EXHIBIT D

BUDGET AND STAFFING PLAN

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 1 of 19
EXHIBIT D-1

BUDGETS FOR:

February 2023

March 2023

April 2023

May 2023

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 2 of 19
EXHIBIT D-1

BUDGETS

Period Covered: February 1, 2023 – February 28, 2023

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

February

2023

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 10

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 10

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 1

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 1

B191 General Litigation 210

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 3 of 19
B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 262

TOTAL FEES: $121,830

MINUS 20%

REDUCTION: $24,366

TOTAL FEES:

(NET OF REDUCTION) $97,464

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 4 of 19
ADDITIONAL FEBRUARY 2023 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: February 1, 2023 through February 28, 2023

A. Contested Matters 

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

matters arising from or relating to PREPA’s contested confirmation process and plan discovery; 

matters arising from or relating to UBS Financial’s Motion to Enforce the Commonwealth's 

Confirmed Plan of Adjustment; and anticipated, litigated contested matters that are currently under 

advisement by the Committee. 

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 5 of 19
Period Covered: March 1, 2023 – March 31, 2023

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

March 2023

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 10

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 10

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 1

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 1

B191 General Litigation 245

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 6 of 19
B410 General Bankruptcy Advice and Opinions 0

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 297

TOTAL FEES: $138,105

MINUS 20%

REDUCTION: $27,621

TOTAL FEES:

(NET OF REDUCTION) $110,484

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 7 of 19
ADDITIONAL MARCH 2023 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: March 1, 2023 through March 31, 2023

A. Contested Matters 

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

matters arising from or relating to PREPA’s contested confirmation process and plan discovery; 

matters arising from or relating to UBS Financial’s Motion to Enforce the Commonwealth's 

Confirmed Plan of Adjustment; and anticipated, litigated contested matters that are currently under 

advisement by the Committee. 

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 8 of 19
Period Covered: April 1, 2023 – April 30, 2023

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

April 2023

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 10

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 10

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 1

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 1

B191 General Litigation 265

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

B410 General Bankruptcy Advice and Opinions 0

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 9 of 19
B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 317

TOTAL FEES: $147,405

MINUS 20% REDUCTION: $29,481

TOTAL FEES:

(NET OF REDUCTION)

$117,924

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 10 of 19
ADDITIONAL APRIL 2023 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: April 1, 2023 through April 30, 2023

A. Contested Matters 

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

matters arising from or relating to PREPA’s contested confirmation process and plan discovery; 

matters arising from or relating to UBS Financial’s Motion to Enforce the Commonwealth's 

Confirmed Plan of Adjustment; and anticipated, litigated contested matters that are currently under 

advisement by the Committee. 

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 11 of 19
Period Covered: May 1, 2023 – May 31, 2023

U.S. TRUSTEE TASK CODE

AND PROJECT CATEGORY

May 2023

B100 Administration 0

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 10

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay/Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with Creditors 3

B155 Court Hearings (including Preparation for Court Hearings) 10

B160 Employment/Fee Applications (Continental) 10

B161 Budgeting (Case) 1

B165 Employment / Fee Application (Other Professionals) 0

B170 Fee and Employment Objections 1

B180 Avoidance Action Analysis 1

B181 Preference Analysis and Recovery Action 0

B185 Assumption/Rejection of Leases and Contracts 0

B190 Other Contested Matters (including GDB restructuring) 1

B191 General Litigation 265

B195 Non-Working Travel 0

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits /Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings/Communications with Debtors/Oversight Board 10

B261 Investigations 0

B300 Claims and Plan 0

B310 Claims Administration and Objections 0

B312 Objections to Claims 0

B320 Plan and Disclosure Statement 0

B321 Business Plan 0

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

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

B420 Restructurings 0

L150 Budgeting 0

TOTAL HOURS: 317

TOTAL FEES: $147,405

MINUS 20%

REDUCTION:

$29,481

TOTAL FEES:

(NET OF REDUCTION)

$117,924

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 13 of 19
ADDITIONAL MAY 2023 SUB-BUDGETS

FOR MATTERS JOINTLY PURSUED BY OVERSIGHT BOARD AND COMMITTEE

Period Covered: May 1, 2023 through May 31, 2023

A. Contested Matters 

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

matters arising from or relating to PREPA’s contested confirmation process and plan discovery; 

matters arising from or relating to UBS Financial’s Motion to Enforce the Commonwealth's 

Confirmed Plan of Adjustment; and anticipated, litigated contested matters that are currently under 

advisement by the Committee. Continental anticipates its involvement in these matters as it relates 

to conflict issues.

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 14 of 19
EXHIBIT D-2

STAFFING PLAN 

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 15 of 19
Period Covered: February 1, 2023 through February 28, 2023.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 10/1/22 

through 10/31/22

Average hourly rate 

for 10/1/22 through 

10/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 16 of 19
Period Covered: March 1, 2023 through March 31, 2023.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 11/01/22 

through 11/30/22

Average hourly rate 

for 11/01/22 through 

11/30/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 17 of 19
Period Covered: April 1, 2023 through April 30, 2023.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period

Average hourly rate 

for period 12/01/22 

through 12/31/22

Average hourly rate 

for 12/01/22 through 

12/31/22 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 2 $375 $300

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 18 of 19
Period Covered: May 1, 2023 through May 31, 2023.

Category of 

timekeeper 

(using categories 

maintained by 

the firm)

Number of 

timekeepers 

expected to work on 

the matter during 

the budget period

Average hourly rate 

for period 01/01/23

through 01/31/23

Average hourly rate 

for 01/01/23 through 

01/31/23 (net of 20%

reduction)

Partner

(20+ Years) 

1 $575 $460

Partner 

(10+ Years) 

1 $525 $420

Associate 3 $315 $252

Paraprofessionals 1 $135 $108

Case:17-03283-LTS Doc#:24740-4 Filed:07/14/23 Entered:07/14/23 15:19:47 Desc:

Exhibit D Page 19 of 19