EXHIBIT C

BUDGET AND STAFFING PLAN

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Exhibit C Page 1 of 21
1

EXHIBIT C-1

BUDGET

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

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

B110 Case Administration 10

B112 General Creditor Inquiries 0

B113 Pleadings Review 70

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 12

B155 Court Hearings 10

B160 Employment / Fee Applications 3

B161 Budgeting (Case) 2

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions 0

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 45

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, 

and handling of adversary proceedings)

75

B195 Non-Working Travel25

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

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

budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will require discovery 

and trial preparation; and (iv) all adversary proceedings in which the Committee has intervened and/or sought to 

intervene will only involve briefing and hearings on motions to dismiss. In addition, it is impossible to predict how 

many hours will be required to prosecute the Committee’s anticipated challenge to certain GO bond claims, including 

because it is impossible to predict the number and extent of objections filed in response thereto. Thus, this proposed 

budget may be materially different from the work actually performed. For instance, discovery disputes may lead to 

extensive litigation. Similarly, the Committee may need to respond to motions that are not and cannot be anticipated. 

At this time, the proposed budget is speculative. 

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

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Exhibit C Page 2 of 21
2

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations (including Renewed Rule 2004) 0

B310 Claims Administration and Objections 80

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 15

B420 Restructurings 70

TOTAL HOURS 399

TOTAL ESTIMATED FEE $99,351.003

3 The Total Estimated Fees are calculated based on a $249 blended hourly rate for the CST Law attorneys who are 

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

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Exhibit C Page 3 of 21
3

ADDITIONAL JUNE 2022 SUB-BUDGETS FOR MATTERS JOINTLY PURSUED BY 

OVERSIGHT BOARD AND COMMITTEE

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee 

Retirement System (ERS) and the Puerto Rico Electric Power Authority Company 

(PREPA)

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking 

over the prosecution of the garden variety avoidance actions.

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

Lien Challenges)

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

GO Lien Challenges are resolved.

C. Omnibus Objection of Oversigh Board and Committee to 2012-2014 GO Bond 

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

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

Omnibus GO Claims Objections are resolved.

D. Adversary Proceeding Against Underwriters, Etc.

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over 

the prosecution of the underwriter litigation.

E. Other Co-Plaintiff Adversary Proceedings

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

following adversary proceedings are resolved:

• Eight adversary proceedings seeking to recover fraudulent transfers made on 

account of GO bonds that were not validly issued [Adv. Proc. No. 19-281, Adv. Proc. No. 

19-282, Adv. Proc. No. 19-283, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. 

Proc. No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

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

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

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

and Adv. Proc. No. 19-361].

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Exhibit C Page 4 of 21
4

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

which the Committee has been appointed as co-plaintiff/co-trustee with the Oversight 

Board) remain stayed pending confirmation of an HTA plan of adjustment or further 

order of the court.

• Four adversary proceedings challenging liens asserted by certain holders of HTA 

bonds [Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. 

Proc. No. 19-365].

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Exhibit C Page 5 of 21
5

Period Covered: July 1, 2022 through July 31, 20224

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

B110 Case Administration 10

B112 General Creditor Inquiries 0

B113 Pleadings Review 70

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 15

B155 Court Hearings 10

B160 Employment / Fee Applications 20

B161 Budgeting (Case) 3

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 50

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, and 

handling of adversary proceedings) 85

B195 Non-Working Travel5

5

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

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

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

budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will require discovery 

and trial preparation; and (iv) all adversary proceedings in which the Committee has intervened and/or sought to 

intervene will only involve briefing and hearings on motions to dismiss. In addition, it is impossible to predict how 

many hours will be required to prosecute the Committee’s anticipated challenge to certain GO bond claims, including 

because it is impossible to predict the number and extent of objections filed in response thereto. Thus, this proposed 

budget may be materially different from the work actually performed. For instance, discovery disputes may lead to 

extensive litigation. Similarly, the Committee may need to respond to motions that are not and cannot be anticipated. 

At this time, the proposed budget is speculative. 

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

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Exhibit C Page 6 of 21
6

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations 0

B310 Claims Administration and Objections 70

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 15

B420 Restructurings 35

TOTAL HOURS 390

TOTAL ESTIMATED FEE $97,110.006

6 The Total Estimated Fees are calculated based on a $249 blended hourly rate for the CST Law attorneys who are 

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

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Exhibit C Page 7 of 21
7

ADDITIONAL JULY 2022 SUB-BUDGETS FOR MATTERS JOINTLY PURSUED BY 

OVERSIGHT BOARD AND COMMITTEE

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee 

Retirement System (ERS) and the Puerto Rico Electric Power Authority Company 

(PREPA)

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking 

over the prosecution of the garden variety avoidance actions.

B. Adversary Proceedings Challenging Liens Aserted by Holders of GO Bonds 

(“GO Lien Challenges)

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

GO Lien Challenges are resolved.

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

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

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

Omnibus GO Claims Objections are resolved.

D. Adversary Proceeding Against Underwriters, Etc.

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over 

the prosecution of the underwriter litigation.

E. Other Co-Plaintiff Adversary Proceedings

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

following adversary proceedings are resolved:

• Eight adversary proceedings seeking to recover fraudulent transfers made on 

account of GO bonds that were not validly issued [Adv. Proc. No. 19-281, Adv. Proc. No. 

19-282, Adv. Proc. No. 19-283, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

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

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

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

Adv. Proc. No. 19-361].

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

which the Committee has been appointed as co-plaintiff/co-trustee with the Oversight 

Board) remain stayed pending confirmation of an HTA plan of adjustment or further order 

of the court.

• Four adversary proceedings challenging liens asserted by certain holders of HTA 

bonds [Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. 

Proc. No. 19-365].

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Exhibit C Page 9 of 21
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Period Covered: August 1, 2022 through August 31, 20227

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

B110 Case Administration 15

B112 General Creditor Inquiries 0

B113 Pleadings Review 70

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 15

B155 Court Hearings 10

B160 Employment / Fee Applications 5

B161 Budgeting (Case) 3

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 55

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, and 

handling of adversary proceedings) 85

B195 Non-Working Travel8

5

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

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

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

budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will require discovery 

and trial preparation; and (iv) all adversary proceedings in which the Committee has intervened and/or sought to 

intervene will only involve briefing and hearings on motions to dismiss. In addition, it is impossible to predict how 

many hours will be required to prosecute the Committee’s anticipated challenge to certain GO bond claims, including 

because it is impossible to predict the number and extent of objections filed in response thereto. Thus, this proposed 

budget may be materially different from the work actually performed. For instance, discovery disputes may lead to 

extensive litigation. Similarly, the Committee may need to respond to motions that are not and cannot be anticipated. 

At this time, the proposed budget is speculative. 

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

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Exhibit C Page 10 of 21
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B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations (including Renewed Rule 2004) 0

B310 Claims Administration and Objections 40

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 15

B420 Restructurings 55

TOTAL HOURS 375

TOTAL ESTIMATED FEE $93,375.009

9 The Total Estimated Fees are calculated based on a $249 blended hourly rate for the CST Law attorneys who are 

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

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Exhibit C Page 11 of 21
11

ADDITIONAL AUGUST 2022 SUB-BUDGETS FOR MATTERS JOINTLY PURSUED 

BY OVERSIGHT BOARD AND COMMITTEE

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee 

Retirement System (ERS) and the Puerto Rico Electric Power Authority Company 

(PREPA)

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

over the prosecution of the garden variety avoidance actions.

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

Lien Challenges)

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

Lien Challenges are resolved.

C. Omnibus Objection of Oversigh Board and Committee to 2012-2014 GO Bond 

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

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

2022), the Omnibus GO Claims Objections are resolved.

D. Adversary Proceeding Against Underwriters, Etc.

Under the Commonwealth plan of adjustment, the Avoidance Action Trustee is taking over 

the prosecution of the underwriter litigation.

E. Other Co-Plaintiff Adversary Proceedings

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

following adversary proceedings are resolved:

• Eight adversary proceedings seeking to recover fraudulent transfers made on 

account of GO bonds that were not validly issued [Adv. Proc. No. 19-281, Adv. Proc. No. 

19-282, Adv. Proc. No. 19-283, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

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

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Exhibit C Page 12 of 21
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regarding ultra vires issues with respect to ERS Bonds [Adv. Proc. No. 19-355, Adv. Proc. 

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

Adv. Proc. No. 19-361].

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

which the Committee has been appointed as co-plaintiff/co-trustee with the Oversight 

Board) remain stayed pending confirmation of an HTA plan of adjustment or further order 

of the court.

• Four adversary proceedings challenging liens asserted by certain holders of HTA 

bonds [Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. 

Proc. No. 19-365].

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Exhibit C Page 13 of 21
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Period Covered: September 1, 2022 through September 30, 2022

10

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

B110 Case Administration 15

B112 General Creditor Inquiries 0

B113 Pleadings Review 70

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 15

B155 Court Hearings 10

B160 Employment / Fee Applications 5

B161 Budgeting (Case) 3

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 55

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, and 

handling of adversary proceedings) 75

B195 Non-Working Travel11 3

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

B230 Financing / Cash Collections 0

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

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

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

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

on motions to dismiss. In addition, it is impossible to predict how many hours will be required to prosecute the 

Committee’s challenges to certain GO and ERS bond claims, including because it is impossible to predict the number 

and extent of objections filed in response thereto. Thus, this proposed budget may be materially different from the 

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

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

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

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Exhibit C Page 14 of 21
14

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations (including Renewed Rule 2004) 0

B310 Claims Administration and Objections 15

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 10

B420 Restructurings 50

TOTAL HOURS 328

TOTAL ESTIMATED FEE $81,672.0012

12 The Total Estimated Fees are calculated based on a $249 blended hourly rate for the CST Law attorneys who are 

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

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Exhibit C Page 15 of 21
15

ADDITIONAL SEPTEMBER 2022 SUB-BUDGETS FOR MATTERS JOINTLY 

PURSUED BY OVERSIGHT BOARD AND COMMITTEE

A. Garden Variety Avoidance Actions Against Vendors of the Commonwealth, the 

Puerto Rico Highways and Transportation Authority (HTA), the Employee 

Retirement System (ERS) and the Puerto Rico Electric Power Authority Company 

(PREPA)

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

over the prosecution of the garden variety avoidance actions.

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

Lien Challenges)

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

GO Lien Challenges are resolved.

C. Omnibus Objection of Oversigh Board and Committee to 2012-2014 GO Bond 

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

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

Omnibus GO Claims Objections are resolved.

D. Adversary Proceeding Against Underwriters, Etc.

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

over the prosecution of the underwriter litigation.

E. Other Co-Plaintiff Adversary Proceedings

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

following adversary proceedings are resolved:

• Eight adversary proceedings seeking to recover fraudulent transfers made on 

account of GO bonds that were not validly issued [Adv. Proc. No. 19-281, Adv. Proc. No. 

19-282, Adv. Proc. No. 19-283, Adv. Proc. No. 19-284, Adv. Proc. No. 19-285, Adv. Proc. 

No. 19-286, Adv. Proc. No. 19-287, and Adv. Proc. No. 19-288]; and

• Two adversary proceedings regarding lien scope issues with respect to ERS bonds 

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

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

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

Adv. Proc. No. 19-361].

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Exhibit C Page 16 of 21
16

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

which the Committee has been appointed as co-plaintiff/co-trustee with the Oversight 

Board) remain stayed pending confirmation of an HTA plan of adjustment or further order 

of the court.

• Four adversary proceedings challenging liens asserted by certain holders of HTA 

bonds [Adv. Proc. No. 19-362, Adv. Proc. No. 19-363, Adv. Proc. No. 19-364, and Adv. 

Proc. No. 19-365].

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Exhibit C Page 17 of 21
17

EXHIBIT C-2

STAFFING PLAN

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

13

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

Partner 4 $270

Member 1 $270

Counsel 2 $260

Junior Partner 2 $240

Senior Associate 2 $200

Associate 1 $170

Paraprofessionals 1 $95

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

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

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

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

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

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

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

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Exhibit C Page 18 of 21
18

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

14

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

Partner 4 $270

Member 1 $270

Counsel 2 $260

Junior Partner 2 $240

Senior Associate 2 $200

Associate 1 $170

Paraprofessionals 1 $95

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

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

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

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

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

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

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

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Exhibit C Page 19 of 21
19

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

15

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

Partner 3 $270

Member 2 $270

Counsel 2 $260

Junior Partner 3 $240

Senior Associate 1 $200

Associate 1 $170

Paraprofessionals 1 $95

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

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

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

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

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

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

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

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Exhibit C Page 20 of 21
20

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

16

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

Partner 3 $270

Member 2 $270

Counsel 2 $260

Junior Partner 3 $240

Senior Associate 1 $200

Associate 2 $170

Paraprofessionals 1 $95

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

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

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

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

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

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

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

Case:17-03283-LTS Doc#:22873-5 Filed:11/15/22 Entered:11/15/22 18:14:56 Desc:

Exhibit C Page 21 of 21