EXHIBIT C 

BUDGET AND STAFFING PLAN 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 1 of 29
EXHIBIT C-1 

BUDGET (JUNE 2022) 

Period Covered: June 1, 2022 through June 30, 20221

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

Period June 1, 2022 

through June 30, 2022 

B110 Case Administration 50 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 10 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 50 

B155 Court Hearings 10 

B160 Employment / Fee Applications 75 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 5 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 10 

B191 General Litigation 20 

B195 Non-Working Travel2 0 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 2 of 29
2 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 0 

B220 Employee Benefits/Pensions 0 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with 

Debtors/Oversight Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 50 

B320 Plan and Disclosure Statement 100 

B420 Restructurings 600 

TOTAL HOURS 998 

TOTAL ESTIMATED FEES $1,121,752.003

MINUS 20% REDUCTION4 ($224,350.40) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $897,401.60 

 

2

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

travel. 

3 The Total Estimated Fees are calculated based on a $1,124 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from June 1, 2022 through June 30, 2022. The 

impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at this 

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-of-thecase reduction, would be approximately $899. 

4 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 3 of 29
3 

ADDITIONAL JUNE 2022 SUB-BUDGETS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of an HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 4 of 29
4 

 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]. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 5 of 29
5 

BUDGET (JULY 2022) 

BUDGET 

Period Covered: July 1, 2022 through July 31, 20225

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

Period July 1, 2022 

through July 31, 

2022 

B110 Case Administration 50 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 10 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 50 

B155 Court Hearings 10 

B160 Employment / Fee Applications 75 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 25 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 10 

B191 General Litigation 20 

 

5

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

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Exhibit C Page 6 of 29
6 

B195 Non-Working Travel6 0 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 50 

B320 Plan and Disclosure Statement 100 

B420 Restructurings 600 

TOTAL HOURS 1,028 

TOTAL ESTIMATED FEES $1,158,556.007

MINUS 20% REDUCTION8 ($231,711.20) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $926,844.80 

 

6

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

travel. 

7 The Total Estimated Fees are calculated based on a $1,127 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from July 1, 2022 through July 31, 2022. The impact 

of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at this time. 

However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-of-the-case 

reduction, would be approximately $902. 

8 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 7 of 29
7 

ADDITIONAL JULY 2022 SUB-BUDGETS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of an HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 8 of 29
8 

 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]. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 9 of 29
9 

BUDGET (AUGUST 2022) 

 

Period Covered: August 1, 2022 through August 31, 20229

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

Period August 1, 

2022 through August 

31, 2022 

B110 Case Administration 50 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 10 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 30 

B155 Court Hearings 10 

B160 Employment / Fee Applications 50 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 25 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 10 

B191 General Litigation 20 

B195 Non-Working Travel10 0 

 

9

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

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

travel. 

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Exhibit C Page 10 of 29
10 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 50 

B320 Plan and Disclosure Statement 100 

B420 Restructurings 600 

TOTAL HOURS 983 

TOTAL ESTIMATED FEES $1,107,841.0011

MINUS 20% REDUCTION12 ($221,568.20) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $886,272.80 

 

11 The Total Estimated Fees are calculated based on a $1,127 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from August 1, 2022 through August 31, 2022. The 

impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at this 

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-of-thecase reduction, would be approximately $902. 

12 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 11 of 29
11 

ADDITIONAL AUGUST 2022 SUB-BUDGETS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

Omnibus GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

following adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of an HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 12 of 29
12 

 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]. 

 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 13 of 29
13 

BUDGET (SEPTEMBER 2022) 

Period Covered: September 1, 2022 through September 30, 202213

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

Period September 1, 

2022 through 

September 30, 2022 

B110 Case Administration 40 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 10 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 30 

B155 Court Hearings 10 

B160 Employment / Fee Applications 50 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 20 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 10 

B191 General Litigation 10 

B195 Non-Working Travel14 0 

 

13 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

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

travel. 

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Exhibit C Page 14 of 29
14 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 50 

B320 Plan and Disclosure Statement 10 

B420 Restructurings 600 

TOTAL HOURS 868 

TOTAL ESTIMATED FEES $978,236.0015

MINUS 20% REDUCTION16 ($195,647.20) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $782,588.80 

 

15 The Total Estimated Fees are calculated based on a $1,127 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from September 1, 2022 through September 30, 

2022. The impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be 

calculated at this time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 

20% end-of-the-case reduction, would be approximately $902. 

16 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 15 of 29
15 

ADDITIONAL SEPTEMBER 2022 SUB-BUDGETS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

Omnibus GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

following adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of the HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 16 of 29
16 

 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]. 

Upon the effective date of the HTA plan of adjustment, the above adversary proceedings will be 

resolved.

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 17 of 29
EXHIBIT C-2 

STAFFING PLAN (JUNE 2022) 

GENERAL STAFFING PLAN 

Period Covered: June 1, 2022 to June 30, 20221

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period June 1, 

2022 through June 

30, 2022 

Average hourly rate 

for period June 1, 2022 

through June 30, 2022 

(net of 20% reduction)2

Partner 6 $1,626 $1,301 

Counsel 5 $1,324 $1,059 

Associate 4 $989 $791 

Paraprofessionals 4 $339 $271 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

2 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 18 of 29
2 

ADDITIONAL JUNE 2022 STAFFING PLANS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of an HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 19 of 29
3 

 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]. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 20 of 29
4 

STAFFING PLAN (JULY 2022) 

GENERAL STAFFING PLAN 

Period Covered: July 1, 2022 to July 31, 20223

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period July 1, 

2022 through July 

31, 2022 

Average hourly rate 

for period July 1, 2022 

through July 31, 2022 

(net of 20% reduction)4

Partner 6 $1,624 $1,299 

Counsel 5 $1,343 $1,074 

Associate 4 $995 $796 

Paraprofessionals 4 $328 $263 

 

3

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

4 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 21 of 29
5 

ADDITIONAL JULY 2022 STAFFING PLANS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of an HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 22 of 29
6 

 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]. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 23 of 29
7 

STAFFING PLAN (AUGUST 2022) 

GENERAL STAFFING PLAN 

Period Covered: August 1, 2022 to August 31, 20225

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period August 1, 

2022 through 

August 31, 2022 

Average hourly rate 

for period August 1, 

2022 through August 

31, 2022 (net of 20% 

reduction)6

Partner 6 $1,624 $1,299 

Counsel 5 $1,343 $1,074 

Associate 4 $995 $796 

Paraprofessionals 4 $328 $263 

 

5

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

6 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 24 of 29
8 

ADDITIONAL AUGUST 2022 STAFFING PLANS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

Omnibus GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

following adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of an HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 25 of 29
9 

 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]. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 26 of 29
10 

STAFFING PLAN (SEPTEMBER 2022) 

GENERAL STAFFING PLAN 

Period Covered: September 1, 2022 to September 30, 20227

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period 

September 1, 2022 

through September 

30, 2022 

Average hourly rate 

for period September 

1, 2022 through 

September 30, 2022 

(net of 20% reduction)8

Partner 6 $1,624 $1,299 

Counsel 5 $1,343 $1,074 

Associate 4 $995 $796 

Paraprofessionals 4 $328 $263 

 

7

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

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

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

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

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

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

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

budget is speculative. 

8 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 27 of 29
11 

ADDITIONAL SEPTEMBER 2022 STAFFING PLANS 

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE 

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

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

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

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

Omnibus GO Claims Objections are resolved. 

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

Lien Challenges”) 

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

Challenges are resolved. 

C. Adversary Proceeding Against Underwriters, Etc. 

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

prosecution of the underwriter litigation. 

D. Garden-Variety Avoidance Actions 

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

prosecution of the garden-variety avoidance actions. 

E. Other Co-Plaintiff Adversary Proceedings 

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

following adversary proceedings are resolved: 

 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 

 Two adversary proceedings regarding lien scope issues with respect to ERS bonds [Adv. 

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

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

356, Adv. Proc. No. 19-357, Adv. Proc. No. 19-358, Adv. Proc. No. 19-359, and Adv. 

Proc. No. 19-361]. 

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

Committee has been appointed as co-plaintiff/co-trustee with the Oversight Board) remain stayed 

pending confirmation of the HTA plan of adjustment or further order of the court. 

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 28 of 29
12 

 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]. 

Upon the effective date of the HTA plan of adjustment, the above adversary proceedings will be 

resolved.

Case:17-03283-LTS Doc#:22879-3 Filed:11/15/22 Entered:11/15/22 20:43:02 Desc:

Exhibit C Page 29 of 29