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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

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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. :

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DECLARATION OF JUAN JOSÉ CASILLAS-AYALA, ESQ. IN SUPPORT OF SECOND

INTERIM FEE APPLICATION OF CASILLAS, SANTIAGO & TORRES, LLC, AS 

LOCAL COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED CREDITORS, 

FOR SERVICES RENDEREDAND REIMBURSEMENT OF EXPENSES FOR PERIOD 

FROM SEPTEMBER 1, 2017 THROUGH JANUARY 31, 2018

Pursuant to Rule 2014(a) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy

Rules”), I, Juan José Casillas-Ayala, 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 Commonwealth of Puerto

Rico. I am a Capital Member and head of the Litigation and Labor Department at the law firm of

Casillas, Santiago & Torres, LLC (“CST Law”), located at, 53 Palmeras St., Ste. 1601, San

Juan, PR 00901, and am duly authorized to make this Declaration on behalf of CST Law. I

make this Declaration in support of the Second Interim Application of Casillas, Santiago &

Torres, LLC, Local Counsel to Official Committee of Unsecured Creditors, for Services Rendered

and Reimbursement of Expenses for the Period from September 1, 2017 through January 31, 2018

(the “Application”).

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14 Capitalized terms used but not defined herein have the meanings set forth in the Application.

Hearing Date: June 6, 2018 at 9:30 a.m. (ET) / 9:30 a.m. (AST)

Objection Deadline: April 9, 2018 at 4:00 p.m. (ET) / 4:00 p.m. (AST)

Case:17-03283-LTS Doc#:2757-2 Filed:03/19/18 Entered:03/19/18 22:02:46 Desc:

Declaration of Juan J. Casillas-Ayala in Support of Second Interim Fee Applicat Page 1 of 3
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2. The facts set forth in this Declaration are based upon my personal knowledge, 

discussions with other CST Law attorneys, and the firm’s client/matter records that were reviewed 

by me or other CST Law 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 CST Law generally.

4. CST Law 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 Interim Fee Period?

Response: No.

Question: If the fees sought in this application as compared to the fees budgeted for the

Interim Fee Period are higher by 10% or more, did you discuss the reasons for 

the variation with the client?

Response: CST remained within all its presented budgets.

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: This application does not include time or fees related to reviewing or revising

time records or preparing, reviewing, or revising invoices.

Case:17-03283-LTS Doc#:2757-2 Filed:03/19/18 Entered:03/19/18 22:02:46 Desc:

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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: This application does not include time or fees for reviewing time records to redact 

any privileged or other confidential information

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 rates 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: This application does not include any rate increase since retention.

5. 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 19

th day of March, 2018.

/s/ Juan J. Casillas-Ayala

Juan J. Casillas-Ayala, Esq.

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