EXHIBIT D

BUDGET AND STAFFING PLAN

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 1 of 19
EXHIBIT D-1

BUDGETS FOR:

June 2022

July 2022

August 2022

September 2022

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 2 of 19
EXHIBIT D-1

BUDGETS

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

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

June

2022

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 15

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 7

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 2

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 215

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 3 of 19
B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 296

TOTAL FEES: $126,015

MINUS 20%

REDUCTION: $25,203

TOTAL FEES:

(NET OF REDUCTION) $100,812

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 4 of 19
ADDITIONAL JUNE 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

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

A. Contested Matters 

Continental represented the Committee with respect to several issues, including the following: the 

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

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

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

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

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 5 of 19
Period Covered: July 1, 2022 - July 31, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY July 2022

B110 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 15

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 7

B160 Employment/Fee Applications (Continental) 15

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 2

B181 Preference Analysis and Recovery Action 1

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 350

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

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B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 436

TOTAL FEES: $202,740

MINUS 20%

REDUCTION: $40,458

TOTAL FEES:

(NET OF REDUCTION) $162,192

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 7 of 19
ADDITIONAL JULY 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

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

A. Contested Matters 

Continental represented the Committee with respect to several issues, including the following: the 

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

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

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

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

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 8 of 19
Period Covered: August 1, 2022 - August 31, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY August 2022

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 15

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 7

B160 Employment/Fee Applications (Continental) 15

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 2

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 2

B191 General Litigation 275

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

B410 General Bankruptcy Advice and Opinions 0

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 9 of 19
B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 361

TOTAL FEES: $167,865

MINUS 20% REDUCTION: $33,573

TOTAL FEES:

(NET OF REDUCTION) $134,292

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 10 of 19
ADDITIONAL AUGUST 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

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

A. Contested Matters 

Continental represented the Committee with respect to several issues, including the following: the 

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

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

contested matters that are currently under advisement by the Committee. 

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 11 of 19
Period Covered: September 1, 2022 - September 30, 2022

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY September 2022

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 10

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 12

B160 Employment/Fee Applications (Continental) 15

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 1

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 1

B191 General Litigation 225

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 12 of 19
B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 282

TOTAL FEES: $131,130

MINUS 20%

REDUCTION:

$26,226

TOTAL FEES:

(NET OF REDUCTION)

$104,904

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 13 of 19
ADDITIONAL SEPTEMBER 2022 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

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

A. Contested Matters 

Continental represented the Committee with respect to several issues, including the following: the 

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

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

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

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

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 14 of 19
EXHIBIT D-2

STAFFING PLAN 

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 15 of 19
Period Covered: June 1, 2022 through June 30, 2022.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 06/1/22 

through 06/30/22

Average hourly rate 

for 06/1/22 through 

06/30/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 16 of 19
Period Covered: July 1, 2022 through July 31, 2022.

Category of

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 07/01/22 

through 07/31/22

Average hourly rate 

for 07/01/22 through 

07/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 17 of 19
Period Covered: August 1, 2022 through August 30, 2022.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 08/01/22 

through 08/31/22

Average hourly rate 

for 08/01/22 through 

08/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 18 of 19
Period Covered: September 1, 2022 through September 30, 2022.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers 

expected to work on 

the matter during 

the budget period

Average hourly rate 

for period 09/01/22 

through 09/30/22

Average hourly rate 

for 09/01/22 through 

09/30/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:22875-4 Filed:11/15/22 Entered:11/15/22 19:49:05 Desc:

Exhibit D Page 19 of 19