Hearing Date: June 6, 2018 at 9:30 a.m. (Atlantic Standard Time)

Objection Deadline: April 9, 2018 at 4:00 p.m. (Atlantic Standard Time)

UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

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

Re: ECF No. 1063, 1150, 1715

(Jointly Administered)

SUMMARY OF SECOND INTERIM APPLICATION OF THE LAW OFFICES OF 

ANDRES W. LOPEZ, PSC FOR ALLOWANCE OF COMPENSATION FOR SERVICES 

RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE

PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY FOR 

THE PERIOD FROM OCTOBER 1, 2017 THROUGH DECEMBER 31, 2017

Name of Applicant: The Law Offices of Andrés W. López, P.S.C. 

(“AWLLAW”)

Authorized to Provide Professional Services to: Puerto Rico Fiscal Agency and Financial Advisory 

Authority (“AAFAF”) as the entity authorized to act on 

behalf of the Commonwealth of Puerto Rico

Period for which compensation and reimbursement are 

sought:

October 1, 2017 through December 31, 2017

Amount of Compensation sought as actual, reasonable, 

and necessary:

$76,055.00

Amount of Expense Reimbursement sought as actual, 

reasonable, and necessary:

$0.00

This is a(n): __ monthly X interim final application

 

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 (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); and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy 

Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747). (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations).

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• Blended Rate in this application for attorneys: $350/hr

• Blended Rate in this application for all timekeepers: $350/hr

Prior Monthly Fee Statements Filed: 

Compensation Period Fees Requested Expenses Requested

May 9, 2017 – November 30, 2017 $108,325.00 $200.00

December 1, 2017 – December 31, 2017 $27,160.00 $0.00

• Both payments have been partially made, for 90% of the total amount. 

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TABLE OF SCHEDULES AND EXHIBITS

Schedule A - List and Summary of Hours by Professional

Schedule B - Summary of Hours and Compensation by Matter Code

Schedule C - Expense Summary

Schedule D - Customary and Comparable Disclosures

Exhibit A - Attorney Certification

Exhibit B - Detailed Time and Expense Records

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Schedule A

LIST AND SUMMARY OF HOURS AND COMPENSATION BY PROFESSIONAL

Name Title or Position Hours Billed in this 

Application

Hourly Rate Billed in this 

Application

Total 

Compensation

Andrés W. López Partner 217.30 $350.00 $76,055.00

TOTAL 217.30 $76,055.00

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Schedule B

SUMMARY OF HOURS AND COMPENSATION BY MATTER CODE

Task Code Matter Description Total Billed

Hours

Total Fees

Requested

Commonwealth Title III Case

Litigation

This category includes analysis, 

preparation, and prosecution of adversary 

proceedings or other litigation. 

48.70 $17,045.00

Relief From Stay 

and Adequate 

Protection

This category includes all matters relating 

to creditor requests for relief from the 

automatic stay or for adequate protection, 

including assisting the Commonwealth 

respond, defend, and settle such requests. 

135.60 $47,460.00

Vendor and 

Other Creditor 

Issues

This category includes all meetings and 

communications with vendors and other 

trade creditors and utility providers. 

33.00 $11,550.00

Total 217.30 $76,055.00

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Schedule C

EXPENSE SUMMARY

Category Amount

No expenses are requested with this application. $0.00

TOTAL $0.00

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Schedule D

CUSTOMARY AND COMPARABLE DISCLOSURES

Category of Timekeeper Blended Hourly Rate

Billed for FY2017

Billed This Case During the 

Compensation Period

Partner N/A $350

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UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

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

Re: ECF No. 1063, 1150, 1715

(Jointly Administered)

SECOND INTERIM APPLICATION OF THE LAW OFFICES OF ANDRES W. LOPEZ, 

P.S.C. FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND 

FOR REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE PUERTO RICO 

FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY FOR THE PERIOD 

FROM OCTOBER 1, 2017 THROUGH DECEMBER 31, 2017

The Law Offices of Andrés W. López, P.S.C. (“AWLLAW”), as counsel to the Puerto 

Rico Fiscal Agency and Financial Advisory Authority (“AAFAF”) as the entity authorized to act 

on behalf of the Commonwealth of Puerto Rico, the Puerto Rico Sales Tax Financing 

Corporation, the Puerto Rico Highways and Transportation Authority, the Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico, the Puerto Rico Electric Power 

Authority (collectively, the “Debtors”), and certain other public corporations and 

instrumentalities of the Government of Puerto Rico, pursuant to the authority granted to it under 

the Enabling Act of the Fiscal Agency and Financial Advisory Authority, Act 2-2017, makes its 

 

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 (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); and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy 

Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747). (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations).

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second interim application (this “Application”) for allowance of compensation, under sections 

316 and 317 of PROMESA, of $76,055.00 for the period from October 1, 2017 through 

December 31, 2017 (the “Compensation Period”) in accordance with the First Amended Order 

Setting Procedures for Interim Compensation and Reimbursement of Expenses of Professionals, 

dated November 8, 2017 [ECF No. 1715] (the “Interim Compensation Order”) and the 

Memorandum regarding Fee Review – Timeline and Process, dated November 10, 2017 (the 

“Fee Examiner Guidelines”). In support of this Application, AWLLAW respectfully states as 

follows:

BACKGROUND

1. On May 3, 2017, the Commonwealth of Puerto Rico (the “Commonwealth”), by 

and through the Financial Oversight and Management Board for Puerto Rico (the “Oversight 

Board”), as the Commonwealth’s representative pursuant to section 315(b) of PROMESA, filed 

a petition with the Court under title III of PROMESA.

2. On May 5, 2017, the Puerto Rico Sales Tax Financing Corporation (“COFINA”), 

by and through the Oversight Board, as COFINA’s representative pursuant to PROMESA 

section 315(b), filed a petition with the Court under title III of PROMESA.

3. On May 21, 2017, the Puerto Rico Highways and Transportation Authority 

(“HTA”), by and through the Oversight Board, as HTA’s representative pursuant to PROMESA 

section 315(b), filed a petition with the Court under title III of PROMESA.

4. On May 21, 2017, the Employees Retirement System for the Commonwealth of 

Puerto Rico (“ERS”), by and through the Oversight Board, as ERS’s representative pursuant to 

PROMESA section 315(b), filed a petition with the Court under title III of PROMESA.

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5. On July 3, 2017, the Puerto Rico Electric Power Authority (“PREPA”), by and 

through the Oversight Board, as PREPA’s representative pursuant to PROMESA section 315(b), 

filed a petition with the Court under title III of PROMESA.

6. Through Orders of this Court, the Commonwealth, COFINA, HTA, ERS, and 

PREPA Title III Cases (together, the “Title III Cases”) are jointly administered for procedural

purposes only, pursuant to PROMESA section 304(g) and Bankruptcy Rule 1015 [ECF Nos. 

242, 537, 1417].

7. This application seeks allowance of compensation and reimbursement of expenses 

incurred by AWLLAW solely in connection with the COFINA related matters described below.

COMPENSATION REQUESTED

8. AAFAF retained AWLLAW pursuant to an engagement letter dated July 31, 2017 

(the “Engagement Letter”). Pursuant to the Engagement Letter, payment of all fees and expenses 

detailed in this Application will be made exclusively by AAFAF.

9. AWLLAW’s hourly rates are set at a level designed to compensate AWLLAW

fairly for the work of its attorneys and are disclosed in detail in the Engagement Letter. 

10. AWLLAW’s rates are appropriate for complex corporate, securities, litigation, 

and restructuring matters, whether in court or otherwise. The rates and rate structure reflect that 

such complex matters typically involve great complexity, high stakes, and intense time pressures. 

Further, there have not been any rate increases during the Compensation Period. AWLLAW

submits that the compensation requested is reasonable in light of the nature, extent, and value of 

such services provided to AAFAF.

11. During the Compensation Period, AWLLAW did not receive any payments or 

promises of payment from any other source for services rendered or to be rendered in any 

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capacity whatsoever in connection with the matters covered by this Application. There is no 

agreement or understanding between AWLLAW and any other person for sharing of 

compensation to be received for services rendered in these cases.

SUMMARY OF SERVICES

12. During the Interim Period, AWLLAW provided important professional services to 

the Debtors in connection with the Title III Cases. Detailed descriptions of the specific services 

provided and the time expended performing such services are attached as Exhibit B, and a 

summary of the services AWLLAW provided to the Debtors during the Compensation Period is 

set forth below.

13. In its fee applications, AWLLAW will use the subject matter categories (each, a 

“Matter Category”) used by its co-counsel law firm, O’Melveny & Myers LLP (“OMM”), for 

keeping time records of the work performed for the Debtors. The following is a summary, by 

Matter Category, of the professional services provided by AWLLAW during the Compensation 

Period.

a) Litigation – 48.70 hours – $17,045.00

14. This category includes analysis, preparation, and prosecution of adversary 

proceedings or other litigation. During the Compensation Period, AWLLAW worked with 

OMM on various litigation matters and on motions filed pursuant to Rule 2004 seeking to 

conduct discovery of various issues relating to Puerto Rico’s fiscal matters.

b) Relief from Stay and Adequate Protection – 135.60 hours – $47,460.00

15. This category includes all matters relating to requests for relief from the automatic 

stay or for adequate protection, including assisting the Commonwealth to respond, defend, 

and settle such requests. During the Compensation Period, AWLLAW worked with OMM in 

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analyzing and responding to requests to lift the Title III stay (either by motion or lift stay 

notice), and in implementing a lift stay protocol to streamline the process for seeking relief 

from the Title III stay.

c) Vendors and Other Creditor Issues – 33.0 hours -- $11,550.00

16. This category includes all meetings and communications with vendors and other 

trade creditors and utility providers. During the Compensation Period, AWLLAW worked with 

OMM in helping to analyze issues and payment disputes with various government vendors, and 

to resolve the issues and disputes as appropriate.

ATTORNEY CERTIFICATION

14. In accordance with Puerto Rico Local Bankruptcy Rule 2016-1(a)(4), the 

undersigned has reviewed the requirements of Puerto Rico Local Bankruptcy Rule 2016-1(a)(4)

and certifies to the best of his information, knowledge, and belief that this Application complies 

with Puerto Rico Local Bankruptcy Rule 2016-1(a)(4). In this regard, and incorporated herein by 

reference, the Certification of Andrés W. López in accordance with the U.S. Trustee Guidelines is 

attached hereto as Exhibit A.

NO PRIOR APPLICATION

15. No prior application for the relief requested by this Application has been made to 

this or any other court.

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WHEREFORE, AWLLAW respectfully requests that the Court enter an order: (a) 

awarding AWLLAW compensation for professional services provided during the Compensation

Period in the amount of $76,055.00; and (b) granting such other relief as is appropriate under the 

circumstances.

Dated: March 20, 2018

San Juan, Puerto Rico

Respectfully submitted, 

/s/Andrés W. López

Andrés W. López

USDC No. 215311

THE LAW OFFICES OF 

ANDRÉS W. LÓPEZ, P.S.C.

902 Fernández Juncos Ave.

San Juan, PR 00907

Tel: (787) 294-9508

Fax: (787) 294-9519

Attorneys for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority 

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Exhibit A

ATTORNEY CERTIFICATION

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UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.2

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 1063, 1150, 1715

(Jointly Administered)

CERTIFICATION OF ANDRES W. LOPEZ PURSUANT TO PUERTO RICO LOCAL 

BANKRUPTCY RULE 2016-1(a)(4)

Andrés W. López, under penalty of perjury, certifies as follows:

1. I am a partner with the law firm of The Law Offices of Andres W. López, P.S.C.

(“AWLLAW”). I make this certification in accordance with Rule 2016-1(a)(4) of the Local 

Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the 

District of Puerto Rico (the “Local Rules”) regarding the contents of applications for 

compensation and expenses. 

2. I am familiar with the work performed by AWLLAW for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority (“AAFAF”), acting for or on behalf of the Debtors.

 

2 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 (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); and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy 

Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747). (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations).

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3. I have read the Second Interim Application of The Law Offices of Andrés W. 

López, P.S.C. for Allowance of Compensation for Services Rendered and for Reimbursement of 

Expenses As Counsel to the Debtors for the Period From October 1, 2017 through December 31, 

2017 (the “Application”), and the facts set forth therein are true and correct to the best of my 

knowledge, information, and belief. 

4. To the best of my knowledge, information, and belief, formed after reasonable 

inquiry, the fees and disbursements sought in the Application are permissible under PROMESA, 

the Bankruptcy Code, the Federal Rules of Bankruptcy Procedure, the Interim Compensation 

Order, the Guidelines for Reviewing Applications for Compensation and Reimbursement of 

Expenses by Attorneys in Larger Chapter 11 Cases, effective November 1, 2013 (the 

“Guidelines”), and the Local Rules of Bankruptcy Practice and Procedure of the United States 

Bankruptcy Court for the District of Puerto Rico.

Dated: March 19, 2018 /s/Andrés W. López

Andrés W. López

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Exhibit B

DETAILED TIME AND EXPENSE RECORDS

I. Litigation

Date Services Hours

10/4/17 Correspond w/M. Pocha re notices of appearance 0.80

in adversary proceeding and receiving Court Orders

and notifications (0.3); conduct factual research re same

(0.5).

10/5/17 Correspond w/R. Holm, P. Friedman re 0.70

objection to fee application (0.3); review draft

re same (0.4).

10/6/17 Review memo from R. Holm re negotiations 0.10

to resolve AAFAF’s objections to a firm’s monthly 

fee statement.

10/6/17 Correspond w/B. Neve re draft motion to facilitate 0.50

flow of FEMA funds; review draft motions re

same.

10/7/17 Review memos from B. Neve, S. Uhland re 0.50

revised federal funds motion; review draft

motion re same.

10/8/17 Review memo from I. Garau re research re 3.00

APRUM adversary proceeding and procedural 

history re same (0.2); conference call w/I. Garau 

re same (0.3); conduct requested research and 

prepare memo to I. Garau re same (2.5).

10/8/17 Review memo from B. Neve re update on motion 0.10

re flow of federal funds and expected filing date.

10/9/17 Review memo from M. Hindman re mediation 0.10

report.

10/10/17 Research re adversary proceedings in which AAFAF 4.30

and/or its executive director have been served with

process (4.0); correspond w/I. Garau re same (0.3).

10/11/17 Review memos from I. Garau, P. Friedman, M. 0.40

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Yassin re proposed stipulation in new potential

adversary matter; review proposed stipulation re same.

10/12/17 Review memo from B. Neve re additional changes 0.50

to draft motion and proposed order re federal funds;

review drafts and revisions re same.

10/17/17 Conference call w/AAFAF team, plaintiffs’ counsel re 1.00

potential adversary complaint and attempt to resolve 

the matter.

10/19/17 Correspond w/A. Shapiro re informative motion 0.40

re appearance at October 25, 2017 hearing; review

draft motion re same.

10/20/17 Correspond w/A. Shapiro re informative motion 0.20

re appearance at October 25, 2017 hearing.

10/23/17 Correspond w/J. Daniels re unopposed motion to file 0.70

a sur-reply and related questions re same (0.4); review 

draft sur-reply re same (0.3).

10/23/17 Correspond w/B. Neve and review draft reply re 0.40

urgent motion re use of federal funds post-Maria.

10/23/17 Correspond w/J. Daniels, R. Holm re response to 1.00

COFINA senior bondholders’ coalition motion (0.3); 

telephone conference w/R. Holm, J. Daniels re procedural

matters re same (0.3); review draft response re same (0.4).

10/24/17 Correspond w/M. Pocha re question about local rules 0.50

and depositions; research local rules re same.

10/26/17 Correspond w/B. Neve re informative motion re 0.40

submission of amended proposed order; review

draft motion re same.

10/27/17 Prepare transcript request for October 25, 2017 0.50

hearing; correspond w/P. Friedman re same.

10/27/17 Review memo from M. Hindman re mediation 0.10

update and next mediation dates.

10/29/17 Review memo from A. Shapiro re informative 2.50

motion regarding statement made at October 25, 

2017 hearing and background re same; telephone

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conference w/P. Friedman re same; review drafts 

of motion re same.

10/30/17 Correspond w/P. Friedman, R. Holm re 0.50

objection to monthly fee statement; review

draft objection re same.

10/31/17 Correspond w/B. Neve re opposition to motion 1.00

from FGIC requesting a 90-day stay of all litigation (0.4);

review draft motions re same (0.6).

10/31/17 Correspond w/J. Zujkowski re draft joinder 0.80

to FOMB objection (0.2); review draft joinder re same

(0.3); review memo from I. Garau re same (0.1); 

telephone conference w/J. Zujkowski re same (0.2).

10/31/17 Correspond w/R. Holm re transcript for October 25, 0.20

2017 Court hearing.

11/1/17 Review memo from C. Yamin Rivera (AAFAF’s associate 0.50

counsel) re following up on translation of P.R. House Bill 

1124; correspond w/translator re same; memo to 

C. Yamin re same.

11/1/17 Review memo from A. Shapiro re pro hac vice application 0.70

for W. Dellinger (0.1); correspond w/A. Shapiro re 

same (0.2); review W. Dellinger’s pro hac vice application 

(0.4).

11/2/17 Review memos from P. Friedman, C. Juan re Eleventh 0.20

Amendment immunity.

11/2/17 Review official committee of unsecured creditors’ objection 0.40

to motion for a 90-day stay of all litigation in Title III matters. 

11/6/17 Review first amended adversary complaint in APRUM matter. 0.80

11/6/17 Correspond w/J. Daniels re AAFAF’s notice of intervention 0.40 

in Commonwealth-COFINA dispute; review draft notice 

re same.

11/6/17 Correspond w/translator re pending certified translation 1.50

(0.2); review certified translation (0.8); memos to and from 

certified translator re making certain corrections (0.4); memo 

to C. Yamin re certified translation (0.1).

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11/7/17 Review memo from Judge Houser re mediations (postponing 0.20

all mediation sessions for the remainder of 2017 and setting 

forth a mediation schedule for 1Q 2018).

11/7/17 Review memo from A. Shapiro re informative motions re 0.50

attendance at next week’s Court hearings; review draft 

informative motions re same; memos to and from A. Shapiro 

re same.

11/8/17 Review Court Order giving notice of proposed new member of 0.10

mediation team (Judge Colton).

11/8/17 Review FGIC’s omnibus reply to objections to request for a 0.20

90-day stay of all litigation.

11/8/17 Correspond w/A. Shapiro re AAFAF informative motion 0.40

re attendance at November 15, 2017 hearing; review 

informative motion re same.

11/8/17 Correspond w/R. Camara re request for a conference call 0.20

re FOMB’s investigative committee.

11/13/17 Correspond w/ J. Daniels re draft motion to enforce 1.20

stipulation and order approving procedure for resolving 

Commonwealth-COFINA dispute and to dismiss other claims 

and counterclaims (0.3); review and revise draft motion (0.7); 

memo to J. Daniels, R. Holm re same (0.2). 

11/13/17 Review memo from R. Camara re conference call to discuss 0.10

issue re FOMB’s investigative committee.

11/13/17 Review notice of agenda of matters scheduled for the 0.10

November 15, 2017 omnibus hearing.

11/14/17 Review case-related documents and pleadings in preparation 2.50

for omnibus hearing.

11/15/17 Attend November 15, 2017 omnibus hearing. 4.50

11/16/17 Review notice with written remarks of Judge Houser at 0.20

November 15, 2017 omnibus hearing.

11/16/17 Review Court Order denying FGIC’s motion for a 90-day stay 0.10

of all litigation.

11/17/17 Correspond w/A. Pavel re informative motions to be filed; 0.50

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review draft motions re same.

11/17/17 Review new adversary complaint (17-AP-278). 0.50

12/1/17 Review Court Order re December 20, 2017 omnibus 0.10

hearing.

12/1/17 Review memo from P. Friedman to W. Dellinger 0.50

re Aurelius case; review memo from W. Dellinger

re same; conference w/P. Friedman re case-related 

matters.

12/2/17 Memo to W. Dellinger re Aurelius case. 0.10

12/5/17 Correspond w/R. Holm re objection to Ambac’s Rule 2004 0.50

motion; review and file draft objection re same.

12/6/17 Correspond w/A. Pavel re draft objection to renewed Rule 0.40

2004 motions; review draft motion re same.

12/7/17 Correspond w/P. Friedman re draft motion to extend 0.40

time to move to dismiss APRUM’s adversary complaint;

review draft motion re same.

12/10/17 Correspond w/B. Neve re motion to inform attendance 0.30

at December 14, 2017 hearing; review draft motion 

re same.

12/11/17 Correspond w/A. Pavel re draft joint statement re Rule 2004 0.40

motion; review draft joint statement.

12/15/17 Correspond w/B. Neve re informative motion re attendance 0.40

at December 20, 2017 omnibus hearing; review draft motion

re same.

12/19/17 Review case-related documents in preparation for December 3.00

20, 2017 omnibus hearing. 

12/19/17 Review memos from I. Blumberg, M. Kremer re draft 0.50

motion to inform re disclosure of cash balances of Puerto 

Rico government entities; review draft motion re same.

12/20/17 Memos to and from M. Kremer re adding Exhibit 0.50

A to motion filed yesterday re cash balances; 

telephone conference w/M. Kremer re same.

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Document Page 21 of 47
12/20/17 Attend December 20, 2017 omnibus hearing. 3.00

12/20/17 Prepare and file transcript order request for today’s 0.50

omnibus hearing; memo to and from A. Shapiro re 

transcript request for today’s omnibus hearing.

12/20/17 Review memo from Judge Houser re modified mediation 0.10

plan and timetable.

12/20/17 Review memo from O. Ramos re National’s request for 0.50

a Rule 2004 motion and meet and confer re same; review

memo from P. Friedman re same; memo to and from O.

Ramos re same.

12/27/17 Memos to and from W. Dellinger re scheduling 0.20

telephone conference to discuss Aurelius matter.

12/29/17 Memos to and from W. Dellinger, P. Friedman re 0.30

conference call to discuss Aurelius matter.

Total Hours: 48.70

Total Fees: $17,045.00

II. Relief From Stay and Adequate Protection

10/2/17 Review memos from D. Perez, C. Juan re Court Order 0.50

in Salud Primaria case, lift stay notices and draft motion 

to extend certain deadlines re same; review draft re same.

10/3/17 Review memos from D. Perez, C. Juan, J. Spina 0.50

re revised stipulation in Cooperativa lift stay

notice matter; review draft revised stipulation

and related documents re same.

10/3/17 Review memo from C. Juan re coordinating a 0.10

conference call to discuss pending matters.

10/3/17 Review memos from C. Juan, D. Perez and 0.40

draft stipulation in Aquasur lift stay notice

matter, with proposed changes for movant’s 

counsel.

10/3/17 Review documents re all pending lift stay notices 3.00

and update status of same.

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Document Page 22 of 47
10/4/17 Correspond with C. Juan re draft stipulation in 0.70

PFZ Properties lift stay matter (0.2); review draft and

case background re same (0.5).

10/4/17 Review memo from C. Juan re proposed stipulation 0.40

in Cano lift stay notice matter; review proposed

stipulation re same; 

10/5/17 Correspond w/D. Perez re next steps on Salud 0.20

Primaria matter.

10/5/17 Review memos from C. Juan, D. Perez re movants’ 0.40

agreement to a stipulation re lift of stay matter;

review draft stipulation re same.

10/5/17 Review memos from C. Juan, D. Perez re 0.50

Aquasur’s counsel agreement with proposed

changes to stipulation re lift stay notice matter;

review proposed revisions re same.

10/6/17 Review memo from C. Juan re Cooperativa’s 0.80

counsel's proposed revisions to stipulation re

notice to lift stay (0.1); review proposed revisions

re same (0.4); review memo from D. Perez re 

objections to proposed revisions (0.1); review

memos between D. Perez, H. Valdes (counsel

to Cooperativa) re same (0.2).

10/6/17 Review memos from F. Vizcarrondo (counsel for 0.80

Diaz-Cambier, Briales-Verdejo, Vega-Diaz, CintronMarzan) and supporting materials re lift stay notices.

10/6/17 Review memos from C. Juan, D. Perez, J. Spina 0.40

and updated stipulation in Aquasur for filing.

10/9/17 Correspond w/D. Perez re recent lift stay notices 0.20

received this week; next steps re same.

10/10/17 Correspond w/C. Juan, D. Perez re most recent 0.20

lift stay notices related to the federal IDEA statute.

10/10/17 Telephone conference w/C. Juan, W. Burgos re update 1.50

and next steps on pending lift stay notice matters (0.5); 

review chart of lift stay notice matters re same (1.0).

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Document Page 23 of 47
10/10/17 Review memos from C. Juan, J. Spina re Aquasur and 0.50

Orbi lift stay notice stipulations; review drafts re same.

10/10/17 Correspond w/D. Perez re Puerto Rico Department of 0.40

Justice’s position on Salud Primaria matter and next

steps re same.

10/10/17 Correspond w/C. Juan, D. Perez re Court Order extending 0.40

meet and confer deadlines in lift stay notice matters.

10/10/17 Correspond w/D. Perez re draft stipulation in 0.50

PFZ Properties lift stay notice matter; changes

proposed re same; review revised draft re same.

10/11/17 Correspond w/C. Juan re PFZ Properties lift 1.00

stay notice matter and reach out to opposing

counsel re draft stipulation re same (0.4); review 

memo from D. Perez re additional changes to

proposed stipulation (0.1); review draft re same (0.3); 

correspond with D. Carrion (counsel for PFZ Properties)

re proposed stipulation (0.2).

10/11/17 Review memos from D. Perez, C. Juan re 0.50

proposed stipulation in Cooperativa lift stay

notice matter and suggested changes re same;

review proposed revisions to draft stipulation.

10/12/17 Review memo from C. Juan re table of lift stay 0.30

notices involving IDEA-related matters; review

memo from D. Perez re same.

10/12/17 Review memos from D. Perez, J. Spina, 0.30

H. Valdes (counsel to Cooperativa) re

changes to the stipulation between the parties

re lift stay notice.

10/12/17 Correspond w/D. Perez re recent Court Order 0.50

requesting that we propose new procedures for

approval of stipulations to lift or modify the

automatic stay; review Court Order re same.

10/12/17 Review memos from C. Juan, D. Perez re stipulations 1.00

reached in various lift stay notice matters (Alicea, 

Esteva, Ortiz) (0.3); review various drafts of proposed 

stipulations re same (0.7).

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 24 of 47
10/13/17 Review memo and attached chart from C. 1.70

Juan re most recent list of lift stay notices (0.2);

review background documents re same (1.5).

10/16/17 Correspond w/D. Carrion (counsel for PFZ 0.70

Properties) re stipulation on lift stay notice; (0.2)

review proposed changes to draft stipulation

re same (0.3); correspond w/C. Juan, D. Perez re 

same (0.2).

10/16/17 Review memo from D. Perez and attached revised 1.00

draft stipulations re lift stay notice matters (Vega, 

Alicea, Ortiz, Esteva, Cano).

10/17/17 Review memos from C. Juan, D. Perez, J. 0.50

Spina and draft stipulation in Vega-Fernandez

lift stay notice matter.

10/17/17 Review memos from C. Juan, D. Perez re 0.40

most recent version of Cano lift stay notice

stipulation; review stipulation re same.

10/18/17 Conference call w/AAFAF, Ankura teams re 0.70

pending vendor matters (0.5); review chart of 

vendor matters re same (0.2).

10/19/17 Review memos from C. Juan, D. Perez and draft 0.70

stipulations in the Esteva and Ortiz-Ortiz

lift stay notice matters.

10/19/17 Review memo from F. Vizcarrondo (counsel to 0.40

Capellán-Rosa) and supporting documents re

lift stay notice; correspond w/C. Juan, D. Perez

re same.

10/19/17 Review memo from L. Murray-Soto re further 0.30

lift stay notice; correspond w/C. Juan re same.

10/19/17 Review memo from C. Montilla (counsel for 2.00

Pentagon Federal Credit Union and BMW Financial 

Services) and supporting documents re lift stay notice

(1.7); correspond w/C. Montilla, D. Penagarícano re

same (0.3).

10/20/17 Review memo from R. Perez-Pietri (counsel to 1.20

Popular Auto) and attached document re lift

stay notice (0.3); correspond w/C. Juan re next steps 

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 25 of 47
(0.2); review summary of matter and related documents

re same (0.7).

10/20/17 Correspond w/C. Montilla re scheduling a meet and 0.40

confer re lift stay notice; correspond w/C. Juan re

same.

10/20/17 Review memos from C. Juan, D. Perez re proposed 1.10

course of action in certain lift stay matters (0.3); review 

documents re same (0.8).

10/23/17 Conference call w/C. Juan, W. Burgos re pending 1.50

lift stay notice matters (0.5); review chart of pending

matters re same (1.0).

10/23/17 Review memos from C. Juan, D. Perez re Diaz-Colon 1.50

matter and lift stay notice (0.3); review background 

documents and case summary re same (1.2).

10/24/17 Review memos from L. Murray-Soto re follow up 0.20

on lift stay notice.

10/24/17 Review memo from J. Rodriguez (counsel to Rentas- 0.40

Martinez) and attached document re lift

stay notice.

10/24/17 Review memos from J. Spina, C. Juan re Capellan- 0.40

Rosa lift stay notice and draft stipulation; review

draft stipulation re same.

10/24/17 Review notice to lift stay re Melendez-Perez 0.20

matter.

10/25/17 Review memos from C. Juan, D. Perez re lift stay 0.40

notice (Zambrana-Garcia) and proposed course of 

action re same; review documents re same. 

10/25/17 Correspond w/J. Spina re GAM Realty motion to 0.40

lift stay and non-compliance with protocol for filing

lift stay notices; review motion to lift stay re same.

10/26/17 Review memo from C. Juan and attached document 0.50

summarizing meet and confer in Salud Primaria

matter; review background documents re same.

10/26/17 Review memos from C. Juan, L. Murray-Soto re 0.40

procedural stage of cases under consideration for

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 26 of 47
lift stay notice purposes.

10/26/17 Review memo from C. Grovas (counsel to 1.20

Mitsubishi Motor Sales of Caribbean) re lift

stay notice and meet and confer (0.2); review 

documents related to request (0.8); correspond w/

C. Juan re same (0.2).

10/26/17 Review memo from M. Mier re lift stay notice 1.50

(GAM Realty LLC) and accompanying documents 

re same.

10/27/17 Correspond w/C. Juan re recommended course of 0.20

action in GAM Realty lift stay notice matter.

10/27/17 Review memo from V. Rivera-Rios and attached 3.20

documents re Caribbean Airport Facilities matter 

and request for a conference to consider a potential 

settlement before filing adversary proceeding (0.5); 

review case-related documents relating to matter (2.0);

telephone conference w/V. Rivera-Rios re same (0.3);

telephone conference w/V. Rivera Sr. re same (0.4).

10/30/17 Review memos from C. Juan, J. Spina re lift 0.40

stay notice matters involving forfeitures and

approximate value of pending claims.

10/30/17 Correspond w/V. Rivera-Rios (counsel to 0.20

Caribbean Airport Facilities) re scheduling

a conference call to discuss case.

10/30/17 Review memo from F. Vizcarrondo re update 0.20

on notice to lift stay and meet-and-confer 

(Rivera-Marcucci); memo to C. Juan re same.

10/31/17 Review memos from L. Murray-Soto, C. Juan and 0.40

attached documents re update of proceedings in 

matters subject to lift stay notice request.

10/31/17 Review memo from C. Juan and attached draft 0.50

stipulations in Rivera-Delgado, Cruz-Rodriguez,

Fernandez-Jorge lift stay notice matters.

10/31/17 Correspond w/C. Juan re conversations w/F. 0.70

Charles (counsel to Ortiz-Rivera) re lift stay

notice and next steps in forfeiture matter (0.3);

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Document Page 27 of 47
telephone conference w/F. Charles re forfeiture

lift stay notice matter and proposed resolution (0.4).

10/31/17 Review memo from C. Juan re status of Asociación 0.10

de Salud Primaria matter.

10/31/17 Review memo from C. Juan re draft stipulation in lift 0.30

stay notice matter (Caraballo-Caraballo); review draft 

stipulation re same.

10/31/17 Review memo from C. Juan and attached updated chart 1.40

of all lift stay notice matters (1.0); telephone conference 

w/C. Juan re same (0.4).

10/31/17 Telephone conference w/V. Rivera (counsel to Caribbean 0.30

Airport Facilities) re potential resolution of matter.

10/31/17 Review memo to and from C. Juan, F. Vizcarrondo re 0.20

follow up on notice to lift stay (Rivera-Marcucci).

11/1/17 Telephone conference w/Victor Rivera Sr. (counsel to 0.30

Caribbean Airport Facilities) re potential adversary 

proceeding.

11/1/17 Review memo from D. Perez re responding to letter from 0.20

Caribbean Airport Facilities and proposed stipulation to 

resolve dispute; review memo response from E. Barak 

re same.

11/1/17 Review memo from J. Rodriguez (counsel to Melendez-Perez) 0.40 

re lift stay notice matter, following up on request for 

meet-and-confer; correspond w/D. Perez re same.

11/1/17 Review memos from D. Perez, C. Juan, P. Friedman, 0.50

W. Burgos re next steps in Asociación de Salud Primaria

matter, strategy re same.

11/2/17 Telephone conference w/C. Juan re: motions to lift stay 0.50

and current status re same.

11/2/17 Review memos from C. Juan re Melendez Perez 0.20

lift stay notice.

11/2/17 Review memo and attachment from L. Murray-Soto 0.30

(notice to lift stay) arguing that her case is not at a 

preliminary stage.

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Document Page 28 of 47
11/2/17 Review memo from H. Bauer re follow-up from counsel on 0.50

notice of motion to lift stay (Rivera/Saavedra); review 

background documents re same.

11/3/17 Review memo from C. Juan following up on pending 0.50

draft stipulations in lift stay notice cases; review draft 

stipulations re same.

11/3/17 Review memo from C. Juan re PR-DOJ’s suggested position 0.40

re notice to lift stay (Melendez-Perez matter); review 

background documents re same.

11/3/17 Correspond w/C. Juan, D. Perez re updated chart of lift stay 0.40

notice matters and procedure for handling them going forward.

11/6/17 Corrrespond w/D. Perez re status of F. Charles 0.80

lift stay notice and recent calls (0.2); memo to D. Perez 

re same (0.1); conference call w/F. Charles re status of lift 

of stay notice and next steps (0.2); memo to D. Perez 

summarizing conversation with F. Charles (0.2); review memo 

from D. Perez re same (0.1).

11/6/17 Review memo from D. Perez re position on pending matters 0.20

included in the updated lift stay notice chart.

11/6/17 Review memo from F. Rivera-Bujosa re lift of stay notice 0.30 

(Pacheco-Pacheco) (0.1); memo to C, Juan, W. Burgos re same.

11/6/17 Review memo from C. Juan re position on stipulation re lift 0.30

stay notice (Rivera-Marcucci); review memo from F. 

Vizcarrondo accepting the terms of the stipulation.

11/6/17 Review memo from C. Juan to L. Murray-Soto (lift stay notice) 0.10

re proposed stipulation.

11/6/17 Review motion filed by Cooperativa de Seguros Múltiples 0.50

seeking clarification or lift of stay; review memo 

from C. Juan re same.

11/7/17 Review memo from E. Rodriguez re notice to lift stay 0.50

(Roberto Rodriguez matter) and attached documents re 

same; memo to C. Juan, W. Burgos re same.

11/7/17 Review memo from M. Mier re following up on lift stay notice 0.40

for GAM Realty LLC; review background documents re same.

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Document Page 29 of 47
11/7/17 Review memo from C. Juan re Asociación de Suscripción 2.90

Conjunta case (a state-court class action that has been settled 

and as to which judgment has entered) (0.2); review letter from 

ASC’s counsel re same (0.2); review documents related to 

underlying case (2.5).

11/8/17 Review memos from C. Juan, I. Garau re proposed stipulation in 0.20

Caribbean Airport Facilities matter.

11/8/17 Review memo from C. Juan re agreement re stipulation in 0.30

Rivera-Marcucci lift stay notice matter; review proposed 

stipulation re same.

11/9/17 Telephone conferences w/V. Rivera-Rios, counsel in Caribbean 2.50

Airport Facilities matter (0.4); telephone conference w/I. Garau 

re same (0.3); telephone conference w/C. Juan re same (0.3); 

review case-related documents re same (1.50).

11/9/17 Correspond w/C. Juan, D. Perez re lift stay notice (Melendez- 0.40

Perez); review proposed course of action re same.

11/9/17 Review memos from F. Charles, C. Juan re stipulation reached 0.50

in Ortiz-Rivera lift stay notice matter; review proposed 

stipulation re same.

11/9/17 Review memo and attached letter from Caribbean Airport 1.20

Facilities’ counsel re proposed stipulation in lift stay notice 

matter and proposed settlement of underlying litigation (0.4); 

correspond w/C. Juan, D. Perez re same (0.4); review memo 

from C. Juan to CAF’s counsel (V. Rivera-Rios) re same (0.1); 

review draft stipulation in CAF lift stay notice matter re same

(0.3).

11/10/17 Review memo from C. Juan re draft stipulation in Pentagon 0.40

Federal Credit Union and BMW Financial Services lift stay 

notices matter; review draft stipulation re same.

11/10/17 Review memo from D. Perez re draft stipulations in 0.80

Rivera-Marcucci and Rentas-Martinez lift stay notice matters

(0.2); review draft stipulations re same (0.6).

11/10/17 Review memo from C. Juan and attached chart re status of lift 0.80

stay notice matters.

11/10/17 Telephone conference w/C. Juan re review and discussion 0.50

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Document Page 30 of 47
of pending lift stay notices.

11/10/17 Review memo from F. Vizcarrondo (counsel for plaintiff in 0.20

Colon-Rosario) re following up on status 

of evaluation of lift stay notice; memo to C. Juan re same. 

11/10/17 Review memo from F. Vizcarrondo (counsel for plaintiff in 0.50

Mercado-Nieves matter) re lift stay notice and potential filing 

of federal complaint; memo to C. Juan re same; review 

supporting documents re same.

11/10/17 Review memos to and from C. Juan, F. Vizcarrondo re several 0.20

pending matters (in federal IDEA cases) and potential for a 

global settlement re same.

11/11/17 Memos to D. Perez re draft stipulations in various lift stay notice 0.30

matters; review memo from D. Perez re same. 

11/11/17 Prepare memo to D. Perez re pending issues in lift stay notice 1.00

matters. 

11/13/17 Review memo from C. Juan to F. Vizcarrondo re status of case 0.30

analysis re pending lift stay notice matters; correspond w/C. 

Juan re same.

11/13/17 Review memo from D. Perez re lift stay notice 0.10

(Melendez-Perez).

11/13/17 Correspond w/D. Perez re lift stay notice matters that 0.20

are pending a public policy determination.

11/13/17 Review memos from L. Murray-Soto, C. Juan re proposed 0.30

stipulation in second lift stay notice matter and attached 

documents re same.

11/13/17 Correspond w/D. Perez, C. Juan re follow-up on lift stay 0.20

notice memo prepared after last conference call.

11/13/17 Correspond w/I. Garau re letter received at AAFAF re 0.50

lift stay notice; review letter re same; memos to and 

from C. Juan re next steps.

11/13/17 Correspond w/C. Juan re list of cases that have been settled 0.50

and as to which judgment has been entered, review list of 

underlying cases and circumstances; memo to D. Perez re same. 

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Document Page 31 of 47
11/13/17 Review memo from I. Garau re bankruptcy-case document 0.30

received at AAFAF; review document re same; memo to I. 

Garau, D. Perez re same.

11/13/17 Review memo from D. Perez re FOMB’s comments on draft 0.50 

stipulations (BMW Financial-Pentagon Federal, Caribbean 

Airport Facilities, and Ortiz-Rivera); review FOMB’s 

comments re same; review draft stipulations re same.

11/13/17 Review Court Order denying Cooperativa de Seguros 0.30

Múltiples’ motion to lift stay; review memo 

from D. Perez to AAFAF team re same.

11/14/17 Review memos from C. Juan to V. Rivera-Rios (counsel for 0.20

Caribbean Airport Facilities) re draft of stipulation to modify

automatic stay.

11/14/17 Review memo from D. Perez re edits to proposed stipulation 0.40

in the Ortiz lift stay notice matter; review edits re same.

11/15/17 Review memo from C. Juan and attached document re draft 0.40

stipulation in Murray-Soto lift stay notice matters; memo to 

C. Juan re same.

11/15/17 Correspond w/C. Juan, D. Perez re draft stipulation in 0.40

Melendez-Perez lift stay notice matter.

11/15/17 Review memo from C. Juan and draft stipulation of Popular 0.40

Auto lift stay notice matter; memo to C. Juan re same.

11/16/17 Telephone conference w/V. Rivera-Rios (counsel for 0.30

Caribbean Airport Facilities) re proposed stipulation re lift 

stay notice matter.

11/16/17 Correspond w/C. Juan, D. Perez re status of state-court 0.30

class action and consultation with AAFAF.

11/16/17 Review memo from F. Vizcarrondo (counsel for Colon-Rosario) 0.20

re lift stay notice; memo to C. Juan, W. Burgos re same.

11/16/17 Review memo from J. Rodriguez (counsel in Melendez-Perez 0.20

and Rentas-Martinez lift stay notice matters) re lift stay notice; 

memo to C. Juan, W. Burgos re same.

11/16/17 Telephone conference w/I. Garau re ASC state court 1.50

class action and next steps (0.4); memo to C. Juan re same (0.2); 

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Document Page 32 of 47
review memo from C. Juan to A. Amadeo-Murga (counsel for 

plaintiffs) re same (0.1); review background documents re same

(0.8).

11/16/17 Correspond w/C. Juan re upcoming conference call re 0.20

pending lift stay notice matters.

11/17/17 Correspond w/C. Juan, D. Perez re Popular Auto lift 0.40

stay notice matter, follow up re proposed draft stipulation.

11/17/17 Review memo from P.J. Porrata re lift stay notice matter. 0.10

11/17/17 Review lift stay notice from F. Vizcarrondo (Capellan-Rosa); 0.20

memo to C. Juan re same.

11/17/17 Telephone conference with C. Juan re pending lift stay 0.50

motions.

11/19/17 Review memo from J. Rodriguez (counsel to 0.10

Melendez-Perez) re stipulation on notice to lift

stay.

11/21/17 Review memos from C. Juan to J. Rodriguez 0.40

(counsel to Melendez-Perez) re stipulation 

on notice to lift stay.

11/22/17 Review memo from C. Juan re draft stipulation 0.40

in Melendez-Perez and review draft re same.

11/22/17 Telephone conference w/C. Juan, W. Burgos 4.00

re chart of pending lift stay notice matters and next 

steps re same (0.50); review chart and background 

documents re same (3.50).

11/24/17 Review notes from conference call on lift stay 1.00

notices and prepare memo with action items

for D. Perez re same.

11/25/17 Review memo from J. Rodriguez (counsel to 0.20

Melendez-Perez) re stipulation on notice to lift

stay; memo to D. Perez re same.

11/27/17 Review memo from V. Rivera-Rios (counsel to 0.40

Caribbean Airport Facilities) re revised draft

stipulation and review same.

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Document Page 33 of 47
11/27/17 Review memo from J. Rodriguez (counsel to 0.40

Melendez-Perez) re stipulation on notice to lift

stay; correspond w/D. Perez, C. Juan re same.

11/27/17 Correspond with D. Perez, C. Juan re responses to 0.50

action items on lift stay notices.

11/27/17 Review memos from D. Perez re draft stipulations on 0.50

lift stay notices (Melendez-Perez and Colon-Rosario);

review draft revised stipulation in Colon-Rosario.

11/27/17 Memo to C. Juan, W. Burgos re motion for 0.10

reconsideration filed in Cooperativa de Seguros 

Múltiples matter (lift stay notice).

11/28/17 Review memos from C. Juan, D. Perez re 0.40

draft stipulation in Melendez-Perez lift stay notice

matter; review revised draft re same.

11/28/17 Review motion to lift stay filed by GAM Realty 2.00

and documents re same (1.5); memo to C. Juan,

W. Burgos, D. Perez re same (0.2); review memo 

from C. Juan summarizing case background (0.3). 

11/28/17 Review memo from C. Juan re Court Order 0.50

scheduling briefing on Cooperativa’s 

motion for reconsideration; review memo 

from D. Perez re scheduling a call to discuss

same; memo to D. Perez re same; review memo

from C. Juan re same.

11/29/17 Telephone conference w/I. Garau re issues related to 0.50

recently filed motion to lift stay and pending lift 

stay notice matters.

11/29/17 Telephone conference w/N. Vargas (counsel to L. M. 0.40

Rodriguez) re lift stay notice and request for a

meet and confer re same; review memo and 

materials sent by attorney Vargas re same.

11/29/17 Correspond w/F. Rivera-Bujosa (counsel to 0.20

Pacheco-Pacheco) re lift stay notice and 

request for a meet and confer.

11/29/17 Telephone conference with D. Perez, I. Garau, C. Juan, 0.50

W. Burgos re recently filed motions to lift stay 

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Document Page 34 of 47
and for reconsideration of Court Orders.

11/29/17 Review memo from J. Rodriguez (counsel to 0.10

Melendez-Perez) re changes to the draft

stipulation.

11/29/17 Correspond w/D. Perez re potential filing 0.20

of motion and availability re same.

11/30/17 Review memo from C. Juan containing 0.40

proposed revised stipulation in Caribbean

Airport Facilities lift stay notice matter; 

review proposed revisions re same.

11/30/17 Memo to D. Perez, C. Juan, W. Burgos re 0.10

L. Murray-Soto’s filing of a proof of claim.

12/1/17 Review memo from C. Juan re L. Rodriguez lift stay 0.50

notice matter and recommended course of action;

review case background re same.

12/1/17 Review memos from D. Perez, C. Juan re J. Rodriguez 0.60

lift stay notice matter (0.4); review draft revised stipulation

re same (0.2).

12/4/17 Review memos from L. Murray-Soto and C. Juan re 0.50

administrative proceeding at Puerto Rico Treasury 

Department and lift stay notice regarding pending 

matters; review documents re same.

12/4/17 Review memos from D. Perez, C. Juan re GAM Realty 0.50

motion to lift stay and status of conversations with GAM’s

counsel; review memo from C. Juan re agreement on a

stipulation.

12/4/17 Review memos from C. Juan, V. Rivera-Rios (counsel to 0.30

Caribbean Airport Facilities) re approval of the stipulation

re lift stay notice matter.

12/5/17 Telephone conference w/V. Rivera-Rios (counsel for CAF) 0.50

re other pending lift stay notice matters; correspond w/D. 

Perez re procedure for continuing litigation in state court 

after the parties stipulate to lift stay.

12/5/17 Review memo from C. Juan re research on status of Puerto 0.50

Rico Treasury Department’s administrative proceedings 

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 35 of 47
filed by L. Murray-Soto; correspond w/D/ Perez re same;

correspond w/C. Juan re same; review amended draft of 

stipulation to incorporate these administrative matters.

12/5/17 Memos to and from D. Perez, C. Juan re L. Rodriguez 0.70

lift stay notice matter and proposed course of action

and stipulation re same. 

12/6/17 Review memo from movant’s counsel in J. Rodriguez 0.80

lift stay notice matter re order received from state court 

(0.2); memos to and from D. Perez, C, Juan re same (0.4); 

review memos from C. Juan and movant’s counsel re next 

steps (0.2).

12/6/17 Review motion to lift stay filed by A. Rivera (counsel to 0.50

Colon-Gonzalez); memo to C. Juan, W. Burgos, D. Perez

re same; review Court Order terminating motion (for failure

to comply with lift stay notice process); memo to C. Juan,

W. Burgos, D. Perez re same.

12/6/17 Review memos from C. Juan, D. Perez re conference call 0.50

to discuss Lopez-Nieves motion to lift stay; review motion

re same.

12/6/17 Review memo from C. Juan containing revised stipulations 1.00

to several lift stay notice matters (from Landrón & Vera law

firm) (0.2); review draft stipulations re same (0.8).

12/7/17 Review memo from C. Juan and proposed draft 0.40

stipulation re L. Rodriguez lift stay notice matter.

12/7/17 Telephone conference w/D. Perez, C. Juan, W. Burgos, I. 0.50

Garau re motion to lift stay in Lopez-Nieves matter.

12/7/17 Conference call w/I. Garau re lift stay notices and 0.20

procedural questions re plan of adjustment.

12/7/17 Review filing of motion to lift stay; memo to C. Juan, 0.50

W. Burgos, D. Perez re likely denial for failure to comply

with procedure set forth by the Court; review Court Order

denying motion to lift stay and requiring compliance

with Court-ordered procedures.

12/7/17 Review memo from C. Juan re First Circuit’s order staying 0.50

the appeal in Cano; review case background and proposed

next steps re similarly-situated matters.

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 36 of 47
12/8/17 Review memo from A. Rivera re lift stay notice 0.40

(re Gonzalez habeas corpus motion); memo to 

C. Juan re same; review memo from C. Juan

to A. Rivera re same.

12/9/17 Review motion to lift stay filed by Corporación de 0.40

Servicios Integrales de Salud; memo to C. Juan re

same.

12/11/17 Review Court Order scheduling briefing in motion to lift 0.50

stay filed by Corporación de Servicios Integrales de Salud;

review memo from C. Juan w/procedural background on 

the case.

12/12/17 Review memo from C. Juan re pending issues in lift stay 0.10

notice matters.

12/12/17 Review memos from D. Perez and C. Juan with changes to 0.50

various draft stipulations in lift stay notice matters (brought

by Landron & Vera); review draft stipulations re same.

12/12/17 Review memos from C. Juan, D. Perez re status of revisions 0.70

and conversations with opposing counsel re GAM Realty 

lift of stay notice.

12/12/17 Review memo from S. Levine re lift stay notice request re 0.50

A. Alvarez del Valle; review supporting document in support

of request.

12/13/17 Review memo from C. Juan re analysis of Alvarez del Valle’s 1.00

lift stay notice request (0.3); review memo from H. Bauer re 

same (0.2); review memo from D. Perez re same (0.1); review 

further memos from D. Perez, C. Juan, and L. Roman re same

(0.4).

12/13/17 Review memo from D. Perez re revised stipulation in 0.40

F. Rodriguez lift stay notice matter; review draft stipulation

re same.

12/13/17 Review memo from C. Juan re draft reply in Salud Primaria 0.80

matter (0.2); review draft reply re same (0.6).

12/13/17 Review memos from L. Murray-Soto, C. Juan, D. Perez re 1.00

Murray-Soto’s revised lift stay notice and the Court’s 

Order denying her motion to consolidate (0.5); review

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 37 of 47
memo from C. Juan re draft of lift of stay stipulation,

with modifications suggested by Murray-Soto (0.3); 

review Murray-Soto’s reply with further modifications 

re same (0.2).

12/14/17 Correspond w/C. Juan re scheduling a conference call to 0.20

discuss pending lift stay notice matters.

12/14/17 Review memo and attached document from Y. Vega re 0.20

lift stay notice.

12/14/17 Review memos from D. Perez, C. Juan re analysis of 0.20

Corporación de Servicios Integrales’ stay motion.

12/14/17 Review memos from L. Murray-Soto, C. Juan, D. Perez 1.00

re revisions to stipulation language re lift stay notice and 

further drafts re same.

12/15/17 Memos to and from C. Juan re follow up on stipulation re 0.20

L. Rodriguez lift stay notice matter.

12/15/17 Review memos from C. Juan re Quiles Auto Sales lift stay 0.50

notice and attached document re same.

12/15/17 Review memos from C. Juan, D. Perez re Corporación de 1.00

Servicios Integrales case and constitutional challenge re 

Same (0.2); review documents re same (0.8).

12/18/17 Review memo from D. Perez and attached document re 0.50

markup on L. Murray-Soto lift stay notice matter; review

further draft stipulation language re same.

12/18/17 Review pending lift stay notice chart and related documents 3.00

(2.5); telephone conference w/C. Juan re pending lift stay 

notices and strategy re same (0.5).

12/18/17 Review memo from Y. Vega-Vega requesting a lift of the 0.50

automatic stay; memo to C. Juan, W. Burgos re same.

12/18/17 Review memo from C. Juan re stipulation in Fournier- 0.50

Padilla lift stay notice matter; review draft stipulation

re same.

12/18/17 Review memos from C. Juan re stipulations in A. Mercado, 1.50

M. Simo-Rios, M. Cruz-Alvarez, and G. Fernandez lift stay 

notice matters (0.5); review draft stipulation re same (1.0).

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 38 of 47
12/18/17 Review memos from C. Juan, D. Perez re Corporación de 0.50

Servicios Integrales’ case and constitutional challenge re 

same; review draft letter to plaintiff counsel re same.

12/18/17 Review memo from C. Juan re proposed course of action in 0.70

Gonzalez v. Miranda matter (0.1); review case background 

re same (0.6).

12/19/17 Memo to D. Perez re Gonzalez lift stay notice and DOJ’s 0.30

proposed course of action re same.

12/19/17 Memo to D. Perez re pending lift stay notice stipulations 0.90

and upcoming conference call re same (0.4); telephone

conference w/D. Perez re pending lift stay notice matters

and next steps re same (0.5).

12/19/17 Review memo from C. Juan and proposed global stipulation 0.70

for pending IDEA-related lift stay notice matters (0.1); review

proposed stipulation re same (0.4); memo to D. Perez re same

(0.2). 

12/19/17 Memos to and from D. Perez, C. Juan re further request 0.50

for revisions to stipulation in L. Murray-Soto lift stay

notice matter; review proposed revised stipulation

re same.

12/19/17 Review memos from D. Perez. P. Possinger, S. Levine 0.80

re potential stipulation in A. Alvarez lift stay notice

matter (0.3); review memo from C. Juan re same (0.1); 

review memos from S. Levine objecting to proposed 

stipulation language (0.3); review memo from C. Juan re 

same (0.1).

12/19/17 Review memo from attorney J. Olmo re lift stay notice 0.50

(Flores-Perez matter); review memo from H. Bauer re

same; memo to C. Juan re same.

12/19/17 Review memo from C. Juan re Corporación de Servicios 0.40

Integrales lift stay notice matter and plaintiff’s counsel

agreement to stipulation to lift stay; review draft 

stipulation re same.

12/19/17 Review memo from C. Juan re draft omnibus lift 0.70

stay motion in compliance with Court’s third case

management order (0.1); review draft motion re same (0.4);

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 39 of 47
memos to and from D. Perez re same (0.2).

12/20/17 Review memo from D. Perez re Gonzalez lift stay 0.40

notice matter; memo to C. Juan re same. 

12/20/17 Memo to and from C. Juan re request for assistance 1.70

on certain pending lift stay notice matters (0.2); review

lift stay notice matters outlined in C. Juan’s memo (1.5).

12/20/17 Review memo from C. Juan re consulting with Puerto 0.70

Rico’s Solicitor General re A. Alvarez lift stay notice

matter (0.1); review memos from C. Juan, D. Perez re

communications with plaintiff’s counsel (0.2); review

memo from C. Juan with proposed revised stipulation

(0.1); review draft stipulation re same (0.3).

12/20/17 Review memos from D. Perez re CSI lift stay notice 0.70

matter and marked-up draft of stipulation (0.2); review

revised stipulation (0.3); review memos from D. Perez, 

C. Juan reflecting further amendments to stipulation (0.2).

12/20/17 Review memo from D. Perez re upcoming deadline to 0.40

file omnibus lift stay motion; review revised draft of

omnibus motion. 

12/21/17 Memo to D. Perez re outstanding lift stay notices and 0.80

proposed next steps re same. 

12/21/17 Review memo from C. Juan re Y. Vega lift stay notice 0.50

matter; review case background re same; memos to and

from D. Perez re same.

12/21/17 Memos to and from C. Juan re pending stipulation 0.50

and global settlement in several IDEA-related 

matters; memo to D. Perez re same.

12/21/17 Review memo from A. Amadeo-Murga and attached 1.90

supporting documentation re lift stay notice in state

court class action (1.5); review memo from C. Juan re

case background and position regarding request (0.4) 

12/22/17 Memos to and from D. Perez re pending global settlement 0.30

in IDEA-related matters.

12/22/17 Review memo from D. Perez re responses and 0.50

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 40 of 47
comments to memo on pending lift stay notice matters;

memo to C. Juan re same.

12/22/17 Review memo from C. Juan re CSI lift stay notice 0.40

matter and plaintiff counsel’s agreement to revised

stipulation; review memo from D. Perez re same.

12/22/17 Review memos from L. Murray-Soto, C. Juan re 0.30

stipulation to be filed with the Court as part of lift

stay notice motion.

12/22/17 Review memo from C. Juan re Flores-Perez lift 0.50

stay notice matter and recommended course of

action; review case background re same; review

memo from D. Perez re same.

12/22/17 Review memo from C. Juan re potential additional 1.50

pending stipulations that could be added to omnibus

lift stay motion if resolved in time for the filing (0.2);

review memo from D. Perez re same (0.1); review

proposed draft stipulations of pending lift stay 

notices (1.2). 

12/22/17 Review memos to and from C. Juan, D. Perez re 0.20

status of F. Rodriguez lift stay notice matter.

12/22/17 Review memo from attorney J. Rios-Rios re 0.50

lift stay notice (L. Roman); review supporting 

documentation re same; memos to and from C. 

Juan re same.

12/22/17 Review memos from attorney J. Rios-Rios re 1.00

additional lift stay notices (D. Rodriguez, M. Ramery, 

Y. Rosado) (0.4); review supporting documents re 

same (0.6).

12/23/17 Review memo from H. Bauer re contact made by 0.40

attorney Y. Mafuz-Blanco; review memos from

D. Perez, H. Bauer re same.

12/26/17 Memo to C. Juan, W. Burgos re lift stay notices 0.20

in D. Rodriguez, M. Ramery, Y. Rosado matters.

12/26/17 Review memo from attorney J. Lopez-Negron re 0.50

lift stay notice in IDEA federal case; review memo

in support re same; memo to C. Juan, W. Burgos re

same.

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 41 of 47
12/26/17 Review memo from D. Perez re pending global 0.40

settlement stipulation in pending IDEA-related

maters; review draft stipulation re same.

12/26/17 Review memo from H. Bauer re motion to lift 0.40

stay filed by K. Perez; review Court Order denying

motion as improvidently filed; review memo from

D. Perez re same. 

12/26/17 Review memo from C. Juan re following up 0.20

on pending lift stay notice matters and request

for assistance with lift stay notice matters

pending sign-off from co-counsel.

12/27/17 Review memo from C. Juan re recent Puerto 0.80

Rico Supreme Court ruling on applicability

of automatic stay in forfeiture cases (0.1); review

PR Supreme Court decision re same (0.7).

12/27/17 Review memos from C. Juan, D. Perez re signed 0.20

stipulation in F. Rodriguez lift stay notice matter.

12/27/17 Review memo from C. Juan and background materials 1.50

re inquiry from Puerto Rico’s Solicitor General re First 

Circuit Order requiring him to opine as to the applicability 

of a stay in cases where plaintiff challenges the

constitutionality of a regulation and proposed

course of action to follow re same.

12/28/17 Review memo from I. Garau re lift stay notice 0.50

matter (Santana-Baez) received at AAFAF;

review lift stay notice re same; memo to C.

Juan re same.

12/28/17 Review memo from D. Perez re revised draft 0.40

stipulation in L. Rodriguez lift stay notice matter;

review revised draft stipulation re same.

12/29/17 Memos to and from attorney A. Amadeo-Murga 0.30

and C. Juan re lift stay notice request.

12/29/17 Review memo from attorney M. Serrano-Urdaz 0.40

re lift stay notice in various matters; memo to

C. Juan re same.

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 42 of 47
Total Hours: 135.60

Total Fees: $47,460.00

III. Vendor and Other Creditor Issues

10/11/17 Telephone conference w/AAFAF, Ankura teams re 0.70

pending vendor matters (0.5); review chart of 

vendor matters re same (0.2).

10/13/17 Review memo from M. Nazario (counsel to 0.10

Trinity) re issues with payment from the 

Puerto Rico government.

10/16/17 Correspond w/J. Klein from Ankura re vendor 0.20

payment issues.

10/23/17 Telephone conference w/M. Velez-Pastrana re various matters 0.50

concerning pre-petition and post-petition non-payments 

and outstanding items for various of her clients.

10/25/17 Conference call w/AAFAF, Ankura teams re 0.70

pending vendor matters (0.5); review chart of 

vendor matters re same (0.2).

10/25/17 Review memo from G. Barrios re Cesar Castillo 0.10

vendor dispute.

10/30/17 Correspond w/J. Klein re Stericycle’s counsel’s 0.50

communication regarding payment issues; 

telephone conference w/M. Nazario (Stericycle’s 

counsel) re same.

10/30/17 Correspond w/M. Velez-Pastrana 0.40

(counsel to GYC LLC and Commercial 

Centers Management Realty) re vendor 

issues regarding government non-payment.

10/30/17 Telephone conference w/M. Nazario (counsel to 0.40

Trinity) re vendor payment status.

10/31/17 Correspond w/O. Fernandez re conference call 0.50

re vendor payments (Liberty Cable); telephone

conference w/O. Fernandez re same.

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 43 of 47
11/1/17 Review memos from M. Velez-Pastrana re various clients 0.60

with pre-petition and post-petition payment issues (0.4); 

memos to J. Klein, D. Perez re same (0.2).

11/1/17 Review memo from J. Klein re updated call log of government 0.50

vendor pre-petition and post-petition payment issues and 

related matters; review updated call log re same; correspond 

w/J. Klein re call this week.

11/2/17 Telephone conference w/J. Klein, D. Perez re outstanding 0.70

items and follow up re payment to vendors (0.5); review 

updated chart re same (0.2).

11/2/17 Memo to M. Velez-Pastrana following up on her memo re 0.20

solar energy credits and statutory source of the credits.

11/2/17 Review memo from M. Nazario and attached non-payment 0.30

schedule re Trinity Services’ outstanding invoices for 

post-petition services rendered to the Puerto Rico 

Corrections Department.

11/3/17 Correspond w/M. Velez-Pastrana re green energy fund 0.20

(vendor non-payment issue).

11/3/17 Memo to M. Nazario (counsel for Trinity Services) re 0.20

outstanding vendor payments for post-petition services 

rendered to the Puerto Rico Corrections Department.

11/6/17 Memo to J. Klein, D. Perez re following up on memo from 0.20

M. Velez-Pastrana re outstanding post-petition payments to 

one of her commercial clients.

11/7/17 Review memo from M. Velez-Pastrana re copy of draft 2.60

contract in the Family Department overdue rent lease matter 

(vendor pre-petition and post-petition payment) (0.1); review 

draft contract re same (0.8); memo to J. Klein, D. Perez

re same (0.2); review memo from M. Velez-Pastrana re 

outstanding payment (vendor) re UPR’s Medical Sciences 

Campus and vendor Reparto Metropolitano Shopping Center

(0.2); memos to M. Velez-Pastrana, D. Perez, J. Klein re same

(0.3); correspond w/M. Velez-Pastrana re Reparto Metropolitano 

(Family Department, lease, payment of post-petition rent) re 

post-petition invoices (0.3); review post-petition invoices (0.5); 

memo to J. Klein, D. Perez re same (0.2).

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 44 of 47
11/7/17 Correspond w/J. Klein (Ankura Consulting) re vendor 0.90

dispute re post-petition payments and lease contract reflecting 

terms and conditions re same (0.2); review contract re same (0.7).

11/8/17 Correspond w/M. Velez-Pastrana re terms and conditions 0.70

of lease contract of premises used by PR’s Family 

Department (0.2); review lease contract re same (0.5).

11/8/17 Review memo from Y. Menendez (Telefonica USA’s and 0.20

Telefonica Larga Distancia’s attorney) re government vendor 

issue (cessation of voice service to PR clients).

11/9/17 Telephone conferences w/Y. Menendez (Telefonica USA’s and 1.00

Telefonica Larga Distancia’s attorney) re government vendor 

issue (cessation of voice service to PR clients) (0.8); telephone 

conference w/D. Perez re same (0.2).

11/9/17 Correspond w/M. Velez-Pastrana re Puerto Rico Family 1.00

Department’s lease contract (vendor issue re post-petition 

nonpayment) (0.3); correspond w/J. Klein re same (0.2); 

review lease contract re same (0.5).

11/10/17 Review memo from M. Velez-Pastrana containing a copy 1.00

of the Family Department contract without duplicate pages 

(0.1); review contract re same (0.7); memo to J. Klein, D. 

Perez re same (0.2).

11/13/17 Correspond w/J. Klein (Ankura Consulting) re weekly 0.20

call log with outstanding vendor issues and conference call 

re same.

11/14/17 Review memo from J. Klein re weekly call log conference call. 0.10

11/16/17 Review memo from Y. Menendez (counsel to Telefonica) re 0.30

current clients from Puerto Rico government, discontinuation 

of service; memo to D. Perez, J. Klein, I. Garau re same.

11/16/17 Correspond w/J. Klein re conference call to discuss 0.20

vendor issues and solutions.

11/17/17 Telephone conference w/J. Klein, D. Perez, I. Garau re 0.70

vendor issues and solutions (0.50); review vendor issues 

log re same (0.2). 

11/29/17 Review memo from J. Klein re vendor issues 0.40

log and conference call today re same; review

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 45 of 47
vendor log; review memo from I. Garau re same.

11/30/17 Telephone conference with V. Sepulveda (counsel 0.40

to Puerto Rico’s Department of Health) re 

Cesar Castillo dispute.

12/6/17 Telephone conference w/AAFAF and Ankura teams re 0.50

government vendor issues; review weekly vendor

chart w/updates re same.

12/6/17 Correspond w/I. Garau re follow-up from call re vendor 0.20

issues and Family Department matter.

12/7/17 Telephone conference w/I. Garau re vendor issue re 0.20

Department of the Family contract.

12/8/17 Telephone conference w/M. Vélez-Pastrana re vendor 0.40

non-payment issues re: Department of the Family,

Puerto Rico Green Fund.

12/8/17 Review memo from V. Sepulveda (Puerto Rico Health 0.10

Department) re upcoming meeting with vendor Cesar

Castillo.

12/12/17 Review memo from M. Velez-Pastrana re draft lease contract 0.50

with Puerto Rico Family Department; review draft contract re

same.

12/15/17 Conference w/Department of Health legal counsel, 5.50

representatives from Cesar Castillo re pending legal

dispute and lift stay notice process (3.0); review 

case-related documents in preparation for meeting with 

Cesar Castillo’s representatives (2.0); telephone conferences 

w/I. Garau re same (0.5).

12/20/17 Memos to and from J. Klein re scheduling vendor 0.20

issues conference call.

12/20/17 Review memo from M. Nazario (counsel for Trinity) 0.50

re new issues with vendor payment; review attached

document reflecting pending payments.

12/21/17 Memo to M. Nazario responding to his inquiry regarding 0.40

overdue vendor payments; memo to J. Klein, D. Perez re

same.

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 46 of 47
12/22/17 Memos to and from J. Klein re conference call to 3.20

discuss pending vendor issues (0.2); review pending

vendor matters and analyze next steps re same (3.0).

12/26/17 Review memos from P. Friedman, M. Yassin re 3.00

payments due to legal professionals (0.3); memos to 

and from P. Friedman re same (0.2); review draft motion

re same (0.3); revise motion (0.3); memo to P. Friedman re

same (0.1); review memo from P. Friedman with changes

to draft (0.2); memo to P. Friedman, M. Yassin re final

draft of motion and filing re same (0.4); memos to and 

from P. Friedman re draft motion with further updates 

on payment status of legal professionals (0.3); review 

and revise draft motions re same (0.4); memo to I. Blumberg 

re same (0.1); review memo from P. Friedman re all pending 

payments made (0.1); review memos to and from P. Friedman 

and retirees committee re payment status and potential mootness 

of any further motion practice on the subject (0.3). 

12/26/17 Memos to and from J. Klein re conference call 0.20

to discuss vendor matters.

12/26/17 Review memos from D. Perez, H. Bauer re vendor 0.50

request for clarification re government leases.

12/27/17 Telephone conference w/J. Klein, D. Perez re 0.70

vendor payment issues (0.5); review vendor call

log re same (0.2).

12/27/17 Review memo from J. Klein re contact person 0.20

in Puerto Rico Department of Corrections 

regarding Trinity vendor payment issue.

Total Hours: 33.00

Total Fees: $11,550.00

For Professional Services rendered: 

Hours Amount

Andrés W. López, Esq. 217.30 $76,055.00

Case:17-03283-LTS Doc#:2781 Filed:03/21/18 Entered:03/21/18 17:08:42 Desc: Main

Document Page 47 of 47