UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

In re: 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

_____________________________________________/

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

CERTIFICATION OF JOHN ARRASTIA, ESQ. IN SUPPORT OF THE FOURTH

INTERIM FEE APPLICATION OF CONTINENTAL PLLC, AS SPECIAL LITIGATION 

AND CONFLICTS COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES 

FOR THE PERIOD FROM FEBRUARY 1, 2023 THROUGH MAY 31, 2023

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

and belief:

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

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

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

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

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

2. I am admitted to practice law in the state of Florida. By order dated April 16, 2019, 

1 The Debtors in these Title III cases, along with each Debtor’s respective Title III case number listed as a bankruptcy 

case number due to software limitations and the last four (4) digits of each Debtor’s federal tax identification number,

as applicable, are the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17-BK-3283 (LTS)) (Last Four Digits

of Federal Tax ID: 3481), (ii) Employees Retirement System of the Government of the Commonwealth of Puerto Rico 

(“ERS”) (Bankruptcy Case No. 17-BK-3566 (LTS)) (Last Four Digits of Federal Tax ID: 9686), (iii) Puerto Rico 

Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567 (LTS)) (Last Four Digits of 

Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); (v) Puerto Rico Electric Power Authority (“PREPA”) 

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

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5523 (LTS)) (Last Four Digits of Federal Tax ID: 3801). (Title III 

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

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I was admitted to appear Pro Hac Vice in the Debtors Title III Cases [Dkt. No. 6330].

3. I am duly authorized to make this Certification on behalf of Continental. The facts 

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

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

Continental attorneys acting under my supervision and direction.

4. In accordance with (a) Local Bankruptcy Rule 2016-1 (the “Local Guidelines”), (b) 

Appendix B of the United States Trustee Guidelines for Reviewing Applications for Compensation 

and Reimbursement of Expenses Filed Under 11 U.S.C. § 330, effective as of November 1, 2013 

(the “U.S. Trustee Guidelines”), and (c) the Third Amended Order Setting Procedures for Interim 

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

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

of Continental PLLC, as Special Litigation and Conflicts Counsel to Official Committee of 

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

February 1, 2023 through May 31, 2023 (the “Application”).2

5. Pursuant to section (a)(4) of the Local Guidelines, I hereby certify that I have read 

the Application and, to the best of my knowledge, information, and belief, formed after reasonable 

inquiry, (a) the compensation and reimbursement of expenses sought in the Application conforms 

with the Bankruptcy Code, the Bankruptcy Rules, the U.S. Trustee Guidelines, and the Local 

Rules, (b) the compensation and reimbursement of expenses are billed at rates no less favorable to 

the Debtors than those customarily employed by Continental generally (taking into consideration 

that Continental employs a variety of fee arrangements with its clients, including hourly fees, 

contingency fees and hybrid fees involving reduced hourly rates and reduced contingency fee 

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

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

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

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

6. Continental seeks allowance of all of its fees incurred during the Application Period 

in the amount of $167,932.00, to the extent such amount has not been paid before the hearing 

scheduled on this Fourth Interim Application. In accordance with the Engagement Letter and 

Retention Order, Continental agreed to a voluntary fee reduction equal to 20%, which results in a 

reduction in fees in the amount of $33,586.40 in the Fourth Interim Application. 

7. Continental provides the following response to the request for information set forth 

in the U.S. Trustee Guidelines:

Question: Did you agree to any variations from, or alternatives to, your 

standard or customary billing rates, fees, or terms for services 

pertaining to this engagement that were provided during the 

Application Period?

Response: Yes. As a courtesy to the Committee and based on circumstances 

unique to the Title III Case, the hourly rates in this matter have not 

been adjusted since counsel were first engaged in April 2019. 

Second, during the Application Period, Continental agreed to a 

voluntary reduction of its fees by an amount equal to 20% of the total 

fees sought to be paid, which reduction totals $33,586.40. 

Question: If the fees sought in this Fourth Interim Application as compared to 

the fees budgeted for the Application Period are higher by 10% or 

more, did you discuss the reasons for the variation with the client?

Response: The fees were below the budgeted amount, therefore the request is 

not applicable. 

Question: Have any of the professionals included in this Fourth Interim 

Application varied their hourly rate based on the geographic location 

of the bankruptcy case?

Response: No.

Question: Does the application include time or fees related to reviewing or 

revising time records or preparing, reviewing, or revising invoices?

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(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 Fourth Interim Application includes approximately 1.8 hours 

and associated fees of approximately $1,035.00 related to preparing, 

reviewing, and revising Continental’s fee statements.

Question: Does this application include time or fees for reviewing time records 

to redact any privileged or other confidential information? If so, 

please quantify by hours and fees.

Response: No.

Question: If the application includes any rate increases since retention: (i) Did 

your client review and approve those rate increases in advance? (ii) 

Did your client agree when retaining the law firm to accept all future 

rate increases? If not, did you inform your client that they need not 

agree to modified rates or terms in order to have you continue the 

representation consistent with ABA Formal Ethics Opinion 11-458?

Response: No rate increases have occurred since the retention date. 

8. I declare under penalty of perjury that, to the best of my knowledge and after 

reasonable inquiry, the foregoing is true and correct.

Executed this 14th day of July 2023.

/s/ John Arrastia

John Arrastia, Esq. (Pro Hac Vice)

CONTINENTAL PLLC

255 Alhambra Cir, Suite 640 

Coral Gables, FL 33134

Tel: 305-677-2707

JArrastia@ContinentalPLLC.com

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