Exhibit D 

Budget Plan

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 1 of 15
Exhibit D-1 

Budget Plan for the Period of October 1, 2017 through October 31, 2017 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 2 of 15
2 

PROJECT 

CATEGORY 

TASK 

CODE OCTOBER OCTOBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 0 – 10 $0 - $7,300 0.00 $0.00 

Legal Research 202 0 – 10 $0 - $7,300 2.10 $1,053.00 

Hearings and other nonfiled communications 

with the Court 

203 10 – 25 $7,300 - 

$18,250 15.20 $11,096.00 

Communications with 

Claimholders 204 5 – 15 $3,650 - $10,950 9.30 $6,789.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 20 – 45 $14,600 - 

$32,850 36.20 $26,426.00 

Documents Filed on 

Behalf of the Board 206 60 – 85 $43,800 - $62,050 76.20 $55,626.00 

Non-Board Court Filings 

207 40 – 65 $29,200 - 

$47,450 41.90 $30,587.00 

Stay Matters 208 0 – 10 $0 - $7,300 0.00 $0.00 

Adversary Proceeding 209 0 – 10 $0 - $7,300 1.30 $949.00 

Analysis and Strategy 210 20 – 45 $14,600 - 

$32,850 34.90 $24,373.00 

Non-Working Travel 

Time 211 0 – 10 $0 - $7,300 0.00 $0.00 

General Administration 212 20 – 45 $14,600 - 

$32,850 16.90 $4,225.00 

Labor, Pension Matters 213 0 – 10 $0 - $7,300 0.00 $0.00 

Legal/Regulatory 

Matters 214 0 – 10 $0 - $7,300 0.00 $0.00 

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 - $7,300 0.00 $0.00 

Confirmation 216 0 – 10 $0 - $7,300 0.00 $0.00 

Tax 217 0 – 10 $0 - $7,300 0.00 $0.00 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 3 of 15
3 

PROJECT 

CATEGORY 

TASK 

CODE OCTOBER OCTOBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Employment and Fee 

Applications 218 0 – 10 $0 - $7,300 0.00 $0.00 

Appeal 219 5 – 15 $3,650 - 

$10,950 0.00 $0.00 

TOTALS 180 - 450 $131,400 - 

$328,500 234.00 $161,124.00 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 4 of 15
4 

Exhibit D-2 

Budget Plan for the Period of November 1, 2017 through November 30, 2017 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 5 of 15
5 

PROJECT 

CATEGORY 

TASK 

CODE NOVEMBER NOVEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 0 – 10 $0 - $7,300 1.00 $730.00 

Legal Research 202 5 – 15 $3,650 - 

$10,950 8.10 $4,617.00 

Hearings and other nonfiled communications 

with the Court 

203 0 – 10 $0 - $7,300 0.20 $146.00 

Communications with 

Claimholders 204 0 – 10 $0 - $7,300 4.80 $3,504.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 10 – 25 $7,300- 

$18,250 10.40 $7,592.00 

Documents Filed on 

Behalf of the Board 206 200 – 255 $146,000 - $186,150 238.90 $172,765.00 

Non-Board Court Filings 

207 60 – 85 $43,800 - 

$62,050 61.90 $45,187.00 

Stay Matters 208 0 – 10 $0 - $7,300 1.40 $350.00 

Adversary Proceeding 209 0 – 10 $0 - $7,300 0.00 $0.00 

Analysis and Strategy 210 40 – 65 $29,200 - 

$47,450 41.50 $30,295.00 

Non-Working Travel 

Time 211 0 – 10 $0 - $7,300 0.00 $0.00 

General Administration 212 10 – 25 $7,300 - 

$18,250 15.20 $4,328.00 

Labor, Pension Matters 213 0 – 10 $0 - $7,300 0.00 $0.00 

Legal/Regulatory 

Matters 214 0 - 10 $0 - $7,300 0.00 $0.00 

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 - $7,300 0.00 $0.00 

Confirmation 216 0 – 10 $0 - $7,300 0.00 $0.00 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 6 of 15
6 

PROJECT 

CATEGORY 

TASK 

CODE NOVEMBER NOVEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tax 217 0 – 10 $0 - $7,300 0.00 $0.00 

Employment and Fee 

Applications 218 0 – 10 $0 - $7,300 18.20 $4,742.00 

Appeal 219 0 – 10 $0 - $7,300 0.00 $0.00 

TOTALS 325 - 600 $237,250 - 

$438,000 401.60 $274,256.00 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 7 of 15
7 

Exhibit D-3 

Budget Plan for the Period of December 1, 2017 through December 31, 2017 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 8 of 15
8 

PROJECT 

CATEGORY 

TASK 

CODE DECEMBER DECEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 0 – 10 $0 - $7,300 0.00 $0.00 

Legal Research 202 5 – 15 $3,650 - 

$10,950 6.00 $4,380.00 

Hearings and other nonfiled communications 

with the Court 

203 0 – 10 $0 - $7,300 0.60 $438.00 

Communications with 

Claimholders 204 0 – 10 $0 - $7,300 0.70 $511.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 0 – 10 $0 - $7,300 2.20 $1,606.00 

Documents Filed on 

Behalf of the Board 206 60 – 85 $43,800 - $62,050 75.00 $53,934.00 

Non-Board Court Filings 

207 20 - 45 $14,600 - 

$32,850 30.00 $21,900.00 

Stay Matters 208 0 – 10 $0 - $7,300 0.00 $0.00 

Adversary Proceeding 209 0 – 10 $0 - $7,300 1.80 $1,314.00 

Analysis and Strategy 210 5 – 15 $3,650 - 

$10,950 9.40 $4,078.00 

Non-Working Travel 

Time 211 0 – 10 $0 - $7,300 0.00 $0.00 

General Administration 212 5 – 15 $3,650 - 

$10,950 10.60 $2,650.00 

Labor, Pension Matters 213 0 – 10 $0 - $7,300 0.00 $0.00 

Legal/Regulatory 

Matters 214 0 – 10 $0 - $7,300 0.00 $0.00 

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 - $7,300 0.00 $0.00 

Confirmation 216 0 – 10 $0 - $7,300 0.00 $0.00 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 9 of 15
9 

PROJECT 

CATEGORY 

TASK 

CODE DECEMBER DECEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tax 217 0 – 10 $0 - $7,300 0.00 $0.00 

Employment and Fee 

Applications 218 10 – 25 $7,300 - $18,250 16.70 $4,895.00 

Appeal 219 0 – 10 $0 - $7,300 0.80 $200.00 

TOTALS 105 - 330 $76,650 – 

$240,900 153.80 $95,906.00 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 10 of 15
10 

Exhibit D-4 

Budget Plan for the Period of January 1, 2018 through January 31, 2018 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 11 of 15
11 

PROJECT 

CATEGORY 

TASK 

CODE JANUARY 2018 JANUARY 2018 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 20 – 50 $15,200 - 

$38,000 0.30 $227.70 

Legal Research 202 30 – 50 $22,800 - 

$38,000 0.30 $227.70 

Hearings and other nonfiled communications 

with the Court 

203 20 – 40 $15,200 - 

$30,400 0.00 $0.00 

Communications with 

Claimholders 204 30 – 60 $22,800 - $45,600 4.60 $3,491.40 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 20 – 50 $15,200 - 

$38,000 5.20 $3,946.80 

Documents Filed on 

Behalf of the Board 206 100 – 200 $76,000 - $152,000 17.00 $12,903.00 

Non-Board Court Filings 

207 20 – 60 $15,200 - 

$45,600 8.30 $6,299.70 

Stay Matters 208 0 – 15 $0 - $11,400 0.00 $0.00 

Adversary Proceeding 209 0 – 5 $0 - $3,800 1.00 $759.00 

Analysis and Strategy 210 20 – 40 $15,200 - 

$30,400 2.70 $2,049.30 

Non-Working Travel 

Time 211 0 – 5 $0 - $3,800 0.00 $0.00 

General Administration 212 20 – 40 $15,200 - 

$30,400 1.10 $286.00 

Labor, Pension Matters 213 0 – 5 $0 - $3,800 0.00 $0.00 

Legal/Regulatory 

Matters 214 0 – 5 $0 - $3,800 0.00 $0.00 

Plan of Adjustment and 

Disclosure Statement 215 50 – 100 $38,000 - $76,000 0.00 $0.00 

Confirmation 216 0 – 5 $0 - $3,800 0.80 $607.20 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 12 of 15
12 

PROJECT 

CATEGORY 

TASK 

CODE JANUARY 2018 JANUARY 2018 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tax 217 10 – 20 $7,600 - 

$15,200 0.00 $0.00 

Employment and Fee 

Applications 218 65 – 80 $49,400 - $60,800 0.60 $156.00 

Appeal 219 0 – 20 $0 - $15,200 0.00 $0.00 

TOTALS 405 - 850 $307,800 – 

$646,000 41.90 $30,953.80 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 13 of 15
13 

Exhibit D-5 

Staffing Plan for the Compensation Period 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 14 of 15
14 

Staffing Plan for the Compensation Period 

Category of Timekeeper1 Number of 

Timekeepers Expected 

to Work on The Matter 

During the Budget Period2

Average Hourly Rate3

Partners 17 $730/ $759 

Senior Counsel 1 $730/ $759 

Associates 13 $730/ $759 

Law Clerks 3 $250/ $260 

Paraprofessionals 14 $250/ $260 

 

1

 Attorney Practice Groups: Bankruptcy (11); Litigation (19); Corporate (1). 

2

 The chart reflects Proskauer’s staffing plan for the designated period based on currently foreseeable activities. 

Actual staffing needs, including additional attorneys, may vary materially based on actual facts and circumstances 

arising in the designated period, including as a result of currently unanticipated disputes. The staffing plan 

currently includes attorneys from the Business Solutions, Governance, Restructuring & Bankruptcy Group 

(BSGR&B); Litigation; and Corporate practice groups. The expertise of attorneys from other specialized areas is 

likely to be required during the course of these PROMESA cases. 

3

 In the ordinary course of business, the standard hourly billing rates for Proskauer professionals and 

paraprofessionals are adjusted annually as of the commencement of the firm’s fiscal year on November 1 to 

reflect economic and other conditions and apply to matters in and out of bankruptcy cases. Pursuant to the 

Appendix B Guidelines, “rate increases” “exclude annual ‘step increases’ historically awarded by the firm in the 

ordinary course to attorneys throughout the firm due to advancing seniority and promotion.” Appendix B 

Guidelines ¶ B.2.d, n.2. Annual step increases are awarded by Proskauer in the ordinary course throughout the 

firm on May 1. Proskauer’s November 25, 2016 engagement letter with the Oversight Board (a copy of which is 

available on the Oversight Board’s website at https://juntasupervision.pr.gov/wp-content/uploads/wpfd/50/ 

58b6126be2546.pdf) (the “Engagement Letter”) provides that Proskauer’s rates will be increased on January 1 

(rather than on November 1) by the lower of the percentage rate increase announced as of November 1 and four 

percent. Because Proskauer’s fees under the Engagement Letter are a blended rate (currently $759) for all 

attorneys and (currently $260) for all other professionals, no annual step increases will be applicable to the rates 

charged in this matter. 

Case:17-03283-LTS Doc#:2870-4 Filed:04/09/18 Entered:04/09/18 19:53:34 Desc:

Exhibit D Page 15 of 15