

$652,095.20 $9,636.29 652,095.20 $9,636.29 $163,023.80 

6/30/22 5/1/22 – 

5/31/22 

$577,627.20 $9,228.34 $577,627.50 $9,228.34 $144,406.80 

Total $2,286,747.10 $32,389.63 $2,286,747.10 $32,389.63 $571,686.78

 

20 This amount reflects a credit of $192,268.03 for fee reductions pursuant to the order approving Paul Hastings’ 

Eleventh Interim Fee Application 

21 This amount reflects (a) a credit of $36,526.28 for fee reductions pursuant to the order approving Paul Hastings’ 

Twelfth Interim Fee Application and (b) a credit of 20,123.34 for fee reductions pursuant to the order approving 

Paul Hastings’ Thirteenth Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 11 of 58
9 

Date 

Submitted 

Monthly 

Period 

Covered 

Requested Fees 

(80%) 

Requested 

Expenses 

(100%) 

Fees Paid Expenses 

Paid 

20% Fee 

Holdback 

Sixteenth Interim Fee Period (June 1, 2022 through September 30, 2022)

8/11/22 6/1/22 – 

6/30/22 

$318,785.60 $1,219.84 $318,785.60 $1,219.84 $79,696.40 

8/31/22 7/1/22 – 

7/31/22 

$175,320.40 $2,233.54 $175,320.40 $2,233.54 $43,830.10 

10/14/22 8/1/22 – 

8/31/22 

$164,811.60 $2,124.83 $164,811.60 $2,124.83 $41,202.90 

10/28/22 9/1/22 – 

9/30/22 

$257,279.60 $1,778.58 -- -- $64,319.90 

Total $916,197.20 $7,356.79 $658,917.60 $5,578.21 $229,409.30 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 12 of 58
10 

PRIOR INTERIM FEE APPLICATIONS 

Date Filed 

[Docket 

No.] 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket 

No.] 

Fees Allowed and Paid Expenses Allowed 

and Paid 

12/15/17 

Docket No. 

2040 

6/26/17 -

9/30/17 

$9,345,478.50 $133,270.22 Docket 

No. 

2685 

Allowed:$9,264,712.49 

Paid: $7,476,382.40 

Authorized to be paid: 

$7,465,577.2022

Allowed:$111,344.06 

Paid: $133,270.22 

Authorized to be paid: 

$111,344.0623

3/19/18 

Docket No. 

2735 

10/1/17 – 

1/31/18 

$7,066,017.75 $95,462.43 Docket 

No. 

3279 

Allowed:$6,960,689.25 

Paid: $5,651,706.20 

Authorized to be paid: 

$5,651,706.20 

Allowed: 

$104,666.0924

Paid: $82,739.90 

Authorized to be paid: 

$82,739.93 

7/16/18 

Docket No. 

3568 

2/1/18 – 

5/31/18 

$8,676,112.75 $586,993.66 Docket 

No. 

5654 

Allowed:$8,576,523.01 

Paid: $6,938,954.20 

Authorized to be paid: 

$6,861,218.4125

Allowed:$583,256.46 

Paid: $586,993.66 

Authorized to be paid: 

$583,256.4626

11/16/18 

Docket No. 

4325 

6/1/18 – 

9/30/18 

$5,795,270.25 $201,725.65 Docket 

No. 

5654 

Allowed:$5,736,730.98 

Paid: $4,636,216.20 

Authorized to be paid: 

$4,589,384.7827

Allowed:$199,429.03 

Paid: $201,725.65 

Authorized to be paid: 

$199,429.0328

4/18/2019 

Docket No. 

5822 

10/1/18 – 

1/31/19 

$4,705,215.50 $95,438.11 Docket 

No. 

8189 

Allowed:$4,509,478.17 

Paid: $3,637,669.1929

Authorized to be paid: 

$3,566,595.4630

Allowed: $94,831.15 

Paid: $89,404.2931

Authorized to be paid: 

$88,797.3332

 

22 Reflects fee reductions in the amount of 80% of $13,507.00 (or $10,806.40), which was credited against 

amounts payable under the January 2018 fee statement. 

23 Reflects expense reductions in the amount of $21,926.16, which was credited against amounts payable under 

the January 2018 fee statement. 

24 Prior to application of a $21,926.16 credit for expense reductions pursuant to order approving Paul Hastings’ 

First Interim Fee Application. 

25 Reflects fee reductions in the amount of 80% of $99,589.74 (or $79,671.79), which was credited against 

amounts payable under the January 2019 fee statement. 

26 Reflects expense reductions in the amount of $3,737.20, which was credited against amounts payable under the 

January 2019 fee statement. 

27 Reflects fee reductions in the amount of 80% of $58,539.27 (or $46,831.42), which was credited against 

amounts payable under the January 2019 fee statement. 

28 Reflects expense reductions in the amount of $2,296.62, which was credited against amounts payable under the 

January 2019 fee statement. 

29 After giving effect to credits for fee reductions in the aggregate amount of 80% of $158,129.01 (or 

$126,503.21) pursuant to the orders approving Paul Hastings’ Third and Fourth Interim Fee Applications. 

30 Reflects fee reductions in the amount of 80% of $88,842.16 (or $71,073.73), which was credited against 

amounts payable under the June 2019 fee statement. Also, amount authorized to be paid is net of $126,503.21 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 13 of 58
11 

Date Filed 

[Docket 

No.] 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket 

No.] 

Fees Allowed and Paid Expenses Allowed 

and Paid 

7/15/19 

Docket No. 

8004 

2/1/19 – 

5/31/19 

$8,183,931.00 $182,540.62 Docket 

No. 

9687 

Allowed:$7,842,124.12 

Paid: $6,547,144.80 

Authorized to be paid: 

$6,430,643.1733

Allowed:$182,312.69 

Paid: $182,540.62 

Authorized to be paid: 

$182,084.7634

11/15/19 

Docket No. 

9219 

6/1/19 – 

9/30/19 

$7,465,708.00 $901,536.23 Docket 

No. 

12861 

Allowed:$7,135,691.63 

Paid: $5,901,492.6635

Authorized to be paid: 

$5,733,012.7136

Allowed:$384,942.38 

Paid: $900,929.2737

Authorized to be paid: 

$385,549.3438

3/16/20 

Docket No. 

12395 

10/1/19 – 

1/31/20 

$5,788,714.00 $281,132.48 Docket 

No. 

13824 

Allowed:$5,641,450.42 

Paid: $4,517,501.1739

Authorized to be paid: 

$4,455,794.7440

Allowed:$281,132.48 

Paid: $280,904.5541

Authorized to be paid: 

$281,033.3042

 

in credits for fee reductions pursuant to the orders approving Paul Hastings’ Third and Fourth Interim Fee 

Applications. 

31 After giving effect to credits for expense reductions in the aggregate amount of $6,033.82 pursuant to the orders 

approving Paul Hastings’ Third and Fourth Interim Fee Applications. 

32 Reflects expense reductions in the amount of $606.96, which was credited against amounts payable under the 

September 2019 fee statement. Also, amount authorized to be paid is net of $6,033.82 in credits for expense 

reductions pursuant to the orders approving Paul Hastings’ Third and Fourth Interim Fee Applications. 

33 Reflects fee reductions in the amount of 80% of $145,627.04 (or $116,501.63), which was credited against 

amounts payable under the December 2019 fee statement. 

34 Reflects expense reductions in the amount of $227.93, which was credited against amounts payable under the 

December 2019 fee statement. 

35 After giving effect to credits for fee reductions in the amount of $88,842.17 (or $71,073.74 after 20% reduction) 

pursuant to the order approving Paul Hastings’ Fifth Interim Fee Application. 

36 Reflects (a) fee reductions in the amount of 80% of $99,027.94 (or $79,222.35), which was credited against the 

amounts payable under the June 2020 fee statement and (b) deferral of fees in the amount of 80% of 

$111,572.00 (or $89,257.60), as agreed between Paul Hastings and the Fee Examiner. Also, amount authorized 

to be paid is net of $71,073.73 in credits for fee reductions pursuant to the order approving Paul Hastings’ Fifth 

Interim Fee Application. 

37 After giving effect to credits for expense reductions in the amount of $606.96 pursuant to the order approving 

Paul Hastings’ Fifth Interim Fee Application. 

38 Reflects (a) expense reductions in the amount of $548.31, which was credited against amounts payable under 

the June 2020 fee statement and (b) deferral of expenses in the amount of $515,438.58, as agreed between Paul 

Hastings and the Fee Examiner. Also, amount authorized to be paid is net of $606.96 in credits for expense 

reductions pursuant to the order approving Paul Hastings’ Fifth Interim Fee Application. 

39 After giving effect to credits for fee reductions in the amount of $145,627.04 (or $116,501.63 after 20% 

reduction) pursuant to the order approving Paul Hastings’ Sixth Interim Fee Application. 

40 Reflects fee reductions in the amount of 80% of $73,343.54 (or $58,674.83), which was credited against 

amounts payable under the June 2020 fee statement. Also, amount authorized to be paid is net of $116,501.63 

in credits for fee reductions pursuant to the order approving Paul Hastings’ Sixth Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 14 of 58
12 

Date Filed 

[Docket 

No.] 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket 

No.] 

Fees Allowed and Paid Expenses Allowed 

and Paid 

7/15/20 

Docket No. 

13682 

2/1/20 – 

5/31/20 

$4,788,916.50 $139,072.95 Docket 

No. 

15355 

Allowed:$4,633,541.85 

Paid: $3,831,133.20 

Authorized to be paid: 

$3,768,121.3443

Allowed:$139,072.95 

Paid: $139,072.95 

Authorized to be paid: 

$139,072.95 

11/16/20 

Docket No. 

15160 

6/1/20 – 

9/30/20 

$2,465,639.50 $150,285.59 Docket 

No. 

16592 

Allowed: $2,270,277.60 

Paid: $1,834,614.42 

Authorized to be paid: 

$1,704,950.0644

Allowed: $150,114.82 

Paid: $149,638.10 

Authorized to be paid: 

$149,467.3345

3/15/21 

Docket No. 

16067 

10/1/20 – 

1/31/21 

$1,861,843.00 $60,177.37 Docket 

No. 

17646 

Allowed:$1,635,017.44 

Paid: $1,489,474.40 

Authorized to be paid: 

$1,335,659.9846

Allowed: $60,177.37 

Paid: $60,177.37 

Authorized to be paid: 

$60,177.37 

7/15/21 

Docket No. 

17380 

2/1/21 – 

5/31/21 

$1,916,538.50 $78,760.38 Docket 

No. 

19500 

Allowed: $1,862,000.95 

Paid: $1,340,554.55 

Authorized to be paid: 

$1,311,333.5647

Allowed: $78,560.38 

Paid: $78,589.61 

Authorized to be paid: 

$78,560.3848

 

41 After giving effect to credits for expense reductions in the amount of $227.93 pursuant to the order approving 

Paul Hastings’ Sixth Interim Fee Application. 

42 Reflects expense reductions in the amount of $99.18, which was credited against amounts payable under the 

June 2020 fee statement. 

43 Reflects fee reductions in the amount of 80% of $78,764.83 (or $63,011.86), which was credited against 

amounts payable under the February 2021 fee statement. 

44 Reflects fee reductions in the amount of 80% of $162,080.45 (or $129,664.36), which was credited against 

amounts payable under the March 2021 fee statement. Also, amount authorized to be paid is net of $172,371.48 

in credits for fee reductions pursuant to the orders approving Paul Hastings’ Seventh and Eighth Interim Fee 

Applications. 

45 Reflects expense reductions in the amount of $170.77, which was credited against amounts payable under the 

March 2021 fee statement. Also, amount authorized to be paid is net of $647.49 in credits for expense 

reductions pursuant to the orders approving Paul Hastings’ Seventh and Eighth Interim Fee Applications. 

46 Reflects fee reductions in the amount of 80% of $192,268.03 (or $153,814.42), which was credited against 

amounts payable under the June 2021 fee statement. 

47 Reflects fee reductions in the amount of 80% of $36,526.28 (or $29,221.02), which was credited against 

amounts payable under the February 2022 fee statement. Also, the amount authorized to be paid is net of 

$240,845.28 in credits for fee reductions pursuant to the order approving Paul Hastings’ Ninth and Tenth 

Interim Fee Applications. 

48 Reflects expense reductions in the amount of $200.00, which was credited against amounts payable under the 

February 2022 fee statement. Also, the amount authorized to be paid is net of $170.77 in credits for expense 

reductions pursuant to the order approving Paul Hastings’ Tenth Interim Fee Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 15 of 58
13 

Date Filed 

[Docket 

No.] 

Period 

Covered 

Requested 

Fees 

Requested 

Expenses 

Order 

[Docket 

No.] 

Fees Allowed and Paid Expenses Allowed 

and Paid 

11/15/21 

Docket No. 

19238 

6/1/21 – 

9/30/21 

$1,950,268.00 $63,942.15 Docket 

No. 

20412 

Allowed: $1,910,232.82 

Paid: $1,406,400.01 

Authorized to be paid: 

$1,390,301.3049

Allowed: $63,942.15 

Paid: $63,942.15 

Authorized to be paid: 

$63,942.15 

5/26/22 

Docket No. 

21038 

10/1/21 – 

1/31/22 

$1,504,585.00 $16,532.01 Docket 

No. 

22727 

Allowed: $1,446,234.52 

Paid: $1,203,668.00 

Authorized to be paid: 

$1,171,327.8150

Allowed: $16,532.01 

Paid: $16,532.01 

Authorized to be paid: 

$16,532.01 

7/15/22 

Docket No. 

21520 

2/1/22 – 

5/31/22 

$2,915,083.50 $32,389.63 Docket 

No. 

22727 

Allowed: $2,774,140.87 

Paid: $2,286,747.10 

Authorized to be paid: 

$2,225,370.0651

Allowed: $32,389.63 

Paid: $32,389.63 

Authorized to be paid: 

$32,389.63 

 

49 Reflects fee reductions in the amount of 80% of $20,123.34 (or $16,098.67), which was credited against 

amounts payable under the February 2022 fee statement. Also, the amount authorized to be paid is net of 

$192,268.03 in credits for fee reductions pursuant to the order approving Paul Hastings’ Eleventh Interim Fee 

Applications. 

50 Reflects fee reductions in the amount of 80% of $40,425.24 (or $32,340.192), which will be credited against 

amounts payable under the October 2022 fee statement. 

51 Reflects fee reductions in the amount of 80% of $76,721.32 (or $61,377.06), which will be credited against 

amounts payable under the October 2022 fee statement. Also, the amount authorized to be paid is net of 

$56,649.62 in credits for fee reductions pursuant to the order approving Paul Hastings’ Twelfth and Thirteenth 

Interim Fee Applications. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 16 of 58
Hearing Date: February 1, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) 

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

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

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

 : 

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

 : 

Debtors.1

 : 

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

SIXTEENTH INTERIM APPLICATION OF PAUL HASTINGS LLP, COUNSEL TO 

OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR ALLOWANCE OF 

COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM 

JUNE 1, 2022 THROUGH SEPTEMBER 30, 2022 

 

1

 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number and the last four (4) 

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

(the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) 

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

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

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

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

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

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

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 17 of 58
TABLE OF CONTENTS 

Page 

PRELIMINARY STATEMENT .................................................................................................... 1

BACKGROUND ............................................................................................................................ 7

COMPENSATION AND REIMBURSEMENT REQUEST ....................................................... 16

SUMMARY OF SERVICES ........................................................................................................ 20

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

(Matter ID 00002) ................................................................................................. 21

II. PREPA (Matter ID 00006) ................................................................................... 24

III. HTA (Matter ID 00007) ........................................................................................ 26

IV. Mediation (Matter ID 00010)................................................................................ 28

ATTENDANCE AT HEARINGS ................................................................................................ 28

REPORT ON MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND 

COMMITTEE ............................................................................................................................... 29

ACTUAL AND NECESSARY DISBURSEMENTS .................................................................. 31

REQUESTED COMPENSATION SHOULD BE ALLOWED ................................................... 32

CONCLUSION ............................................................................................................................. 35

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 18 of 58
SUPPORTING DECLARATION, EXHIBITS, AND SCHEDULES 

SUPPORTING DECLARATION OF LUC A. DESPINS 

EXHIBIT A CUSTOMARY AND COMPARABLE COMPENSATION 

DISCLOSURES 

EXHIBIT B SUMMARY OF TIMEKEEPERS INCLUDED IN THIS APPLICATION 

EXHIBIT C BUDGETS AND STAFFING PLANS FOR APPLICATION PERIOD 

 EXHIBIT C-1 BUDGETS 

 EXHIBIT C-2 STAFFING PLANS 

EXHIBIT D SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

CATEGORY 

 EXHIBIT D-1 SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

CATEGORY AS COMPARED TO BUDGET 

 EXHIBIT D-2 SUMMARY OF EXPENSE REIMBURSEMENT REQUESTED BY 

CATEGORY 

EXHIBIT E BREAKDOWN OF COMPENSATION AND EXPENSE 

REIMBURSEMENT REQUESTED BY DEBTOR 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

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 19 of 58
1 

To the Honorable United States District Judge Laura Taylor Swain: 

Paul Hastings LLP (“Paul Hastings”), counsel to the Official Committee of Unsecured 

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

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

of 2016 (“PROMESA”),2 section 503(b) of Title 11, United States Code (the “Bankruptcy 

Code”) as made applicable to these cases by section 301(a) of PROMESA, Rule 2016 of the 

Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules” 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 Paul Hastings for the period from June 1, 2022 through and including September 

30, 2022 (the “Application Period”), and for reimbursement of its actual and necessary expenses 

incurred during the Application Period, respectfully represents: 

PRELIMINARY STATEMENT 

1. During the Application Period, Paul Hastings continued to handle numerous 

matters that were of critical importance to the interests of the Debtors and their creditors. Most 

importantly, during the Application Period, Paul Hastings led the Committee’s efforts to allow 

litigation to proceed on two threshold questions with respect to the PREPA bondholders’ legal 

entitlements, namely (1) the scope of the bondholders’ security interest and (2) the non-recourse 

nature of the PREPA bonds. While the Committee’s repeated requests were initially opposed by 

the Oversight Board (and overruled by the Court), the Oversight Board (and the Court) 

 

1

 Prior to August 25, 2017, the Committee was the official committee of unsecured creditors for the 

Commonwealth’s Title III case only. On August 25, 2017, the U.S. Trustee expanded the Committee’s role to 

also include the Title III cases of HTA, ERS, and PREPA. 

2

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

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 20 of 58
2 

ultimately agreed that litigation on these threshold questions should go forward—concurrently 

with continued mediation.3 At the same, during the Application Period, Paul Hastings 

participated in the PREPA mediation, analyzed legal issues pertinent to the claims and security 

interests asserted by holders and insurers of PREPA bonds, prepared related legal memoranda, 

and assisted London Economics International, LLC (“LEI”), the Committee’s financial advisor 

in the PREPA case, in preparing presentations in connection with the mediation.4

2. Separately, Paul Hastings continued to advise the Committee with respect to the 

HTA plan of adjustment (the “HTA Plan”), which was confirmed by the Court on October 12, 

2022. As the Court will recall, prior to the Application Period, on May 9, 2022, the Committee 

reached a global settlement with the Oversight Board regarding the terms of the HTA Plan.5 

During the Application Period, Paul Hastings reviewed and commented on the Oversight 

Board’s drafts of the HTA Plan, the related disclosure statement, the proposed confirmation 

order, the proposed findings of fact and conclusions of law, and the plan supplement (including 

an amended avoidance actions trust agreement). In addition, Paul Hastings reviewed numerous 

pleadings filed in response to the Oversight Board’s motion seeking approval of the disclosure 

statement and confirmation of the HTA Plan. 

 

3

 Summary judgment motions in that litigation were due on October 24, 2022. 

4

 Due to mediation confidentiality, Paul Hastings cannot further elaborate on the substance of these materials. In 

addition, Paul Hastings has redacted all references to specific mediation issues in its monthly fee statements 

attached to this Application. Paul Hastings will submit unredacted versions of such statements for the Court’s 

review, if the Court so requests. The Fee Examiner has received unredacted versions of such statements. 

5

 Among other things, pursuant to the settlement, the HTA Plan provides aggregate consideration to holders of 

allowed HTA general unsecured claims and allowed HTA convenience claims consisting of (a) cash in the 

amount of $48 million and (b) the net recoveries from certain avoidance actions to be pursued by the Avoidance 

Action Trust (established under the Commonwealth plan of adjustment). The cash consideration represents a 

92% increase over the $25 million that the Oversight Board had proposed under the prior version of the HTA 

Plan. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 21 of 58
3 

3. All the while, Paul Hastings has continued to advise the Committee on all issues 

bearing on the rights of unsecured creditors in these Title III cases and taken proactive steps to 

protect their rights, including by: 

a. reviewing the Oversight Board’s reports regarding the 

designation and status of claims in connection with the 

alternative dispute resolution (“ADR”) process and 

administrative claims reconciliation (“ACR”) process; 

b. holding regular Committee meetings and communicating 

regularly with Committee members regarding ongoing matters 

in the Title III cases; and 

c. monitoring hearings, pleadings filed, and orders entered in the 

Title III cases and related adversary proceedings (including, 

where appropriate, filing objections), and representing the 

Committee in hearings before the Court. 

4. Paul Hastings has continued to perform these services in an economic, effective, 

and efficient manner commensurate with the complexity and importance of the issues involved. 

For example, the work performed by Paul Hastings was carefully assigned to appropriate 

professionals or paraprofessionals according to the experience and level of expertise required for 

each particular task. Moreover, whenever possible, Paul Hastings sought to minimize the costs 

of Paul Hastings’ services to the Committee by utilizing talented junior attorneys and 

paraprofessionals to handle the more routine aspects of the assignments and by delegating, to the 

extent practicable, questions of Puerto Rico law to local counsel. 

5. In addition, a small core group of Paul Hastings attorneys was utilized for the vast 

majority of the work in these Title III cases to minimize the costs of intra-Paul Hastings 

communication and education about the cases. Notably, only two Paul Hastings attorneys 

telephonically attended the various hearings held during the Application Period, thereby 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 22 of 58
4 

minimizing the time billed on these hearings. This is to be contrasted with other firms that have 

several partners attending such hearings. 

6. Moreover, to the extent appropriate, Paul Hastings sought to work closely with 

counsel to the Oversight Board, counsel to the Oversight Board’s Special Claims Committee (the 

“Special Claims Committee”), counsel to the Puerto Rico Fiscal Agency and Financial Advisory 

Authority (“AAFAF”), and counsel for the official committee of retirees (the “Retiree 

Committee”) in order to eliminate unnecessary duplication and allocate tasks in an efficient 

manner. For example, with limited exceptions, the Committee did not become involved in 

addressing stay relief requests and, instead, deferred these matters to representatives of the 

Debtors. In addition, to the extent appropriate, the Committee joined in the relief sought by 

other parties (as opposed to incurring the cost of preparing its own standalone motions) or 

concluded that no pleading was necessary at all. The Committee has also continued to be very 

judicious in determining in which adversary proceedings to intervene, despite the First Circuit’s 

ruling affirming the Committee’s unconditional right to intervene in adversary proceedings.6

7. It also bears emphasizing that Paul Hastings’ fees for the Application Period (i.e., 

$916,197.20, net of 20% end-of-case reduction) were its lowest fee total for any interim fee 

period in these Title III case. 

8. Finally, we note that the blended attorney hourly rate ($975 after the 20% 

reduction) for the Application Period is not comparable to the average hourly rate of other 

professionals in these Title III cases. Importantly, the Firm’s blended attorney hourly rate does 

 

6

 Paul Hastings has agreed to reduce its total fees by an amount equal to 20% of the firm’s case fees (with the 

precise fees to be waived to attain the 20% reduction to be designated by Paul Hastings (in its sole discretion) in 

connection with the final fee application process). For the avoidance of doubt, at this time, Paul Hastings seeks 

allowance of $1,145,246.50 (i.e., 100% of fees for services rendered during the Application Period), but 

payment of fees in the amount of $916,197.20 (to the extent such amount has not been paid before the hearing 

scheduled on this Application). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 23 of 58
5 

not reflect the numerous cost-saving measures that were put in place, including deferring a 

variety of matters to the Committee’s local counsel, Casillas, Santiago & Torres LLC (“CST”), 

and the Committee’s special litigation counsel, Genovese, Joblove & Battista, P.A. 

(“Genovese”),7

 which have significantly lower rates than Paul Hastings. For example, Paul 

Hastings determined (with Committee approval) that all garden-variety avoidance actions should 

be handled by CST. Moreover, certain other adversary proceedings (such as the complaint 

against certain PREPA fuel suppliers) were being handled by Genovese (and are now being 

handled by Continental), even where Paul Hastings does not have a conflict. If it were not for 

these cost-saving measures, Paul Hastings would have used more junior attorneys for these tasks, 

which would have materially reduced the blended attorney hourly rate for the Application 

Period. Furthermore, Paul Hastings submits that concentrating work in small teams (that 

naturally involve more senior attorneys at higher rates) is more cost-efficient than spreading 

work out across large teams with numerous junior attorneys (which would have the effect of 

artificially lowering the blended hourly rate). By comparison, on average, the Paul Hastings core 

teams are half the size of other firms’ core teams. 

9. In sum, Paul Hastings respectfully submits that the services for which it seeks 

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

Debtors, and their stakeholders and were rendered to protect, preserve, and maximize the value 

for unsecured creditors during the pendency of these Title III cases. The results obtained to date 

have benefited not only the Committee but also the Debtors and their creditors. Accordingly, in 

 

7

 Earlier this year, three former Genovese lawyers who had been primarily responsible for the representation of 

the Committee as special litigation counsel joined the firm of Continental PLLC (“Continental”). The 

Committee approved Continental’s substitution for Genovese, effective as of February 14, 2022, as detailed in 

the Continental retention application, dated February 28, 2022 [Docket No. 20222], which the Court approved 

on March 18, 2022 [Docket No. 20407]. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 24 of 58
6 

light of the nature and complexity of these Title III cases, Paul Hastings’ charges for professional 

services performed and expenses incurred are reasonable under applicable standards. For all 

these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow 

interim compensation for professional services performed and reimbursement for expenses as 

requested. 

10. This 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”).8 To the 

extent necessary, Paul Hastings requests a waiver for cause shown of any requirements not met 

by this Application. 

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

the following Exhibits and Schedules: 

 Exhibit A contains disclosures regarding “customary and comparable 

compensation.” 

 Exhibit B contains a summary of Paul Hastings’ timekeepers included in this 

Application. 

 Exhibit C-1 contains the budgets for Paul Hastings’ services during the 

Application Period. 

 Exhibit C-2 contains the staffing plans for Paul Hastings’ services during the 

Application Period. 

 Exhibit D-1 contains a summary of the compensation requested as compared to 

the compensation budgeted for the firm’s services during the Application Period. 

 

8

 The Committee and Paul Hastings 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. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 25 of 58
7 

 Exhibit D-2 contains a summary of the expense reimbursements requested by 

category. An itemized schedule of all such expenses is included in Paul 

Hastings’ monthly statements. 

 Exhibit E contains a breakdown of compensation and expense reimbursement 

requested by Debtor 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 Application. 

 Schedule 3 includes the proposed order approving this Application. 

BACKGROUND 

12. 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 ERS Title III Case, and the HTA Title III Case, the “Title III Cases”).9 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. 

13. 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 

 

9

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

Case. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 26 of 58
8 

Creditors [Docket No. 338]. On June 26, 2017, the Committee selected Paul Hastings as counsel 

to the Committee. 

14. On July 10, 2017, the Committee filed an application to retain and employ Paul 

Hastings as counsel, effective June 26, 2017 [Docket No. 610] (the “Retention Application”). 

By order of this Court entered August 10, 2017 [Docket No. 999] (the “Retention Order”), 

incorporated herein by this reference, Paul Hastings’ retention as counsel to the Committee was 

approved effective as of June 26, 2017. 

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

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

Compensation Order”).10

16. 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. Paul Hastings’ 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 Paul 

Hastings, as counsel to the Committee, shall be deemed to apply to the representation of the 

Committee if ever enlarged to include unsecured creditors of other debtors, without the need to 

obtain a modification of this Order.” 

 

10 The Interim Compensation Order was most recently amended on June 24, 2022 [Docket No. 21334]. Because 

the Committee continues to remain in existence as to the Commonwealth and ERS cases until the order 

confirming the Commonwealth Plan becomes a Final Order, and the Committee also remains in existence as to 

the PREPA and HTA cases, this Application covers the period from June 1, 2022 through September 30, 2022 

for all four cases, in accordance with footnote 6 of the Third Amended Order Setting Procedures for Interim 

and Final Compensation and Reimbursement of Expenses of Professionals [Docket No. 20546], which 

provision was not revised by the June 24, 2022 amendment. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 27 of 58
9 

17. The Retention Order authorized Paul Hastings 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.11 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 Paul 

Hastings under this Order shall be an administrative expense.” In addition, as provided in the 

Retention Order, the Oversight Board has consented to the Debtors’ payment of Paul Hastings’ 

allowed fees and expenses. 

18. Paul Hastings has agreed to reduce its fees by an amount equal to 20% of its total 

case fees, with the precise fees to be waived to attain the 20% reduction to be designated by Paul 

Hastings (in its sole discretion) in connection with the final fee application process. For that 

reason, at this time Paul Hastings seeks payment of only 80% of its fees incurred during the 

Application Period, but allowance of 100% of such fees. Paul Hastings agreed to this reduction 

in reliance on the fact that the timing of the payment of Paul Hastings’ fees and expenses would 

be governed by Court orders which contained strict procedures and deadlines, and that such 

order would be complied with. 

19. On October 6, 2017, the Court entered the Order Pursuant to PROMESA 

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

Related Relief [Docket No. 1416] (the “Fee Examiner Order”). The Court appointed Brady 

Williamson as the Fee Examiner in the Title III Cases. 

 

11 Paragraph 2 of the Retention Order provides, among other things, that “Paul Hastings will charge its regular 

hourly rates in effected from time to time; as such rates may be increased periodically, annually or otherwise.” 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 28 of 58
10 

20. On December 15, 2017, Paul Hastings filed its first interim fee application with 

respect to the period from June 26, 2017 through September 30, 2017 [Docket No. 2040] (the 

“First Interim Fee Application”). In accordance with the Interim Compensation Order, Paul 

Hastings received a preliminary report from the Fee Examiner and agreed to certain adjustments 

in its requested fees and expenses.12 On March 7, 2018, the Court approved the First Interim Fee 

Application, with the agreed-upon adjustments. 

21. On March 19, 2018, Paul Hastings filed its second interim fee application with 

respect to the period from October 1, 2017 through January 31, 2018 [Docket No. 2735] (the 

“Second Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.13 On June 8, 

2018, the Court approved the Second Interim Fee Application, with the agreed-upon 

adjustments. 

22. On July 16, 2018, Paul Hastings filed its third interim fee application with respect 

to the period from February 1, 2018 through May 31, 2018 [Docket No. 3568] (the “Third 

Interim Fee Application”). Paul Hastings received a preliminary report from the Fee Examiner 

and agreed to certain adjustments in its requested fees and expenses.14 On March 14, 2019, the 

Court approved the Third Interim Fee Application, with the agreed-upon adjustments. 

 

12 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $67,259.01 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $13,507.00 (which amount was credited against Paul 

Hastings’ January 2018 fee statement), and (c) expense reductions in the amount of $21,926.16 (which amount 

also was credited against Paul Hastings’ January 2018 fee statement). 

13 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $103,943.50 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $1,385.00 (which amount was credited against Paul 

Hastings’ January 2018 fee statement), and (c) expense reductions in the amount of $12,722.50 (which amount 

also was credited against Paul Hastings’ January 2018 fee statement). 

14 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $125,338.14 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 29 of 58
11 

23. On November 16, 2018, Paul Hastings filed its fourth interim fee application with 

respect to the period from June 1, 2018 through September 30, 2018 [Docket No. 4325] (the 

“Fourth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.15 On March 14, 

2019, the Court approved the Fourth Interim Fee Application, with the agreed-upon adjustments. 

24. On March 18, 2019, Paul Hastings filed its fifth interim fee application with 

respect to the period from October 1, 2018 through January 31, 2019 [Docket No. 5822] (the 

“Fifth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.16 On July 23, 

2019, the Court approved the Fifth Interim Fee Application, with the agreed-upon adjustments. 

25. On July 15, 2019, Paul Hastings filed its sixth interim fee application with respect 

to the period from February 1, 2019 through May 31, 2019 [Docket No. 8004] (the “Sixth 

Interim Fee Application”). Paul Hastings received a preliminary report from the Fee Examiner 

and agreed to certain adjustments in its requested fees and expenses.17 On January 2, 2020, the 

Court approved the Sixth Interim Fee Application, with the agreed-upon adjustments. 

 

application, (b) additional fee reductions in the amount of $99,589.74 (which amount was credited against Paul 

Hastings’ January 2019 fee statement), and (c) expense reductions in the amount of $3,737.20 (which amount 

also was credited against Paul Hastings’ January 2019 fee statement). 

15 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $69,137.26 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $58,539.27 (which amount was credited against Paul 

Hastings’ January 2019 fee statement), and (c) expense reductions in the amount of $2,296.62 (which amount 

also was credited against Paul Hastings’ January 2019 fee statement). 

16 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $106,895.16 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $88,842.17 (which amount was credited against Paul 

Hastings’ June 2019 fee statement), and (c) expense reductions in the amount of $606.96 (which amount also 

was credited against Paul Hastings’ September 2019 fee statement). 

17 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $196,179.84 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $145,627.04 (which amount was credited against Paul 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 30 of 58
12 

26. On November 15, 2019, Paul Hastings filed its seventh interim fee application 

with respect to the period from June 1, 2019 through September 30, 2019 [Docket No. 9219] (the 

“Seventh Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.18 On April 17, 

2020, the Court approved the Seventh Interim Fee Application, with the agreed-upon 

adjustments. 

27. On March 16, 2020, Paul Hastings filed its eighth interim fee application with 

respect to the period from October 1, 2019 through January 31, 2020 [Docket No. 12395] (the 

“Eighth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.19 On July 24, 

2020, the Court approved the Eighth Interim Fee Application, with the agreed-upon adjustments. 

28. On July 15, 2020, Paul Hastings filed its ninth interim fee application with respect 

to the period from February 1, 2020 through May 31, 2020 [Docket No. 13682] (the “Ninth 

Interim Fee Application”). Paul Hastings received a preliminary report from the Fee Examiner 

 

Hastings’ December 2019 fee statement), and (c) expense reductions in the amount of $227.93 (which amount 

also was credited against Paul Hastings’ December 2019 fee statement). 

18 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $119,416.43 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $99,027.94 (which amount was credited against Paul 

Hastings’ June 2020 fee statement), and (c) expense reductions in the amount of $548.31 (which amount also 

will be credited against Paul Hastings’ June 2020 fee statement). In addition, Paul Hastings and the fee 

examiner agreed to provisionally defer (a) $111,572.00 in Paul Hastings’ fees related to the expert report 

prepared by London Economics International, LLC (“LEI”) and (b) $515,438.58 in expenses related to the 

expert report prepared by LEI. 

19 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $73,920.04 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $73,343.54 (which amount was credited against Paul 

Hastings’ June 2020 fee statement), and (c) expense reductions in the amount of $99.18 (which amount also 

was credited against Paul Hastings’ June 2020 fee statement). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 31 of 58
13 

and agreed to certain adjustments in its requested fees and expenses.20 On December 7, 2020, 

the Court approved the Ninth Interim Fee Application, with the agreed-upon adjustments. 

29. On November 16, 2020, Paul Hastings filed its tenth interim fee application with 

respect to the period from June 1, 2020 through September 30, 2020 [Docket No. 15160] (the 

“Tenth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.21 On April 27, 

2021, the Court approved the Tenth Interim Fee Application, with the agreed-upon adjustments. 

30. On March 15, 2021, Paul Hastings filed its eleventh interim fee application with 

respect to the period from October 1, 2020 through January 31, 2021 [Docket No. 16067] (the 

“Eleventh Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.22 On August 3, 

2021, the Court approved the Eleventh Interim Fee Application, with the agreed-upon 

adjustments. 

31. On July 15, 2021, Paul Hastings filed its twelfth interim fee application with 

respect to the period from February 1, 2021 through May 31, 2021 [Docket No. 17380] (the 

“Twelfth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

 

20 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $76,609.82 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $78,764.83 (which amount were credited against Paul 

Hastings’ February 2021 fee statement). 

21 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $33,281.45 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application, (b) additional fee reductions in the amount of $162,080.45 (which amount was credited against Paul 

Hastings’ March 2021 fee statement), and (c) expense reductions in the amount of $170.77 (which amount also 

was credited against Paul Hastings’ March 2021 fee statement). 

22 These agreed-upon adjustments consisted of (a) fee reductions in the amount of $34,557.53 to be included 

within the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee 

application and (b) additional fee reductions in the amount of $192,268.03 (which amount was credited against 

Paul Hastings’ June 2021 fee statement). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 32 of 58
14 

Examiner and agreed to certain adjustments in its requested fees and expenses.23 On December 

13, 2021, the Court approved the Twelfth Interim Fee Application, with the agreed-upon 

adjustments. 

32. On November 15, 2021, Paul Hastings filed its thirteenth interim fee application 

with respect to the period from June 1, 2021 through September 30, 2021 [Docket No. 19238] 

(the “Thirteenth Interim Fee Application”). Paul Hastings received a preliminary report from the 

Fee Examiner and agreed to certain adjustments in its requested fees and expenses.24 On March 

18, 2022, the Court approved the Thirteenth Interim Fee Application, with the agreed-upon 

adjustments. 

33. On May 26, 2022, Paul Hastings filed its fourteenth interim fee application with 

respect to the period from October 1, 2021 through January 31, 2022 [Docket No. 21038] (the 

“Fourteenth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.25 On October 28, 

2022, the Court approved the Fourteenth Interim Fee Application, with the agreed-upon 

adjustments. 

 

23 These agreed-upon adjustments consist of (a) fee reductions in the amount of $18,011.28 to be included within 

the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee application, 

(b) additional fee reductions in the amount of $36,526.28 (which amount was credited against Paul Hastings’ 

February 2022 fee statement) and (c) expense reductions in the amount of $200.00 (which amount also was 

credited against Paul Hastings’ February 2022 fee statement). 

24 These agreed-upon adjustments consist of (a) fee reductions in the amount of $19,911.84 to be included within 

the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee application 

and (b) additional fee reductions in the amount of $20,123.34 (which amount was credited against Paul 

Hastings’ February 2022 fee statement). 

25 These agreed-upon adjustments consist of (a) fee reductions in the amount of $17,925.24 to be included within 

the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee application 

and (b) additional fee reductions in the amount of $40,425.24 (which amount will be credited against Paul 

Hastings’ October 2022 fee statement). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 33 of 58
15 

34. On July 15, 2022, Paul Hastings filed its fifteenth interim fee application with 

respect to the period from February 1, 2022 through May 31, 2022 [Docket No. 21520] (the 

“Fifteenth Interim Fee Application”). Paul Hastings received a preliminary report from the Fee 

Examiner and agreed to certain adjustments in its requested fees and expenses.26 On October 28, 

2022, the Court approved the Fifteenth Interim Fee Application, with the agreed-upon 

adjustments. 

35. On January 19, 2022, the Court entered an order [Docket No. 19813] confirming 

the 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 (the “Commonwealth Plan”). The Effective 

Date of the Commonwealth Plan occurred on March 15, 2022. Pursuant to §90.1 of the 

Commonwealth 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 Commonwealth Plan did not affect the continued existence of the Committee 

in the PREPA and HTA cases. 

36. On October 12, 2022, the Court entered an order [Docket No. 22582] confirming 

the Modified Fifth Amended Title III Plan of Adjustment of the Puerto Rico Highways and 

Transportation Authority, dated September 6, 2022 [Docket No. 1404 in Case No. 17-3567] (as 

amended, supplemented, or modified prior, at, or subsequent to the HTA confirmation hearing, 

including the plan supplement, and as may be amended, supplemented, or modified pursuant to 

 

26 These agreed-upon adjustments consist of (a) fee reductions in the amount of $64,221.31 to be included within 

the agreed overall 20% reduction in total fees sought by Paul Hastings LLP as part of its final fee application 

and (b) additional fee reductions in the amount of $76,721.32 (which amount was credited against Paul 

Hastings’ October 2022 fee statement). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 34 of 58
16 

section 313 of PROMESA, the “HTA Plan”). The Effective Date of the HTA Plan has not yet 

occurred. 

COMPENSATION AND REIMBURSEMENT REQUEST 

37. By this Application, Paul Hastings seeks allowance of compensation for 

professional services rendered to the Committee during the Application Period in the aggregate 

amount of $1,145,246.5027 and expense reimbursements in the aggregate amount of $7,356.79. 

These amounts are allocated among the Commonwealth Title III Case, the HTA Title III Case, 

the ERS Title III Case, and the PREPA Title III Case, as follows: 

Application Period Fees Expenses Total 

Commonwealth Title III Case $316,629.5028 $2,702.97 $319,332.47 

HTA Title III Case $170,719.00 $1,640.61 $172,359.61 

ERS Title III Case $0.00 $0.00 $0.00 

PREPA Title III Case $657,898.00 $3,013.21 $660,911.21 

Total $1,145,246.50 $7,356.79 $1,152,603.29 

38. The Committee has approved the amounts requested by Paul Hastings for services 

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

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

Period. All services for which compensation is requested herein were performed for or on behalf 

 

27 As noted, Paul Hastings has agreed to reduce its fees by an amount equal to 20% of its total case fees, with the 

precise fees to be waived to attain the 20% reduction to be designated by Paul Hastings (in its sole discretion) in 

connection with the final fee application process. Accordingly, the firm only seeks payment, at this time, of 

fees in the amount of $916,197.20 (to the extent such amount has not been paid before the hearing scheduled on 

this Application), which is 80% of $1,145,246.50). 

28 For the Application Period, the Commonwealth-related fees relate to: (a) PRRADA disclosures and professional 

fee applications ($141,663.50); (b) general pleadings review and preparation of related Committee update 

emails ($117,983.00); (c) preparation for, and attendance at, omnibus hearings ($17,652.00); (d) claims 

administration matters ($11,070.00); (e) post-effective date work with respect to the Commonwealth Plan, 

including the appeals of the confirmation order ($2,337.00); and (f) other case administrative matters, including 

maintaining case calendars and task lists ($14,039.50). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 35 of 58
17 

of the Committee. Moreover, as detailed on Exhibit D hereto, the aggregate amount of fees 

incurred by Paul Hastings during the Application Period was well below the fees budgeted. 

39. To date, Paul Hastings has received payments totaling $664,495.81 for services 

rendered during the Application Period, which amount consists of (a) $658,917.60 representing 

80% of the fees for services invoiced during the period from June 1, 2022 through August 31, 

2022 and (b) $5,578.21 (representing 100% of expenses invoiced for the same period). As of the 

date of this Application, the amount of $259,058.18 remains unpaid, which amount consists of 

(a) $257,279.60 (representing 80% of the fees for services invoiced during the period from 

September 1, 2022 through September 30, 2022 and (b) $1,778.58 (representing 100% of 

expenses invoiced for the same period). 

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

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

rendered during the Application Period. By this Application, Paul Hastings requests allowance 

of all fees and expenses incurred for services rendered during the Application Period. At this 

time, however, Paul Hastings seeks payment of only (a) 80% of the fees for services invoiced 

during the Application Period and (b) 100% of expenses invoiced during the Application Period. 

41. In addition, as a courtesy to the Committee and based on circumstances unique to 

the Title III Cases, during the Application Period Paul Hastings voluntarily waived fees totaling 

$15,037.50. The time billed by these timekeepers was reasonable, and Paul Hastings 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 Paul Hastings’ fees and expenses. Additionally, Paul Hastings did not increase the 

hourly rates of timekeepers working on the Puerto Rico matter as of June 1, 2022 and, instead, 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 36 of 58
18 

maintained the pre-June 1, 2022 rates for the Application Period (even though hourly rates 

increased on a firm-wide basis as of June 1, 2022). This translates into an additional $26,498.00 

in fees that Paul Hastings voluntarily agreed to forgo. Paul Hastings also voluntarily waived 

expenses totaling $117.20 as a courtesy to the Committee during the Application Period. For 

details regarding the waived fees and expenses, please see the Declaration of Luc A. Despins 

filed concurrently herewith. 

42. There is no agreement or understanding between Paul Hastings and any other 

person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of 

compensation to be received for services rendered in these cases. 

43. Paul Hastings maintains computerized records, in the form of monthly statements, 

of the time spent by all Paul Hastings’ attorneys and paraprofessionals in connection with its 

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

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

rendered, a detailed, 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. 

44. The fees charged by Paul Hastings in the Title III Cases are billed in accordance 

with its existing billing rates and procedures in effect during the Application Period with certain 

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

Cases, Paul Hastings agreed to continue to charge a reduced rate for the services of the following 

attorney during the Application Period (adjusted to reflect, on a pro forma basis, the 20% end-ofcase reduction): 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 37 of 58
19 

Attorney Standard 2022 Rate 

(adjusted to reflect 20% 

end-of-case reduction)29

Reduced 2022 Rate (adjusted to 

reflect 20% end-of-case 

reduction)

Luc A. Despins $1460 $1,360 

Subject to the foregoing exceptions, the rates Paul Hastings charges for the services rendered by 

its professionals and paraprofessionals in the Title III Cases are comparable to the rates Paul 

Hastings charges for professional and paraprofessional services rendered in comparable 

nonbankruptcy related matters. Moreover, when Paul Hastings’ restructuring professionals and 

paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. 

Such fees are reasonable based on the customary compensation charged by comparably skilled 

practitioners in comparable nonbankruptcy cases in a competitive national legal market. 

45. Paul Hastings’ rates are set at a level designed to fairly compensate Paul Hastings 

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

Paul Hastings operates in a complicated 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, Paul Hastings set its rates for attorneys and paraprofessionals both in the 

restructuring group and other practice 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, Paul Hastings endeavors 

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

principal competitor firms. 

 

29 For purposes of this table, the Standard 2022 Rate is the pre-June 1, 2022 rate, i.e., prior to the firm-wide rate 

increases on June 1, 2022. As noted above, Paul Hastings did not implement this rate increase in the Title III 

Cases. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 38 of 58
20 

46. Paul Hastings’ professional services during the Application Period required an 

aggregate expenditure of 1008.40 recorded hours by Paul Hastings’ attorneys and 

paraprofessionals, broken down as follows: partners (143.20 hours), counsel (420.80 hours), 

associates (354.30 hours), and paraprofessionals (90.10 hours). During the Application Period, 

Paul Hastings’ billing rates for attorneys rendering services in this matter ranged from [$745 to 

$1,745] per hour (before the application of any fee reductions). 

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

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

preparation of this Application, or Paul Hastings has for any other reason not sought 

compensation or reimbursement with respect to such services or expenses, Paul Hastings 

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

such expenses, in a supplemental or future application. 

SUMMARY OF SERVICES 

48. During the Application Period, Paul Hastings assisted and advised the Committee 

on a regular basis regarding legal matters relating to the restructuring of the Debtors, including 

related adversary proceedings, and all other matters arising in the performance of the 

Committee’s duties. In addition, Paul Hastings has prepared various motions, applications, 

orders, and other pleadings submitted to the Court for consideration, and has performed the 

necessary professional services that are described below and in the monthly statements attached 

hereto as Schedule 2.30 For ease of reference and transparency purposes, Paul Hastings created 

 

30 The description of services in this Application is limited to those matters in which Paul Hastings provided 

five (5) or more hours of service during the Application Period. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 39 of 58
21 

several matter numbers for its representation of the Committee. The matter numbers are divided 

by Debtor and/or large tasks the Committee undertook, as follows: 

Matter ID Matter Name 

00002 Official Committee of Unsecured Creditors 

00004 Communications with Creditors (other than 

Committee Members) 

00006 PREPA 

00007 HTA 

00009 Other Adversary Proceedings 

00010 Mediation 

00012 Creditors’ Committee Meetings 

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

(Matter ID 00002) 

(a) Case Administration (Task Code B110) 

Fees: $14,039.50 Total Hours: 19.40 

49. During the Application Period, Paul Hastings continued to advise the Committee 

on general case administration. In order to efficiently track deadlines, organize documents, and 

manage work streams, Paul Hastings maintained a global task list and case calendar. Further, 

Paul Hastings coordinated internally and with the Committee’s financial advisor, Zolfo Cooper 

LLP (“Zolfo Cooper”) regarding Committee communications, case strategy, and work streams. 

Paul Hastings also communicated with certain Committee members and others in connection 

with the administration of the Title III Cases. 

50. Furthermore, Paul Hastings undertook a variety of other tasks related to case 

administration, such as handling administrative matters in connection with the filing and service 

of pleadings. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 40 of 58
22 

(b) Pleadings Review (Task Code B113) 

Fees: $29,548.00 Total Hours: 43.10 

51. During the Application Period, Paul Hastings continued to review and prepare 

summaries of pleadings filed and orders entered in the Title III Cases for internal review and 

review by the Committee. 

(c) Meetings of and Communications with Creditors (Task Code B150) 

Fees: $89,172.50 Total Hours: 97.20 

52. During the Application Period, Paul Hastings continued to prepare reports and 

summaries to keep the Committee apprised of relevant developments in the Title III Cases and 

related adversary proceedings. 

(d) Court Hearings (Task Code B155) 

Fees: $23,257.00 Total Hours: 24.10 

53. During the Application Period, Paul Hastings attended, (a) the June 29, 2022 

omnibus hearing, at which hearing Paul Hastings observed the proceedings but did not address 

the Court, (b) the August 17, 2022 omnibus hearing, at which Paul Hastings addressed the Court, 

including with respect to the Oversight Board’s motion to extend time to object to proofs of 

claim, and (c) the September 28, 2022 omnibus hearing, at which hearing Paul Hastings 

addressed the Court, including with respect to the Oversight Board’s motion to establish a 

litigation schedule with respect to its challenges to the PREPA bond claims. 

54. In preparation for these hearings, Paul Hastings also reviewed relevant issues 

raised in the parties’ pleadings and filed the requisite informative motions to be heard. In 

addition, Paul Hastings observed the Oversight Board’s public meeting on July 1, 2022. 

(e) Fee/Employment Applications (Paul Hastings) (Task Code B160) 

Fees: $128,445.00 Total Hours: 120.60 

55. During the Application Period, Paul Hastings prepared, among other things, five 

monthly fee statements for services provided during the months of April 2022 through August 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 41 of 58
23 

2022, the Fifteenth Interim Fee Application, and portions of this Application. In addition, and in 

accordance with the Bankruptcy Code, the Bankruptcy Rules, the Puerto Rico Recovery 

Accuracy in Disclosures Act (the “PRRADA”), and the Court’s related orders [Docket Nos. 

19859, 19980, 20419, and 20467], Paul Hastings continued to identify possible connections 

between the firm and parties in interest in the Title III Cases and prepared its twelfth 

supplemental declaration and portions of its thirteenth supplemental declaration of Luc A. 

Despins regarding the firm’s retention as Committee counsel. Paul Hastings also reviewed 

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

Examiner and his counsel to address questions regarding Paul Hastings’ interim fee applications. 

(f) Fee/Employment Applications for Other Professionals (Task Code B165) 

Fees: $ 13,218.50 Total Hours: 17.30 

56. During the Application Period, Paul Hastings assisted the Committee’s other 

professionals, including the Committee financial advisor, Zolfo Cooper, and the Committee’s 

communications advisor, Kroma Advertising, Inc. (“Kroma”), with their fee applications, as well 

Committee members with expense reimbursement requests. Paul Hastings also handled other 

matters related to the employment of professionals, including disclosures under PRRADA. 

(g) Claims Administration and Objections (Task Code B310) 

Fees: $11,070.00 Total Hours: 12.20 

57. During the Application Period, Paul Hastings prepared the Committee’s limited 

response to the Oversight Board’s motion to extend time to object to proofs of claims against the 

Commonwealth, ERS, and PBA, requesting that the Court condition the requested extension on 

the Oversight Board setting forth a timeline to complete the claims reconciliation process. While 

the Court did not impose such a condition, the Court did require the Oversight Board to provide 

additional details in its future status reports regarding the progress in the claims reconciliation 

process. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 42 of 58
24 

II. PREPA (Matter ID 00006) 

(a) Meetings and Communications with Creditors (Task Code B150) 

Fees: $84,956.00 Total Hours: 81.60 

58. During the Application Period, Paul Hastings provided numerous updates to the 

Committee regarding developments in the PREPA case, including as it relates to the litigation 

challenging the PREPA bondholders’ claims and security interest. In addition, Paul Hastings 

handled numerous update calls with the Committee on these matters. 

(b) Court Hearings (Task Code B155) 

Fees: $25,353.00 Total Hours: 19.20 

59. During the Application Period, Paul Hastings attended the September 28, 2022 

omnibus hearing, at which hearing Paul Hastings addressed the Court, including with respect to 

the Oversight Board’s motion to establish a litigation schedule with respect to its challenges to 

the PREPA bond claims. In preparation for these hearings, Paul Hastings also reviewed relevant 

issues raised in the parties’ pleadings. 

(c) General Litigation (Task Code B191) 

Fees: $138,903.00 Total Hours: 102.90 

60. During the Application Period, Paul Hastings advised the Committee on 

numerous litigation matters related to the PREPA case. Following termination of the PREPA 

mediation on September 16, 2022, the Oversight Board sought approval of a litigation schedule 

to adjudicate two threshold questions with respect to the PREPA bondholders’ legal entitlements, 

namely (1) the scope of the bondholders’ security interest and (2) the non-recourse nature of the 

PREPA bonds. At the same time, the Mediation Team also requested approval of certain 

amendments to the mediation order, including a further extension of the mediation outside date, 

so that mediation could continue concurrently with litigation. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 43 of 58
25 

61. In response to the foregoing, Paul Hastings prepared (a) the Committee’s 

statement in response to the termination of the PREPA mediation, (b) the Committee’s limited 

response to the Oversight Board’s motion to establish a litigation schedule, and (c) the 

Committee’s objection to the proposed amendments to the PREPA mediation order. In general, 

the Committee was (and remains) supportive of the Oversight Board’s sequencing of the PREPA 

bondholder litigation—although, at the time, the Committee reserved its right regarding the 

scope of its participation rights in that litigation.31 As it relates to the amendments to the 

mediation order, the Committee raised a number of concerns, including as it relates to the 

concept of a “toggle” plan of adjustment that would take into consideration alternative outcomes 

in the ongoing litigation. 

62. On September 27, 2022, the Court entered an order approving the Oversight 

Board’s proposed litigation schedule (with certain modifications) and, separately, amended the 

mediation order to allow mediation to continue concurrently with litigation.32

(d) Claims Administration and Objections (Task Code B310) 

Fees: $8,230.00 Total Hours: 6.50 

63. During the Application Period, Paul Hastings continued its analysis of PREPA 

general unsecured claims, as well as prepared and filed a status report in the Committee’s appeal 

before the First Circuit regarding its objection to the PREPA bond claims. 

(e) Restructuring (Task Code B420) 

Fees: $122,460.00 Total Hours: 88.50 

64. During the Application Period, Paul Hastings prepared three limited objection to 

the Oversight Board’s various requests to extend the outside mediation date and extend the 

 

31 The scope of the Committee’s participation rights was subsequently addressed in a stipulation between the 

parties. 

32 The Court also required the Oversight Board to propose a “toggle” plan by December 1, 2022. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 44 of 58
26 

Oversight Board’s deadline to file their proposal for the “path forward” in PREPA’s Title III 

case. While the Committee did not oppose an extension of mediation, the Committee argued 

that, concurrently with ongoing mediation, the Oversight Board should submit a proposed 

litigation schedule. The Court overruled the Committee’s limited objections; however, as noted 

above, the Court ultimately agreed that litigation on threshold questions as to the PREPA 

bondholders’ legal entitlements (namely, the scope of their security interest and the non-recourse 

nature of their claims) should go forward. 

65. In addition, during the Application Period, Paul Hastings continued to update the 

Committee’s financial advisor on PREPA matters (i.e., LEI) regarding PREPA-related 

developments. 

III. HTA (Matter ID 00007) 

(a) Meetings and Communications with Creditors (Task Code B150) 

Fees: $6,500.50 Total Hours: 5.80 

66. During the Application Period, Paul Hastings worked with the Committee’s 

communications advisor (i.e., Kroma) to update the Committee’s website to reflect recent 

developments with respect to the HTA Plan. In addition, Paul Hastings worked with the 

Committee’s local Puerto Rico counsel (i.e., CST) to reach out to HTA general unsecured 

creditors to advise them that the Committee recommended that HTA general unsecured creditors 

vote to accept the HTA Plan. 

(b) Court Hearings (Task Code B155) 

Fees: $38,000.00 Total Hours: 31.10 

2. During the Application Period, Paul Hastings attended, (a) the June 17, 2022 

hearing on the approval of the disclosure statement for the HTA Plan, at which hearing Paul 

Hastings observed the proceedings but did not address the Court, (b) the August 8, 2022 pre-trial 

conference with respect to the hearing on confirmation of the HTA Plan, at which conference 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 45 of 58
27 

Paul Hastings observed the proceedings but did not address the Court, and (c) the August 17, 

2022 hearing on confirmation of the HTA Plan, at which hearing Paul Hastings addressed the 

Court in support of such confirmation. 

3. In preparation for these hearings, Paul Hastings also reviewed relevant issues 

raised in the parties’ pleadings and filed the requisite informative motions to be heard. 

(c) Assumption/Rejection of Leases and Contracts (Task Code B185) 

Fees: $15,814.50 Total Hours: 12.80 

67. During the Application Period, Paul Hastings analyzed issues related to the 

rejection of HTA contracts and leases and the treatment of rejection damages claims related to 

same. 

(f) Working Travel (Task Code B195) 

Fees: $8,850.00 Total Hours: 12.00 

4. During the Application Period, one Paul Hastings attorney travelled to San Juan, 

Puerto Rico, to attend the August 17, 2022 hearing on confirmation of the HTA Plan. 

(d) Plan and Disclosure Statement (including Business Plan) (Task Code B320) 

Fees: $98,377.50 Total Hours: 76.30 

68. Following the conclusion of the confirmation hearings on the Commonwealth 

Plan, Paul Hastings continued to focus its attention on the treatment of HTA general unsecured 

creditors under the HTA Plan. Ultimately, the Committee and the Oversight Board reached a 

settlement regarding the treatment of HTA general unsecured creditors, which settlement was 

memorialized in the letter agreement, dated May 9, 2022. 

69. During the Application Period, Paul Hastings reviewed and commented on the 

Oversight Board’s drafts of the HTA Plan, the related disclosure statement, the proposed 

confirmation order, the proposed findings of fact and conclusions of law, and the plan 

supplement (including an amended avoidance actions trust agreement). In addition, Paul 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 46 of 58
28 

Hastings reviewed numerous pleadings filed in response to the Oversight Board’s motion 

seeking approval of the disclosure statement and confirmation of the HTA Plan. Paul Hastings 

also prepared reservation of rights with respect to the foregoing. 

70. Ultimately, the HTA Plan was confirmed on October 12, 2022. 

IV. Mediation (Matter ID 00010) 

(a) Restructuring (Task Code B420) 

Fees: $267,432.50 Total Hours: 221.20 

71. During the Application Period, Paul Hastings prepared for and participated in the 

PREPA mediation directed by the Court pursuant to its orders, dated April 8, 2022 [Docket No. 

20526 and 20527]. Among other things, Paul Hastings conducted legal research, prepared 

related analyses for mediation, and communicated with the mediation team. Due to mediation 

confidentiality restrictions, Paul Hastings cannot publicly disclose the substance of the issues 

addressed in mediation.33

ATTENDANCE AT HEARINGS 

72. 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”), Paul Hastings provides 

the following summary regarding the attendance of Paul Hastings professionals at Court 

hearings:34

 June 17, 2022: The June 17, 2022 omnibus hearing on the approval of the HTA 

disclosure statement, which was held remotely, was attended telephonically by 

 

33 In addition, Paul Hastings has redacted all references to specific mediation issues in its monthly fee statements 

attached to this Application. Paul Hastings will submit unredacted versions of such statements for the Court’s 

review, if the Court so requests. The Fee Examiner has received unredacted versions of such statements. 

34 Among other things, the Presumptive Standards Order provides that “[f]or attendance at hearings in which a 

professional anticipates a speaking role, fees and expenses incurred for attendance by timekeepers other than 

those with meaningful speaking roles (plus one additional timekeeper per speaker) are not compensable.” 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 47 of 58
29 

Mr. Despins, Mr. Bongartz, and Mr. Maza. Paul Hastings submits that given 

Mr. Maza’s significant involvement on matters related to confirmation of the 

HTA plan of adjustment, his attendance at the HTA disclosure statement hearing 

was reasonable. 

 June 29, 2022: The June 29, 2022 omnibus hearing, which was held remotely, 

was attended telephonically by Mr. Despins and Mr. Bongartz. 

 August 8, 2022: The August 8, 2022 pre-trial conference for the HTA 

confirmation hearing, which pre-trial conference was held remotely, was 

attended telephonically by Mr. Bongartz. 

 August 17, 2022: The August 17, 2022 hearing on confirmation of the HTA 

plan of adjustment, which was held in person in San Juan, Puerto Rico, was 

attended by Mr. Bongartz in person, as well as telephonically by Mr. Despins 

and Mr. Bassett. Paul Hastings submits that given Mr. Bassett’s significant 

involvement on matters related to confirmation of the HTA plan of adjustment, 

his attendance at the HTA disclosure statement hearing was reasonable. 

 August 17, 2022: The August 17, 2022 omnibus hearing, which was held in 

person in San Juan, Puerto Rico, was attended by Mr. Bongartz in person, as 

well as telephonically by Mr. Despins. 

 September 28, 2022: The September 28, 2022 omnibus hearing on the approval 

of the HTA disclosure statement, which was held remotely, was attended 

telephonically by Mr. Despins, Mr. Bongartz, and Mr. Maza. Paul Hastings 

submits that given Mr. Maza’s significant involvement on matters related to 

confirmation of the challenge to the PREPA bond claims, his attendance at the 

September 28, 2022 hearing (which include the hearing on the Oversight 

Board’s motion to approve a litigation schedule for its challenge to the PREPA 

bond claims) was reasonable. 

REPORT ON MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND 

COMMITTEE 

73. As requested by the Fee Examiner, we set forth below the status of the 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 stipulations for 

the joint prosecution of causes of action or claims objections. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 48 of 58
30 

 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. 

 Adversary Proceeding Against Underwriters, etc.: Prior to the effective date of 

the Commonwealth Plan, Continental, the Committee’s special litigation counsel, 

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]. Paul Hastings had no involvement in this 

adversary proceeding. Moreover, pursuant to 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. 

 Garden-Variety Avoidance Actions: Prior to the effective date of the 

Commonwealth Plan, the “garden-variety” avoidance actions were handled by 

CST, the Committee’s local counsel. Paul Hastings’ involvement in these 

avoidance actions was limited to reviewing and commenting on draft forms of 

pleadings or “case management” pleadings, and providing high-level oversight 

and direction with respect to these adversary proceedings. Pursuant to the 

Commonwealth Plan, the “garden-variety” avoidance actions (as detailed on 

Exhibit A to the Commonwealth Plan) were transferred to the Avoidance Actions 

Trust. CST and Continental handle these actions as counsel to the Avoidance 

Actions Trustee. 

 Other Co-Plaintiff Adversary Proceedings: Upon the effective date of the 

Commonwealth Plan, the following adversary proceedings were resolved in 

accordance with the Commonwealth Plan: 

o 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 

o Seven adversary proceedings challenging liens asserted by certain holders 

of GO bonds [Adv. Proc. No. 19-291, Adv. Proc. No. 19-292, Adv. Proc. 

No. 19-293, Adv. Proc. No. 19-294, Adv. Proc. No. 19-295, Adv. Proc. 

No. 19-296, and Adv. Proc. No. 19-297]. 

 HTA-Related Co-Plaintiff Adversary Proceedings: Pursuant to the Final Stay 

Order, the following co-plaintiff adversary proceedings are stayed pending an 

order of the Court lifting the stay or confirmation of a plan of adjustment for 

HTA: 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 49 of 58
31 

o 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]. 

On October 12, 2022, the Court confirmed the HTA plan of adjustment. The 

effective date of the plan has not yet occurred. 

 ERS-Related Co-Plaintiff Adversary Proceedings: Upon the effective date of the 

Commonwealth Plan, the following adversary proceedings were resolved in 

accordance with the Commonwealth Plan: 

o Six adversary proceeding related to ERS bond issues [Adv. Proc. No. 19-

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

361, Adv. Proc. No. 19-366, and Adv. Proc. No. 19-367]. 

 HTA Revenue Bond Co-Plaintiff Adversary Proceeding: Adv. Proc. No. 20-007 

has been dismissed. 

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

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

ACTUAL AND NECESSARY DISBURSEMENTS 

75. As set forth in Exhibit D-2 hereto, Paul Hastings disbursed $7,356.79 as expenses 

incurred in providing professional services during the Application Period, which principally 

consisted of online legal research (e.g., LEXIS and WESTLAW). Because Paul Hastings 

believes that online legal research is far more cost-efficient than manual research using hardbound volumes, Paul Hastings encourages computerized legal research even though it is not a 

profit center for Paul Hastings. 

76. The time constraints imposed by the circumstances of the matters handled by Paul 

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

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

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

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

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 50 of 58
32 

other Paul Hastings employees who worked late in the evenings or on weekends were 

reimbursed for their reasonable meal and transportation costs in accordance with the Local Rules 

and firm policy. Paul Hastings’ regular practice is not to include components for those charges 

in overhead when establishing billing rates, but rather to charge its clients for these and all other 

out-of-pocket disbursements incurred during the regular course of the provision of legal services. 

77. Further, Paul Hastings believes the rates for charges incurred are the market rates 

that the majority of law firms charge clients for such services. In addition, Paul Hastings 

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 

78. 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; 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 51 of 58
33 

(iv) whether the services were performed within a reasonable 

amount of time commensurate with the complexity, importance, 

and nature of the problem, issue, or task addressed; 

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

board certified or otherwise has demonstrated skill and 

experience in the restructuring field; and 

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

compensation charged by comparably skilled practitioners in 

cases other than cases under this title or title 11, United States 

Code. 

79. 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 . . . .” 

80. In the instant case, Paul Hastings respectfully submits that the services for which 

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

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

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

Title III Cases. The services rendered to the Committee were performed in an economic, 

effective, and efficient manner commensurate with the complexity and importance of the issues 

involved. The results obtained to date have benefited not only the Committee but also the 

Debtors, their stakeholders, and other interested parties. Accordingly, the compensation 

requested herein is reasonable in light of the nature, extent, and value of such services to the 

Committee, the Debtors, and all parties in interest. 

81. 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, Paul Hastings sought to minimize the costs of Paul Hastings’ services 

to the Committee by utilizing talented junior attorneys and paraprofessionals to handle the more 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 52 of 58
34 

routine aspects of the assignments. A small group of the same Paul Hastings attorneys was 

utilized for the vast majority of the work in order to minimize the costs of intra-Paul Hastings 

communication and education about the Title III Cases. As demonstrated by this Application, 

Paul Hastings spent its time economically and without unnecessary duplication. Accordingly, 

approval of the compensation sought herein is warranted. 

NOTICE 

82. In accordance with the Interim Compensation Order, Paul Hastings will provide 

notice of this Application to (i) the attorneys for the Oversight Board, Proskauer Rose LLP and 

O’Neill & Borges LLC; (ii) the attorneys for the Puerto Rico Fiscal Agency and Financial 

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

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

Official Committee of Retired Employees, Jenner & Block LLP and Bennazar, García & Milián, 

C.S.P.; (v) the Puerto Rico Department of Treasury; (vi) the Fee Examiner, Brady Williamson; 

and (vii) counsel to the Fee Examiner, Godfrey & Kahn, S.C. and EDGE Legal Strategies, PSC. 

In addition, the notice of hearing with respect to this Application will be served on all parties that 

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

[Remainder of page intentionally left blank.] 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 53 of 58
35 

CONCLUSION 

WHEREFORE, Paul Hastings 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 $1,145,246.50, representing 100% of 

the fees billed during the Application Period, and reimbursement of $7,356.79, representing 

100% of the actual and necessary expenses incurred during the Application Period, 

(ii) authorizing and directing the Debtors’ payment of the difference between (a) the sum of 80% 

of the fees allowed (after taking into account any credits) and 100% of the expenses allowed and 

(b) the amounts previously 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 Paul Hastings’ right to seek 

such further compensation and/or payment for the full value of services performed and expenses 

incurred, and (iv) granting Paul Hastings such other and further relief as is just. 

Dated: November 15, 2022 

 

 /s/ Luc A. Despins .

PAUL HASTINGS LLP 

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

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

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

200 Park Avenue 

New York, New York 10166 

Telephone: (212) 318-6000 

lucdespins@paulhastings.com 

nicholasbassett@paulhastings.com 

alexbongartz@paulhastings.com 

Counsel to the Official Committee of Unsecured 

Creditors

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 54 of 58
UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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

 : 

In re: : 

 : 

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III 

 : 

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

 : 

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

 : 

Debtors.1 : 

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

DECLARATION OF LUC A. DESPINS IN SUPPORT OF SIXTEENTH INTERIM 

FEE APPLICATION OF PAUL HASTINGS LLP, AS COUNSEL TO OFFICIAL 

COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES RENDERED 

AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JUNE 1, 2022 

THROUGH SEPTEMBER 30, 2022 

Pursuant to Rule 2014(a) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

Rules”), I, Luc A. Despins, declare that the following is true to the best of my knowledge, 

information, and belief: 

1. I am an attorney admitted and in good standing to practice in the State of New 

York. I am a partner with the law firm of Paul Hastings LLP (“Paul Hastings”), located at, 

among other offices worldwide, 200 Park Avenue, New York, New York 10166, and am duly 

authorized to make this Declaration on behalf of Paul Hastings. I make this Declaration in 

 

1

 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number and the last four (4) 

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

(the “Commonwealth”) (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) 

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

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

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

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

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

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

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 55 of 58
2 

support of the Sixteenth Interim Application of Paul Hastings LLP, Counsel to Official 

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

the Period from June 1, 2022 through September 30, 2022 (the “Application”).2 

2. The facts set forth in this Declaration are based upon my personal knowledge, 

discussions with other Paul Hastings attorneys, and the firm’s client/matter records that were 

reviewed by me or other Paul Hastings attorneys acting under my supervision and direction. 

3. 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 conform with the Bankruptcy Code, the 

Bankruptcy Rules, the U.S. Trustee Guidelines, and the Local Rules, and (b) the compensation 

and reimbursement of expenses are billed at rates no less favorable to the Debtors than those 

customarily employed by Paul Hastings generally. 

4. Paul Hastings 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 Cases, during the Application Period Paul Hastings agreed 

to the following voluntary fee reductions and expense write-offs: 

(i) For services rendered during the Application Period, Paul Hastings 

reduced the rate charged for the following attorney: 

Attorney Standard 2022 Rate 

(adjusted to reflect 20% 

end-of-case reduction)

Reduced 2022 Rate (adjusted 

to reflect 20% end-of-case 

reduction)

Luc A. Despins $1,460 $1,360 

 

2

 Capitalized terms used but not defined herein have the meanings set forth in the Application. 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 56 of 58
3 

The foregoing reduced rate translated into $15,037.50 in waived fees. 

(ii) Paul Hastings did not increase the hourly rates of timekeepers working on 

the Puerto Rico matter as of June 1, 2022 and, instead, maintained the preJune 1, 2022 rates for the Application Period (even though hourly rates 

increased on a firm-wide basis as of June 1, 2022). This translates into an 

additional $26,498.00 in waived fees. 

(iii) Paul Hastings waived expenses totaling $117.20, as follows: 

a. The firm waived all charges with respect to late-work, in-office 

meals (even though the Fee Examiner guidelines permit in-office meal 

charges of up to $20.00 per meal). At a $20.00 cap per meal, this 

translates into a total write-off of $0.00; 

b. The firm capped car service charges at $100.00 resulting in a 

write-off of $29.70; and 

c. To comply with Local Rule 2016-1(b)(1), the firm reduced color 

photocopy charges by 50% from 50 cents per page to 25 cents per page 

(even though the Fee Examiner’s guidelines permit color photocopy 

charges of 50 cents per page), resulting in a write-off of $87.50. 

(iv) The aggregate amount of the foregoing reductions/write-offs is 

$41,652.70. 

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

the Application Period are higher by 10% or more, did you discuss the 

reasons for the variation with the client? 

Response: Not applicable. 

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

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

Response: No. 

Question: Does the application include time or fees related to reviewing or revising 

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

to work involved in preparing and editing billing records that would not be 

compensable outside of bankruptcy and does not include reasonable fees 

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

Response: The Application does not include time for preparing, reviewing, or 

revising time records. However, in the interest of full disclosure, the 

Application includes approximately 9.9 hours and associated fees of 

approximately $14,491.50 related to preparing, reviewing, and revising 

Paul Hastings’ fee statements, including related summary tables, 

correspondence with notice parties, and ensuring time entries are properly 

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 57 of 58
4 

categorized by matter number and task code. On average, less than 2.0 

hours were spent on each of the five monthly fee statements prepared 

during the Application Period. 

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: As is customary, Paul Hastings adjusts its hourly rates periodically 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. Effective 

February 1, 2022, with the Committee’s approval, Paul Hastings adjusted 

its hourly rates in accordance with the Retention Order, the Retention 

Application, and the supporting Declaration of Mark Richard [Docket No. 

610-3]. The Retention Order provides that Paul Hastings will charge its 

regular hourly rates in effect from time to time, as such rates may be 

increased periodically, annually or otherwise. As detailed in the 

Declaration of Mark Richard [Docket No. 610-3], the Committee was 

advised of the foregoing.

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

inquiry, the foregoing is true and correct. 

Executed this 15th day of November 2022 

 /s/ Luc A. Despins 

Luc A. Despins

Case:17-03283-LTS Doc#:22879 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc: Main

Document Page 58 of 58