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

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

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

PROMESA 

Title III 

 

as representative of Case No. 17-BK-3283 (LTS) 

THE COMMONWEALTH OF PUERTO RICO, et al., (Jointly Administered) 

Debtors.1 

 

SECOND INTERIM APPLICATION OF BETTINA M. WHYTE, 

IN HER CAPACITY AS THE COFINA AGENT, FOR INTERIM 

ALLOWANCE OF COMPENSATION FOR SERVICES 

RENDERED AND REIMBURSEMENT OF EXPENSES INCURRED 

FROM OCTOBER 1, 2017 THROUGH JANUARY 31, 2018

 

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). 

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EXHIBITS 

Exhibit 1 – Certification of Bettina M. Whyte 

Exhibit 2 – Summary of Professionals for the Application Period 

Exhibit 3 – Summary of Expenses for the Application Period 

Exhibit 4 – Summary of Time by Billing Category for the Application Period 

Exhibit 4-A – Time and Expense Detail for the October Fee Statement 

Exhibit 4-B – Time and Expense Detail for the November Fee Statement 

Exhibit 4-C – Time and Expense Detail for the December Fee Statement 

Exhibit 4-D – Time and Expense Detail for the January Fee Statement 

 

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SUMMARY SHEET TO THE SECOND INTERIM APPLICATION OF BETTINA M. 

WHYTE FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED 

AND REIMBURSEMENT OF EXPENSES INCURRED IN HER CAPACITY AS 

THE COFINA AGENT FROM OCTOBER 1, 2017 THROUGH JANUARY 31, 2018 

Name of Applicant Bettina M. Whyte 

Time period covered by this application October 1, 2017 through January 

31, 2018 

Total compensation incurred this period $160,945.00 

Total expenses sought this period $3,779.562

Petition date May 5, 2017 for COFINA (as 

defined below) 

Retention date August 3, 2017 

Date of order approving employment August 10, 2017 nunc pro tunc to 

August 3, 2017 

Total compensation approved by interim order to date $208,056.503

Total expenses approved by interim order to date $11,674.59 

Total allowed compensation paid to date $208,056.50 

Total allowed expenses paid to date $11,674.59 

Compensation sought in this application already paid 

pursuant to the interim compensation order but not yet 

allowed (October, November and December 2017) 

$106,168.50 

Expenses sought in this application already paid pursuant to 

the interim compensation order but not yet allowed 

(October, November and December 2017) 

$5,180.56 

 

2

 This amount reflects voluntary reductions to expenses in the amount of $1,561.00, reflecting the fee 

examiner’s views that certain expenses should be capped at certain amounts. 3

 Additionally, pursuant to an agreement with the fee examiner, $41,130.00 in fees and $5,102.57 in 

expenses are still pending review by the fee examiner and no order has been entered allowing or 

disallowing those amounts. 

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To the Honorable United States District Court Judge Laura Taylor Swain: 

Bettina M. Whyte (“Ms. Whyte”), in her capacity as the COFINA Agent (together with 

her employees, the “COFINA Agent”) in the above-captioned Title III cases (the “Title III 

Cases”), hereby submits her second interim fee application (the “Application”) for an award of 

interim compensation for professional services rendered in the amount of $160,945.00 and 

reimbursement for actual and necessary expenses in connection with such services in the amount 

of $3,779.56, for the period of October 1, 2017 through January 31, 2018 (the “Application 

Period”). The COFINA Agent submits this Application pursuant to sections 316 and 317 of the 

Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”),4 48 U.S.C. §§ 

2176, 2177; sections 105(a) and 503(b) of chapter 11 of the United States Code (the 

“Bankruptcy Code),5 Rule 2016(a) of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”),6 Rule 2016-1 of the Bankruptcy Rules for the United States Bankruptcy 

Court for the District of Puerto Rico (the “Local Rules”)7 and the First Amended Order Setting 

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals (the 

“Interim Compensation Order”) [Dkt. No. 1715]. In support of the Application, in her 

capacity as the COFINA Agent, Ms. Whyte respectfully represents: 

 

4

 PROMESA is codified at 48 U.S.C. §§ 2101–2241. 

5

 Unless otherwise noted, all Bankruptcy Code sections cited in the Application are made applicable to these 

Title III Cases pursuant to section 301(a) of PROMESA. 

6

 All Bankruptcy Rules referenced in the Application are made applicable to these Title III Cases pursuant to 

section 310 of PROMESA. 

7

 The Local Rules are made applicable to these Title III Cases by the Court’s Order (A) Imposing and 

Rendering Applicable Local Bankruptcy Rules to These Title III Cases, (B) Authorizing Establishment of 

Certain Notice, Case Management, and Administrative Procedures, and (C) Granting Related Relief [Dkt. 

No. 249]. 

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JURISDICTION AND VENUE 

1. This Court has subject matter jurisdiction over this matter pursuant to 

section 306(a) of PROMESA. 

2. Venue is proper pursuant to section 306(a) of PROMESA. 

3. The COFINA Agent makes this Application pursuant to sections 316 and 

317 of PROMESA, sections 105(a) and 503(b) of the Bankruptcy Code, Bankruptcy Rule 2016, 

Local Rule 2016-1, the Commonwealth-COFINA Stipulation (as defined below) and the Interim 

Compensation Order. 

BACKGROUND 

A. General Background 

4. 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. 

5. On May 5, 2017, the Puerto Rico Sales Tax Financing Corporation 

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

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

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

title III of PROMESA. 

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

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

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

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

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

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

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

and PREPA Title III Cases (collectively, the “Title III Cases”) are jointly administered for 

procedural purposes only pursuant to section 304(g) of PROMESA and Bankruptcy Rule 1015. 

[See Dkt. Nos. 242, 537 and 1417.] 

B. The COFINA Agent’s Retention

10. On August 10, 2017, the Court entered the Stipulation and Order 

Approving Procedure to Resolve Commonwealth-COFINA Dispute [Dkt. No. 996] (the 

“Commonwealth-COFINA Stipulation”), which appointed Ms. Whyte as the COFINA Agent. 

The Commonwealth-COFINA Stipulation also authorized COFINA to compensate her in 

accordance with the COFINA Agent’s normal hourly rates and reimburse the COFINA Agent for 

the firm’s actual and necessary out-of-pocket expenses incurred, subject to application to this 

Court as set forth herein. As set forth more fully below, pursuant to the Interim Compensation 

Order (as defined below), the COFINA Agent has filed four monthly fee statements related to 

this Application and has been paid 90%8

 of the fees and 100% of the expenses for her monthly 

fee statements for October, November, and December 2017 in accordance with the Interim 

Compensation Order, and payment for the January, 2018 fee statement is pending. Prior to the 

submission of this Application, the COFINA Agent submitted an Interim Application for the

period of August 3, 2017-September 30, 2017 (the “First Interim Fee Application”), and the 

 

8

 The Debtors erroneously paid the entire amount of the fees requested in the monthly fee statement for 

August to the COFINA Agent without accounting for the 10% holdback. In order to comply with the 

holdback requirements in the Interim Compensation Order, the COFINA Agent allocated this 10% 

overpayment as a prepayment of her fees in her fee statement for November, and reduced her fee request 

for November accordingly. 

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Court entered an order allowing that compensation (after accounting for the reductions proposed 

by the fee examiner and agreed to by the COFINA Agent). 

SUMMARY OF PROFESSIONAL COMPENSATION 

AND REIMBURSEMENT OF EXPENSES REQUESTED 

11. By this Application and pursuant to sections 316 and 317 of PROMESA, 

sections 105(a) and 503(b) of the Bankruptcy Code, Rule 2016(a) of the Bankruptcy Rules and 

Rule 2016-1 of the Local Rules, the COFINA Agent requests that this Court authorize interim 

allowance of compensation for professional services rendered and reimbursement of expenses 

incurred during the Application Period in the amount of $164,724.56 (the “Application 

Amount”), which includes (a) compensation of $160,945.00 in fees for services rendered to 

COFINA and (b) reimbursement of $3,779.569 in actual and necessary expenses in connection 

with these services. As of the date hereof, the COFINA Agent has been paid all amounts other 

than $54,776.50, which represents 10% of the COFINA Agent’s fees that have been “held back” 

(generally referred to herein as the “Holdback”) for the month of October, November and 

December, and 100% of the fees and expenses incurred during January 2018.10 

PRIOR INTERIM AWARDS AND REQUESTS 

12. The Court has entered an order [Docket No. 2685] allowing the COFINA 

Agent’s First Interim Fee Application, after including the reductions proposed by the fee 

examiner and agreed to by the COFINA Agent. 

FEES AND EXPENSES FOR THE APPLICATION PERIOD 

13. The COFINA Agent’s services in these cases have been substantial, 

necessary, and beneficial to COFINA. Throughout the Application Period, the variety and 

complexity of the issues involved and the need to address those issues on an expedited basis 

 

9

 See footnote 2. 

10 See footnote 8. 

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required the COFINA Agent, in the discharge of her professional responsibilities, to devote 

substantial time by professionals. 

14. Specifically, the COFINA Agent’s requested compensation reflects the 

requisite time, skill and effort the COFINA Agent and her employees expended during the 

Application Period towards, inter alia: (a) continuing to advance these cases to a resolution on a 

dual track of litigation and mediation; and (b) preparing for and attending various mediation 

sessions and hearings, including participating in calls with the mediators. 

MONTHLY FEE STATEMENTS 

15. The Interim Compensation Order provides, among other things, that 

professionals are required to serve monthly itemized billing statements (the “Monthly Fee 

Statements”) on counsel to the Oversight Board, counsel to AAFAF, the U.S. Trustee, counsel 

to the Official Committee of Unsecured Creditors, counsel to the Official Committee of Retired 

Employees and the Fee Examiner (collectively, the “Notice Parties”). Upon passage of the 

objection period, if no objections are received, the Debtors are authorized to pay to the 

professionals 90% of the fees and 100% of the expenses requested. In addition to the Interim 

Compensation Order authorizing payment, the COFINA Agent received further confirmation of 

the Debtors’ obligation to pay her fees pursuant to the Order Approving COFINA Agent’s 

Motion Pursuant to 48 U.S.C. § 2161 and 11 U.S.C. § 105(a) for Order: (I) Confirming that 48 

U.S.C. § 2125 Applies to COFINA Agent; (II) Confirming Retention of Local Counsel; and (III) 

Clarifying Payment of Fees and Expenses of COFINA Agent and her Professionals [Dkt. No. 

1612] (the “COFINA Protections Order”). The COFINA Protections Order directs payment to 

the COFINA Agent and her professionals out of the collateral “purportedly pledged to COFINA 

bondholders because the services of the COFINA Agent (i) serve as adequate protection for the 

collateral and/or (ii) are “reasonable” and “necessary” to protect the collateral pursuant to section 

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506(c) of the Bankruptcy Code, the Agent/Professional Fees shall be paid pursuant to the Interim 

Compensation Order or any other order of the Court. . . . .” COFINA Protections Order ¶ 5. The 

COFINA Protections Order further provides that if COFINA is unable to make payments to the 

COFINA Agent’s professionals for any reason, the Commonwealth must make such payments 

within fourteen days of receiving notice of COFINA’s nonpayment. 

16. In compliance with the Interim Compensation Order, the COFINA Agent 

has submitted Four (4) Monthly Fee Statements relating to the Application Period. Payment on 

account of these Monthly Fee Statements was requested as follows: 

(a) Pursuant to the Monthly Fee Statement for the period 

October 1, 2017 through October 31, 2017 (the “October Fee 

Statement”), the COFINA Agent requested payment of 

$38,943.30, representing the total of (i) $ 37,296.00, which is 

90% of the fees requested for services rendered (i.e., 

$41,440.00) plus (ii) $1,411.19,11 representing 100% of the 

expenses incurred during the period. 

(b) Pursuant to the Monthly Fee Statement for the period November 1, 

2017 through November 30, 2017 (the “November Fee Statement”), 

the COFINA Agent requested payment of $33,471.65, representing 

the total of (i) $46,462.50, which is 90% of the fees requested for 

services rendered (i.e., $51,625.00), plus (ii) $1,971.26,12 representing 

100% of the expenses incurred during the period, less (iii) the 

$16,021 overpayment of the August 2017 payment request.13

(c) Pursuant to the Monthly Fee Statement for the period 

December 1, 2017 through December 31, 2017 (the 

“December Fee Statement”), the COFINA Agent requested 

payment of $22,967.11, representing the total of (i) 

$22,410.00, which is 90% of the fees requested for services 

rendered (i.e., $24,900.00), plus (ii) $397.11,14 representing 

100% of the expenses incurred during the period. 

(d) Pursuant to the Monthly Fee Statement for the period January 

1, 2018 through January 31, 2018 (the “January Fee 

Statement”), the COFINA Agent requested payment of 

 

11 See footnote 2. 

12 See footnote 2. 

13 See footnote 8. 

14 See footnote 2. 

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$38,842.00, representing the total of (i) $38,682.00, which is 

90% of the fees requested for services rendered (i.e., 

$42,980.00), plus (ii) $0.00,15 representing 100% of the 

expenses incurred during the period. 

FEES AND EXPENSES INCURRED DURING APPLICATION PERIOD 

17. Annexed hereto as Exhibit 1 is the Certification of Bettina M. Whyte 

pursuant to the Local Rules (the “Certification”). 

18. Annexed hereto as Exhibit 2 is a summary sheet listing professional who 

has worked on these cases during the Application Period, his or her hourly billing rate during the 

Application Period, and the amount of the COFINA Agent’s fees attributable to each individual. 

19. The COFINA Agent also maintains records of all actual and necessary 

out-of-pocket expenses incurred in connection with the rendition of professional services. A 

schedule setting forth the categories of expenses and amounts for which reimbursement is 

requested for the Application Period is annexed hereto as Exhibit 3. 

20. The COFINA Agent maintains written records of the time expended by 

the professionals carrying out professional services to COFINA. Such time records are made 

contemporaneously with the rendition of services by the person rendering such services. 

Annexed hereto as Exhibit 4 is a list of all of the matters for which services were rendered by the 

COFINA Agent during the Application Period and the aggregate amount of hours and fees 

expended for each of those matters. 

21. Except as set forth in the Certification, no agreement or understanding 

exists between the COFINA Agent and any other entity for the sharing of compensation to be 

received for services rendered in or in connection with these cases. 

 

15 See footnote 2. 

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22. The fees charged by the COFINA Agent in these title III cases are billed in 

accordance with its existing billing rates and procedures. 

23. The rates the COFINA Agent charged in these cases are consistent with 

the rates charged by the COFINA Agent to her non-bankruptcy clients. The COFINA Agent’s 

standard hourly rates are similar to the customary compensation charged by comparably-skilled 

practitioners in comparable non-bankruptcy and bankruptcy cases in a competitive national legal 

market. 

SUMMARY OF SERVICES RENDERED 

24. The following summary highlights the major areas to which the COFINA 

Agent devoted substantial time and attention during the Application Period. The full breadth of 

the COFINA Agent’s services are reflected in the time records, copies of which are annexed 

hereto as Exhibits 4(A)-(D). 

A. Mediation 

(Fees: $74,015.00/ Hours Billed: 69.85) 

25. On June 23, 2017, this Court entered the Order Appointing Mediation 

Team [Dkt. No. 430] (the “Mediation Order”) to establish a process to attempt to cooperatively 

resolve issues arising in the Title III Cases, including the Commonwealth-COFINA Dispute. 

26. The parties bound by the Mediation Order include the COFINA Agent, the 

Commonwealth Agent and certain of their respective constituents, among others. The Mediation 

Order requires principals with settlement authority and their respective advisors to personally 

attend the mediation sessions. 

27. The subject matter of the mediations is confidential but generally 

encompassed any and all issues arising in the Title III Cases, as determined by the appointed 

mediation team. 

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28. During the Application Period the COFINA Agent spent a significant 

amount of time reviewing and analyzing relevant issues to assist and comment regarding draft 

mediation statements setting forth the COFINA Agent’s position on these issues. The COFINA 

Agent also spent significant time communicating and consulting with Willkie Farr & Gallagher 

LLP (WF&G), as counsel to the COFINA Agent, and other professionals, including the COFINA 

constituents that are participating in the mediation, and the mediators. 

B. Litigation 

(Fees: $64,350.00 / Hours Billed: 60.3) 

29. Pursuant to the Commonwealth-COFINA Stipulation, the Oversight Board 

appointed the COFINA Agent for the express purpose of litigating and/or settling the 

Commonwealth-COFINA Dispute on behalf of COFINA. 

30. The Commonwealth Agent subsequently commenced an adversary 

proceeding against the COFINA Agent, attacking the ownership and constitutionality of 

COFINA’s sales and use tax revenue. 

31. During the Application Period, the COFINA Agent spent time on a range 

of issues arising in the COFINA Agent’s discharge of her duty to litigate and/or settle the 

Commonwealth-COFINA Dispute. The COFINA Agent met with and held telephonic 

discussions with a number of the stakeholders about the dispute, reviewed legal arguments 

relating to the dispute (relying on the legal review and analysis provided by WF&G), reviewed 

and provided comments on Court documents and other documents provided to her by various 

stakeholders. The COFINA Agent conferred regularly with WF&G and local Puerto Rico 

counsel to the COFINA Agent. 

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C. Fee Application/Agent 

(Fees: $7,430.00 / Hours Billed: 8.5) 

32. The COFINA Agent spent time preparing and reviewing her first interim 

fee application and monthly fee statements. 

D. Fee Application/ Counsel 

(Fees: $7,800.00 / Hours Billed: 8.7) 

33. During the Application Period the COFINA Agent spent time reviewing 

and analyzing monthly fee statements from counsel as required by the Interim Compensation 

Order. 

E. Non-Working Travel 

(Fees: $7,350.00 / Hours Billed: 7.5)

34. In accordance with the UST Guidelines, the COFINA Agent has billed all 

non-working travel time to this matter. All time in this matter was billed at fifty percent (50%) 

of the COFINA Agent’s standard hourly rates. 

EVALUATING THE COFINA AGENT’S SERVICES 

35. Section 317 of PROMESA authorizes interim compensation of 

professionals and incorporates the substantive standards of section 316 of PROMESA to govern 

the Court’s award of interim compensation. Section 316 of PROMESA provides that a court 

may award a professional employed by the debtor “reasonable compensation for actual, 

necessary services rendered,” and “reimbursement for actual, necessary expenses.” 48 U.S.C. § 

2176(a)(1) and (2). Section 316(c) sets forth the criteria for such an award: 

In determining the amount of reasonable compensation to be 

awarded to a professional person, the court shall consider the 

nature, the extent, and the value of such services, taking into 

account all relevant factors including— 

(1) the time spent on such services; 

(2) the rates charged for such services; 

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(3) whether the services were necessary to the administration of, 

or beneficial at the time at which the service was rendered to the 

completion of, a case under this chapter; 

(4) whether the services were performed within a reasonable 

amount of time commensurate with the complexity, importance, 

and nature of the problem, issue, or task addressed; 

(5) with respect to a professional person, whether the person is 

board certified or otherwise has demonstrated skill and experience 

in the restructuring field; and 

(6) whether the compensation is reasonable based on the 

customary compensation charged by comparably skilled 

practitioners in cases other than cases under this title or title 11 of 

the United States Code.48 U.S.C. § 2176(c). 

36. The COFINA Agent respectfully submits that the services for which she 

seeks compensation in this Application were necessary for and beneficial to the estate. The 

COFINA Agent further submits that the services rendered were performed efficiently and 

effectively. Finally, the COFINA Agent submits that the compensation requested herein is 

reasonable in light of the nature, extent and value of such services and those parties impacted by 

her actions and that the compensation requested is based on the customary compensation charged 

by comparably skilled practitioners in cases other than cases under title 11. 

THE COFINA AGENT’S REQUEST FOR INTERIM COMPENSATION 

37. The COFINA Agent submits that her request for interim allowance of 

compensation is reasonable. The services rendered by the COFINA Agent, as highlighted above, 

required substantial time and effort, resulting in substantial progress and success in these cases. 

The services rendered by the COFINA Agent during the Application Period were performed 

diligently and efficiently. 

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38. The professional services performed by the COFINA Agent during the 

Application Period required an aggregate expenditure of 154.85 hours by the COFINA Agent 

and her employee. 

39. The COFINA Agent’s hourly billing rates for professionals working on 

these cases ranged from $800.00 - $1,100.00. The COFINA Agent’s hourly rates and fees 

charged are consistent with the market rate for comparable services. As set forth in the 

Certification, the hourly rates and fees charged by the COFINA Agent are the same as those 

generally charged to, and paid by, the COFINA Agent’s other clients. Indeed, unlike fees paid 

by most of the COFINA Agent’s clients, due to the “holdback” of fees from prior Monthly Fee 

Statements and the delays inherent in the fee application process, the present value of the fees 

paid to the COFINA Agent by the Debtors generally is less than fees paid monthly by other 

clients. 

DISBURSEMENTS 

40. The COFINA Agent incurred actual and necessary out-of-pocket expenses 

during the Application Period, in the amounts set forth in Exhibit 3. By this Application, the 

COFINA Agent respectfully requests allowance of such reimbursement in full. 

41. The disbursements for which the COFINA Agent seeks reimbursement 

include the following: 

a. Administrative Expenses – Charged for duplicating and 

reproduction costs, cost of supplies, invoicing software user 

fees; 

b. Teleconferencing – the COFINA Agent does not charge for 

long distance telephone calls but does bill for the use of 

teleconferencing services; 

c. Postage/ Messenger/Delivery Services – the COFINA Agent’s 

practice is to charge postal, overnight delivery and courier 

services at actual cost; 

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d. Lodging/Travel Expenses/Airfare – The COFINA Agent’s 

practice is to charge lodging, airfare and travel services at 

actual cost to the client; 

e. Local Car Service – The COFINA Agent’s practice is to 

charge ground transportation services at actual cost to the 

client; and 

f. Local Meals – The COFINA Agent’s practice is to charge for 

local meals while traveling out of town to attending meetings, 

mediations and hearings at actual cost to the client. 

PROCEDURE 

42. In accordance with the Interim Compensation Order, the COFINA Agent 

has provided: (a) notice and copies of the Application to the Notice Parties and (b) notice of this 

Application to all parties that have requested notice pursuant to Bankruptcy Rule 2002.16 The 

COFINA Agent submits that no other or further notice is required. 

 

16 Copies of the Application, including exhibits, are available on the Debtors’ claims and noticing agents’ 

website: https://cases.primeclerk.com/puertorico. 

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CONCLUSION 

 WHEREFORE, the COFINA Agent respectfully requests that this Court enter an 

order: 

(a) allowing interim approval of compensation to the COFINA Agent 

for services rendered from October 1, 2017 through January 31, 

2018, inclusive, in the amount of $ 160,945.00; 

(b) allowing interim approval of reimbursement to the COFINA Agent 

of actual, necessary expenses incurred in connection with the 

rendition of such services from October 1, 2017 through January 

31, 2018, inclusive, in the amount of $ 3,779.56;

(c) approving and directing the payment of all fees and expenses 

incurred by the COFINA Agent that remain unpaid, including all 

Holdbacks; and 

(d) such other relief as may be just or proper. 

Dated: March 19, 2018 

Bettina M. Whyte, as COFINA Agent

By: /s/ Bettina M. Whyte 

Bettina M. Whyte 

545 West Sagebrush Drive 

Jackson, WY 83001 

Telephone: (917) 826-8781 

 /s/ Nilda M. Navarro-Cabrer 

Nilda M. Navarro-Cabrer 

NAVARRO-CABRER LAW OFFICES 

(USDC-PR 20212) 

El Centro I, Suite 206 

500 Muñoz Rivera Avenue 

San Juan, Puerto Rico 00918 

Telephone: (787) 764-9595 

Facsimile: (787) 765-7575 

Local Counsel to the COFINA Agent 

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EXHIBIT 1 

Certification of Bettina M. Whyte 

 

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

PROMESA 

Title III 

 

as representative of Case No. 17-BK-3283 (LTS) 

THE COMMONWEALTH OF PUERTO RICO, et al., (Jointly Administered) 

Debtors.1 

 

CERTIFICATION OF BETTINA M. WHYTE PURSUANT TO 

LOCAL BANKRUPTY RULE 2016-1(a)(4) REGARDING CERTIFICATION OF 

APPLICATIONS FOR COMPENSATION IN PUERTO RICO BANKRUPTCY CASES 

I, Bettina M. Whyte, certify as follows: 

1. I am the COFINA Agent in the above-captioned cases. 

2. I submit this certification in conjunction with the COFINA Agent’s 

Second interim application (the “Application”)2 for allowance of fees and reimbursement of 

expenses for the period October 1, 2017 through January 31, 2018 (the “Application Period”) in 

accordance with Rule 2016-1(a)(4) of the Local Bankruptcy Rules for the District of Puerto 

Rico, the Bankruptcy Rules, the Bankruptcy Code and the Interim Compensation Order 

(collectively, the “Guidelines”). 

 

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). 2

 Capitalized terms used but not otherwise defined herein have the meaning ascribed to them in the 

Application. 

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3. I am the professional designated by the COFINA Agent with the 

responsibility for COFINA Agent’s compliance in these cases with the Guidelines. This 

certification is made in connection with the Application for interim allowance of compensation 

for professional services and reimbursement of expenses for the Application Period in 

accordance with the Guidelines. 

4. Pursuant to Local Rule 2016-1(a)(4) of the Local Rules: (a) I have read 

the COFINA Agent’s Application; (b) to the best of my knowledge, information, and belief, 

formed after reasonable inquiry (except as stated herein or in the Application), the fees and 

disbursements sought in the Application fall within the Guidelines; (c) except to the extent the 

fees and disbursements are prohibited by the Guidelines, the fees and disbursements sought are 

billed at or below the rates and in accordance with practices customarily employed by the 

COFINA Agent and generally accepted by her clients; and (d) the compensation and 

reimbursement of expenses sought in this Application are billed at rates no less favorable to the 

COFINA Agent than those customarily employed by the COFINA Agent. 

5. The Monthly Fee Statements were provided to the Notice Parties as 

required by the Interim Compensation Order. 

6. A copy of the daily time records for each of the Monthly Fee Statements, 

broken down by matter and listing the name of the professional, the date on which the services 

were performed, and the amount of time spent in performing the services has previously been 

provided to the Notice Parties. The time records set forth in reasonable detail the services 

rendered by the COFINA Agent in these cases. 

7. Included in Exhibit 4 of the Application is a list of the different matter 

headings under which time was recorded during the Application Period. The list includes all 

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discrete matters within these cases during the Application Period that reasonably could have 

been expected to constitute a substantial portion of the fees sought during any given application 

period. 

8. Except as permitted pursuant to Bankruptcy Rule 2016, and as set forth 

above, no agreement or understanding exists between the COFINA Agent and any person for a 

division of compensation or reimbursement received or to be received herein or in connection 

with these cases. 

9. The COFINA Agent has sought to keep her fees and expenses at a 

reasonable level and to utilize professional services and incur expenses as necessary to 

competently represent COFINA. 

Dated: March 19, 2018 

 /s/ Bettina M. Whyte 

Bettina M. Whyte 

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EXHIBIT 2 

Summary of Professionals for the Application Period

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COMPENSATION BY INDIVIDUAL 

Name Position Hours Hourly 

Rate 

Fees Earned 

Bettina M. Whyte COFINA 

Agent 123.55 $1,100.00 $135,905.00 

Frederick G. Kraegel 

Senior 

Business 

Executive 

31.3 $800.00 $25,040.00 

TOTAL: 154.85 $1,039.36 $160,945.00 

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EXHIBIT 3 

Summary of Expenses for the Application Period

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Disbursements for Period October 1, 2017 through January 31, 2018 

Disbursement Amount 

Postage/ Messenger/ Overnight Delivery $103.80 

Local Transportation $653.36 

Overhead Expenses $600.00 

Local Meals $34.17 

Supplies and Invoicing Software Fee $40.00 

Meeting Space Rental Fee $0.00 

Lodging $1,786.64 

Airfare $2,213.59 

Less: Voluntary Reduction -$1,561.00 

Total: $3,779.56 

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EXHIBIT 4 

Summary of Time by Billing Category for the Application Period

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SERVICES RENDERED BY CATEGORY 

OCTOBER 1, 2017 THROUGH JANUARY 31, 2018 

Service Category Hours 

Billed 

Fees Billed 

COFINA Bond Litigation 60.3 $64,350.00 

Mediation 69.85 $74,015.00 

Fee Applications/Agent 8.5 $7,430.00 

Fee Applications/Counsel 8.7 $7,800.00 

Non-Working Travel (Billed at Half Time) 7.5 $7,350.00 

TOTAL 154.85 $160,945.00 

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EXHIBIT 4-A 

Time and Expense Detail for the October Fee Statement 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

CO FINA 

QTY DESCRIPTION 

28.8 Professional Services: Bettina Whyte 

12.2 Professional Services: Fred Kraegel 

!11voice 103·11 7 

Invoice 103117 

November 2, 2017 

RATE AMOUNT 

$1,100.00 $31,680.00 

$800.00 $9,760.00 

TOTAL DUE $41,440.00 

page 1 of6 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice 103117 

November 2, 2017 

Invoice submitted to: 

CO FINA 

Invoice Total 

$41,440.00 

Prof~§si2aal Servjces 

~ ~ 

10/3/2017 Bettina Whyte Mediation 0.2 $220.00 

Call with K. Klee 

Bettina Whyte Mediation 0.6 $660.00 

Review informational documents from K. Klee 

10/4/2017 Bettina Whyte Mediation 1.6 $1,760.00 

Call with KTBS re strategy 

Bettina Whyte Mediation 0.3 $330.00 

Call with Centerview re financial analysis 

Bettina Whyte Litigation 0.4 $440.00 

Call re D. Forman re 105 motion and other issues 

10/5/2017 Fred Kraegel Mediation 0.3 $240.00 

Weekly conference update call B. Whyte, WF&G, KTB&S 

Bettina Whyte Mediation 0.3 $330.00 

Attend weekly update call with F. Kraegel, WF&G, KTB&S 

10/10/2017 Fred Kraegel Fee Application 0.8 $640.00 

Draft and review September 2017 Fee Statement 

Fred Kraegel Mediation 0.3 $240.00 

Review September 2017 KTB&S invoice 

Fred Kraegel Mediation 0.4 $320.00 

Review documents 

Bettina Whyte Mediation 1.5 $1 ,650.00 

Call with Judge Houser and all parties in interest 

Bettina Whyte Mediation 0.4 $440.00 

Call with M. Feldman and K. Klee re next steps 

Bettina Whyte Mediation 0.4 $440.00 

Review documents 

Bettina Whyte Mediation 0.3 $330.00 

Review and respond to emails 

Bettina Whyte Mediation 0.1 $110.00 

Call with K. Klee re next steps 

10/11/2017 Fred Kraegel Mediation 0.8 $640.00 

Attend weekly update call with B. Whyte, WF&G, KTB&S and 

review additional information 

Fred Kraegel Mediation 0.6 $480.00 

Review and respond to emails 

invoice 103117 page 2 of 6 

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Hours Fees 

Bettina Whyte Mediation 0.4 $440.00 

Review informational emails 

Bettina Whyte Litigation 0.4 $440.00 

Read Senior Coalition Motion in Support 

Bettina Whyte Mediation 0.8 $880.00 

Attend weekly update call with F. Kraegel, WF&G, KTB&S and 

additional review of information 

Bettina Whyte Fee Application 0.4 $440.00 

Work on timesheets 

10/13/2017 Bettina Whyte Research 0.9 $990.00 

Attend Reorg Research Webinar 

Bettina Whyte Litigation 0.3 $330.00 

Review and discuss new schedule for motions with K. Klee 

Bettina Whyte Litigation 0.3 $330.00 

Review revised draft of Answer 

Bettina Whyte Litigation 0.5 $550.00 

Call with WFG & KTBS re various legal issues 

Bettina Whyte Mediation 0.2 $220.00 

Call with K. Klee re memo to Mediators on key issues 

10/15/2017 Bettina Whyte Litigation 1.1 $1,210.00 

Read two drafts of Stip & Order re 105 issue. Exchange emails re 

same with WF&G and K. Klee 

10/ 16/2017 Bettina Whyte Mediation 0.4 $440.00 

Call with M. Feldman re schedule for hearings, discuss 105 

motion, discuss matters related to Commonwealth settlement 

issues 

Bettina Whyte Mediation 0.3 $330.00 

Call with M. Feldman & Commonwealth Agent 

Bettina Whyte Litigation 0.3 $330.00 

Review Draft 3 of Motion and read and respond to emails re: 

same 

Bettina Whyte Litigation 0.8 $880.00 

Call with WF&G & KTB&S re Stip & Order 

10/18/2017 Fred Kraegel Mediation 0.4 $320.00 

Weekly update call B. Whyte, WF&G, KTB&S 

Bettina Whyte Mediation 0.4 $440.00 

Attend weekly update call with F. Kraegel, WF&G, KTB&S 

Bettina Whyte Mediation 0.2 $220.00 

Call with Centerview re retention matters 

10/19/2017 Bettina Whyte Mediation 0.3 $330.00 

Read and review documents 

Bettina Whyte Mediation 0.3 $330.00 

Send and review documents 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman 

10/20/2017 Bettina Whyte Litigation 0.5 $550.00 

Review and comment on pleadings re schedule 

Bettina Whyte Mediation 0.6 $660.00 

Read and review emails 

Invoice 103 ·11 7 page 3 of 6 

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Hours Fees 

Bettina Whyte Litigation 1.1 $1,210.00 

Review and respond to issues re Scheduling Order, discuss with 

attorneys 

10/21/2017 Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman re upcoming phone call with Judge Houser 

Bettina Whyte Mediation 0.8 $880.00 

Call with Judge Houser, M. Feldman & Commonwealth Agent re 

Mediations 

10/23/2017 Bettina Whyte Mediation 1.5 $1,650.00 

Call with WF&G & S. Kirpalani re COFINA Coalition's strategy 

Bettina Whyte Mediation 0.3 $330.00 

Call with M. Rodrigue re SUT collection analysis 

Bettina Whyte Litigation 0.3 $330.00 

Call with K. Klee re AFFAF Motion 

Bettina Whyte Mediation 0.6 $660.00 

Read & respond to emails 

Bettina Whyte Mediation 0.6 $660.00 

Review information provided by Miller Buckfire 

10/24/2017 Fred Kraegel Non-Working Travel 1.0 $800.00 

2 hours of non working travel, 1/2 time, to New York City to 

attend hearing 

Bettina Whyte Mediation 0.7 $770.00 

Discuss Miller Buckfire analysis with Centerview 

Bettina Whyte Mediation 0.6 $660.00 

Read & review emails and respond 

10/25/2017 Fred Kraegel Mediation 0.3 $240.00 

Weekly update call B. Whyte, WF&G, KTB&S 

Fred Kraegel Mediation 1.2 $960.00 

Discussion with C. Koenig re Case matters 

Fred Kraegel Litigation 3.6 $2,880.00 

Attend Hearing re Case matters 

Fred Kraegel Non-Working Travel 2.0 $1,600.00 

4 hours of non working travel, 1/2 time, from New York City after 

attending hearing 

Bettina Whyte Litigation 0.1 $110.00 

Call with K. Klee re Hearing 

Bettina Whyte Mediation 0.3 $330.00 

Attend weekly update call with F. Kraegel, WF&G, KTB&S 

Bettina Whyte Litigation 0.3 $330.00 

Review materials on 105 Hearing 

10/27/2017 Bettina Whyte Mediation 0.8 $880.00 

Read public information re all Hearings 

Bettina Whyte Litigation 0.4 $440.00 

Read draft Scheduling Motion and return comments 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman re Mediations, etc. 

10/29/2017 Bettina Whyte Mediation 0.5 $550.00 

Call with Centerview re Miller Buckfire analysis 

lrwoice 1031 17 p<.ige 4 of6 

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Hours Fees 

Bettina Whyte Litigation 1.2 $1 ,320.00 

Read & comment on several drafts of Amended Counterclaims & 

Answer 

10/30/201 7 Bettina Whyte Mediation 0.2 $220.00 

Call with J. Weiss & C. Koenig re response to new Fee 

Application Schedule 

Bettina Whyte Litigation 0.5 $550.00 

Review and provide comments to proposed 105 Motion and 

Motion on Revised Scheduling Order 

Bettina Whyte Fee Application 0.5 $550.00 

Work on timesheeets 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman re strategy 

10/31 /2017 Fred Kraegel Fee Application 0.5 $400.00 

Complete Time and Expense reporting for October 2017 

Bettina Whyte Mediation 0.3 $330.00 

Call with Miller Buckfire re analysis 

Bettina Whyte Mediation 0.6 $660.00 

Read and respond to emails 

Bettina Whyte Mediation 0.3 $330.00 

Call with Attorneys re Sr Cofina Bondholders' position 

41.0 $41,440.00 

Total amount of this invoice: $41,440.00 

Invoice 1031 17 

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Name 

Bettina Whyte 

Fred Kraegel 

Matter 

Mediation 

Mediation 

Litigation 

Litigation 

Fee Application 

Fee Application 

Research 

Non-Working Travel 

Invoice 103 i' "17 

Fee Summary by Professional 

Fee Summary by Matter 

Hours Rate 

28.8 $1,100.00 

12.2 $800.00 

Hours Rate 

18.5 $1,100.00 

4.3 $800.00 

8.5 $1,100.00 

3.6 $800.00 

1.3 $800.00 

0.9 $1,100.00 

0.9 $1 ,100.00 

3.0 $800.00 

Fees 

$31,680.00 

$9,760.00 

Fees 

$20,350.00 

$3,440.00 

$9,350.00 

$2,880.00 

$1,040.00 

$990.00 

$990.00 

$2,400.00 

page 6 of 6 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

CO FINA 

QTY 

Costs: 

Invoice 10311 72 

DESCRIPTION 

Invoice 1031172 

November 2, 2017 

RATE AMOUNT 

$1,647.30 

TOTAL DUE $1,647.30 

page 7 of3 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice submitted to: 

COFINA 

Costs 

10/9/2017 Bettina Whyte Administrative Expenses 

Invoice 1031172 

November 2, 2017 

Invoice Total 

$1,647.30 

Cost 

$10.00 

Monthly invoicing software fee for 1 additional user 

10/24/2017 Fred Kraegel Travel $803.19 

Flights to/from New York City attend Hearing. 

Fred Kraegel Lodging $576.11 

Attend October 25 Hearing 

Fred Kraegel Ground Transportation $53.00 

Taxi Airport to Hotel 

10/25/2017 Fred Kraegel Ground Transportation $55.00 

Taxi Courthouse to Airport 

10/31/2017 Bettina Whyte Misc. Supplies $150.00 

Monthly overhead expenses 

$1,647.30 

Total amount of this invoice: $1,647.30 

Invoice 1031172 page 2 of 3 

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Name 

Bettina Whyte 

Fred Kraegel 

Expense Type 

Administrative Expenses 

Travel 

Lodging 

Ground Transportation 

Misc. Supplies 

invoice 10311 72 

Cost Summary by Professional 

"f' e 

Administrative Expenses 

Misc. Supplies 

Total 

Travel 

Lodging 

Ground Transportation 

Total 

Cost Summary by Type 

Cost 

$10.00 

$150.00 

$160.00 

$803.19 

$576.11 

$108.00 

$1,487.30 

Costs 

$10.00 

$803.19 

$576.11 

$108.00 

$150.00 

page 3 of 3 

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EXHIBIT 4-B 

Time and Expense Detail for the November Fee Statement 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

CO FINA 

QTY DESCRIPTION 

39.95 Professional Services: Bettina Whyte 

9.6 Professional Services: Fred Kraegel 

Invoice 113017 

Invoice 113017 

December 6, 2017 

RATE AMOUNT 

$1,100.00 $43,945.00 

$800.00 $7,680.00 

TOTAL DUE $51,625.00 

page 1of6 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice 113017 

December 6, 2017 

Invoice submitted to: 

COFINA 

Invoice Total 

$51,625.00 

Professional Services 

Hours Fees 

11/1/2017 Bettina Whyte Mediation 0.5 $550.00 

Call with Miller Buckfire and Centerview re Senior Cofina 

Coalition position 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman re Senior COFINA Coalition's strategy 

Bettina Whyte Mediation 0.5 $550.00 

Call with M. Sonkin of National 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman re COFINA bondholders' positions 

Bettina Whyte Mediation 0.3 $330.00 

Call with K. Klee re COFINA bondholders' positions and next 

steps 

Bettina Whyte Mediation 0.2 $220.00 

Call with Miller Buckfire re position of Senior COFINA 

bondholders 

Bettina Whyte Mediation 0.5 $550.00 

Attend weekly attorney update call 

Fred Kraegel Mediation 0.5 $400.00 

Attend weekly attorney update call 

11/2/2017 Fred Kraegel Case Administration 0.6 $480.00 

Read articles and daily emails regarding matters related to case 

Bettina Whyte Mediation 0.7 $770.00 

Read articles and emails re same with attorneys 

11/3/2017 Bettina Whyte Mediation 1.0 $1,100.00 

Read and review informational article 

Bettina Whyte Mediation 0.3 $330.00 

Read and respond to emails 

11/4/2017 Bettina Whyte Litigation 0.6 $660.00 

Read Commonwealth's Answer to Catina's Counterclaims 

Bettina Whyte Litigation 0.8 $880.00 

Read Quinn Emanuel's Intervention, Counterclaims and Cross 

Claims 

Bettina Whyte Litigation 0.4 $440.00 

Read and respond to emails with attorneys re same 

11/6/2017 Fred Kraegel Fee Application 0.7 $560.00 

Review October 2017 Monthly Fees and Expense reporting 

invoice 113017 oage 2 ot6 

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Hours Fees 

Bettina Whyte Litigation 0.9 $990.00 

Review motions filed in COFINA and related matters 

Bettina Whyte Litigation 0.3 $330.00 

Read and responds to emails with attorneys re upcoming 

Informational Meetings 

11/7/2017 Bettina Whyte Litigation 0.8 $880.00 

Read public info re litigation matters and summaries 

Bettina Whyte Mediation 0.4 $440.00 

Emails with attorneys re next steps based on revised Mediation 

and Trial schedule 

11/8/2017 Fred Kraegel Mediation 0.8 $640.00 

Attend weekly attorney call 

Bettina Whyte Mediation 0.8 $880.00 

Call with Scoggins, Tilden Park and Golden Tree 

Bettina Whyte Mediation 1.2 $1,320.00 

Read Motions, Pleadings and Summaries of Hearings 

Bettina Whyte Mediation 0.8 $880.00 

Attend weekly attorney call 

11/9/2017 Fred Kraegel Mediation 0.8 $640.00 

Review articles and emails relevant to the case 

Bettina Whyte Mediation 0.6 $660.00 

Review information from attorneys 

11/10/2017 Fred Kraegel Fee Application 0.4 $320.00 

Finalize October 2017 Fee and Expenses information 

Bettina Whyte Mediation 0.6 $660.00 

Numerous emails with attorneys regarding a call with COFINA 

Senior Coalition Steering Committe 

Bettina Whyte Mediation 0.4 $440.00 

Read & respond to emails 

11/13/2017 Bettina Whyte Mediation 0.8 $880.00 

Call with WF&G, KTBS, Scoggins, Golden Tree Tilden Park S. 

Kirpalani 

Bettina Whyte Mediation 0.6 $660.00 

Review and respond to emails 

Bettina Whyte Mediation 0.2 $220.00 

Call with WF&G and KTBS 

11/14/2017 Bettina Whyte Litigation 1.5 $1,650.00 

Read Motions filed by numerous parties re Scope of Agents 

Bettina Whyte Mediation 0.5 $550.00 

Review Seniors Coalition group's proposal 

Bettina Whyte Mediation 0.2 $220.00 

Discuss Seniors Coalition group's proposal with Centerview 

Bettina Whyte Mediation 0.6 $660.00 

Call with Seniors Coalition Group Steering Committee and WF&G, 

KTSB and S. Kirpilani 

Bettina Whyte Mediation 0.2 $220.00 

Call with WF&G, KTBS and Centerview 

Bettina Whyte Litigation 0.4 $440.00 

Read and respond to emails 

Invoice 113017 page 3 of 6 

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Hours Fees 

11/16/2017 Fred Kraegel Mediation 1.2 $960.00 

Review articles and emails relevant to case matters 

Bettina Whyte Litigation 0.7 $770.00 

Read and respond to emails 

11/17/2017 Bettina Whyte Litigation 0.5 $550.00 

Attend weekly Attorney call 

Bettina Whyte Litigation 0.7 $770.00 

Review Draft COFINA Motions 

Bettina Whyte Litigation 0.5 $550.00 

Read and respond to emails 

11/20/2017 Bettina Whyte Litigation 0.5 $550.00 

Read and respond to emails 

Bettina Whyte Litigation 0.5 $550.00 

Call with WF&G, KTBS and N. Navarro 

11/21/2017 Bettina Whyte Litigation 0.6 $660.00 

Read and respond to emails 

11/25/2017 Bettina Whyte Fee Application 0.5 $550.00 

Timesheets 

11/26/2017 Bettina Whyte Case Administration 0.3 $330.00 

Read and respond to emails 

11/27/2017 Bettina Whyte Mediation 0.1 $110.00 

Call with K. Klee 

Fred Kraegel Case Administration 2.4 $1,920.00 

Draft November 2017 - June 2018 Fees and Expenses 

information 

Bettina Whyte Mediation 0.5 $550.00 

Read pertinent articles, read and respond to emails 

Bettina Whyte Mediation 1.3 $1,430.00 

Prepare for meeting with UCC Agent 

Bettina Whyte Mediation 0.6 $660.00 

Call with attorneys to discuss numerous issues 

1 i/28/2017 Bettina Whyte Mediation 0.7 $770.00 

Review info related to COFINA/Commonwealth dispute 

Bettina Whyte Mediation 1.2 $1 ,320.00 

Work on plane to prep for meeting with Commonwealth Agent 

Bettina Whyte Mediation 1.0 $1,100.00 

Read and respond to legal memos 

Bettina Whyte Non-Working Travel 2.0 $2.200.00 

Non working travel - 4.0 hours at 1/2 time 

11/29/2017 Bettina Whyte Mediation 1.0 $1,100.00 

Meeting with K. Klee re strategy 

Bettina Whyte Mediation 2.0 $2,200.00 

Meeting at WF&G with K. Klee to discuss several legal issues and 

strategies 

Bettina Whyte Mediation 0.8 $880.00 

Attend Creditor Working Group Call 

Bettina Whyte Mediation 1.25 $1,375.00 

Meeting with Commonwealth Agent and COFINA Agent attorneys 

Invoice 1130 17 page 4 of 6 

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 Document Page 42 of 67
Bettina Whyte Litigation 

Review and comment on Draft #1 of Omnibus Opposition Motion 

of COFINA Agent on Scope Motion 

Bettina Whyte Non-Working Travel 

Non working travel - 5 hours at 1/2 time 

Fred Kraegel Case Administration 

Finalize information re November 2017 - June 2018 fees and 

expenses 

11/30/2017 Bettina Whyte Litigation 

Review revised drafts of Omnibus Motion of COFINA Agent on 

Scope 

Bettina Whyte Mediation 

Calls with Attorneys re various issues 

Hours Fees 

1.0 $1 ,100.00 

2.5 $2,750.00 

2.2 $1 ,760.00 

0.7 $770.00 

0.5 $550.00 

49.55 $51,625.00 

Total amount of this invoice: $51,625.00 

Invoice 113017 pagf: 5 oi' 6 

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Name 

Bettina Whyte 

Fred Kraegel 

Matter 

Mediation 

Mediation 

Case Administration 

Case Administration 

Litigation 

Fee Appllcation 

Fee Application 

Non-Working Travel 

Invoice 11 301 7 

Fee Summary by Professional 

Fee Summary by Matter 

Hours Rate 

39.95 $1, 100.00 

9.6 $800.00 

Hours Rate 

23.25 $1,100.00 

3.3 $800.00 

5.2 $800.00 

0.3 $1,100.00 

11.4 $1 ,100.00 

1.1 $800.00 

0.5 $1 ,100.00 

4.5 $1,100.00 

Fees 

$43,945.00 

$7,680.00 

Fees 

$25,575.00 

$2,640.00 

$4,160.00 

$330.00 

$12,540.00 

$880.00 

$550.00 

$4,950.00 

page 6 of 6 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

CO FINA 

QTY 

Costs: 

Invoice 113017'2 

DESCRIPTION 

Invoice 1130172 

December 6, 2017 

RATE AMOUNT 

$2,976.15 

TOTAL DUE $2,976.15 

page 1 of S 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice 1130172 

December 6, 2017 

Invoice submitted to: 

COFINA 

Invoice Total 

$2,976.15 

Costs 

i i/1/2017 Bettina Whyte Postage and Shipping 

FedEx package with COFINA documents from JH to SC. (shipped 

10/23) 

i i/9/2017 Bettina Whyte Administrative Expenses 

Monthly invoicing software fee for i additional user 

i 1/28/2017 Bettina Whyte Ground Transportation 

Car to the Airport for flight to New York City to attend meetings at 

Willkie Farr & Gallagher office on 11/29 

Bettina Whyte Travel 

Flight to New York City to attend meeting at WF&G on 11/29 

Bettina Whyte Ground Transportation 

Car from Airport to hotel 

Bettina Whyte Meals and Entertainment 

Coffee and meal while waiting for flight to New York City 

11 /29/2017 Bettina Whyte Ground Transportation 

Car from the Airport after attending meeting at Willkie Far & 

Gallagher office in New York City 

Bettina Whyte Meals and Entertainment 

Breakfast with K. Klee to discuss case before meeting at WF&G 

Bettina Whyte Lodging 

Hotel Stay due to meeting at WF&G in New York City 

Bettina Whyte Ground Transportation 

Car from WF&G after meeting to the airport 

Bettina Whyte Travel 

Flight from New York City after attending meeting at WF&G 

11/30/2017 Bettina Whyte Miscellaneous Expense 

Monthly overhead expenses 

Invoice 1130 172 

Total amount of this invoice: 

Cost 

$56.69 

$10.00 

$60.00 

$485.20 

$178.49 

$4.72 

$60.00 

$29.45 

$1,210.53 

$155.87 

$575.20 

$150.00 

$2,976.15 

$2,976.15 

page 2 of.'3 

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Name 

Bettina Whyte 

Expense Type 

Postage and Shipping 

Administrative Expenses 

Ground Transportation 

Travel 

Meals and Entertainment 

Lodging 

Miscellaneous Expense 

Invoice 1130172 

Cost Summary by Professional 

T' e 

Postage and Shipping 

Administrative Expenses 

Ground Transportation 

Travel 

Meals and Entertainment 

Lodging 

Miscellaneous Expense 

Total 

Cost Summary by Type 

Cost 

$56.69 

$10.00 

$454.36 

$1,060.40 

$34.17 

$1 ,210.53 

$150.00 

$2,976.15 

Costs 

$56.69 

$10.00 

$454.36 

$1,060.40 

$34.17 

$1,210.53 

$150.00 

page 3 ol3 

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EXHIBIT 4-C 

Time and Expense Detail for the December Fee Statement 

Case:17-03283-LTS Doc#:2725 Filed:03/19/18 Entered:03/19/18 16:01:46 Desc: Main

 Document Page 48 of 67
Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

COFINA 

QTY DESCRIPTION 

18.2 Professional Services: Bettina Whyte 

6.1 Professional Services: Fred Kraegel 

Invoice 123 11 7 

Invoice 123117 

January 2, 2018 

RATE AMOUNT 

$1,100.00 $20,020.00 

$800.00 $4,880.00 

TOTAL DUE $24,900.00 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice 123117 

January 2, 2018 

Invoice submitted to: 

COFINA 

Invoice Total 

$24,900.00 PrQfes~ion51I S~CYic~~ 

Hours Em 

12/1/2017 Bettina Whyte Mediation 0.8 $880.00 

Review materials relating to Commonwealth-COFINA dispute. 

Review and respond to emails 

Bettina Whyte Mediation 0.6 $660.00 

Call with Seniors Coalition Steering Committee 

Bettina Whyte Mediation 0.6 $660.00 

Call with attorneys re call with COFINA Seniors Coalition and 

upcoming meeting with National 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Sonkin re potential meeting with National 

Bettina Whyte Case Administration 0.7 $770.00 

Prepare time sheets and work on travel plans and misc logistics 

12/6/2017 Fred Kraegel Fee Application 2.3 $1,840.00 

Draft and review First Interim Application 

Fred Kraegel Mediation 0.6 $480.00 

Review materials relating to Commonwealth-COFINA dispute 

Bettina Whyte Mediation 0.2 $220.00 

Call with WF&G , KTBS & Kramer Levin 

Bettina Whyte Mediation 0.2 $220.00 

Call with WF&G and KTBS re call with Kramer Levin 

Bettina Whyte Litigation 0.5 $550.00 

Read and respond to emails re strategy 

Bettina Whyte Mediation 0.5 $550.00 

Read COFINA related articles 

12/8/2017 Bettina Whyte Mediation 0.3 $330.00 

Review materials relating to Commonwealth-COFINA dispute 

Bettina Whyte Mediation 1.0 $1,100.00 

Call with WF&G, KTBS, Weil and principals from National to 

discuss strategies and scope issues 

Bettina Whyte Mediation 0.2 $220.00 

Follow up call with WF&G and KTBS re call with National 

12/11/2017 Fred Kraegel Case Administration 1.2 $960.00 

Further review First Interim Application 

Bettina Whyte Litigation 1.3 $1,430.00 

Read documents related to litigation. Read motions from various 

parties related to scope and other COFINA matters 

Invoice 123 117 page 2 uf 5 

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Hours ~ 

Bettina Whyte Litigation 0.2 $220.00 

Read and respond to emails re litigation matters 

Bettina Whyte Case Administration 0.2 $220.00 

Prepare and enter time entries 

12/12/2017 Bettina Whyte Mediation 0.4 $440.00 

Call with WF&G, KTBS, L. Despins, Z. Cooper re case status and 

next steps 

Bettina Whyte Mediation 0.3 $330.00 

Call with W&FG & KTBS re case status and next steps 

Bettina Whyte Mediation 1.0 $1,100.00 

Call with COFINA Juniors, WF&G, KTBS and Kramer Levin re 

Junior's opinions re case status and next steps, litigation, etc. 

Bettina Whyte Mediation 0.2 $220.00 

Debrief call with WF&G & KTBS following call with COFINA 

Juniors 

12/14/2017 Bettina Whyte Mediation 0.8 $880.00 

Read and respond to various emails 

Bettina Whyte Mediation 1.3 $1 ,430.00 

Read information related to COFINA 

12/ 19/2017 Bettina Whyte Mediation 0.5 $550.00 

Read & respond to emails 

Bettina Whyte Mediation 0.5 $550.00 

Read information related to COFINA 

Fred Kraegel Mediation 0.4 $320.00 

Read information related to COFINA 

12/20/2017 Bettina Whyte Mediation 0.4 $440.00 

Read information related to COFINA 

Bettina Whyte Mediation 0.4 $440.00 

Attend weekly update call with WF&G & KTBS 

Fred Kraegel Mediation 0.4 $320.00 

Attend weekly update call with WF&G & KTBS 

Fred Kraegel Mediation 0.4 $320.00 

Read information related to COFINA 

Fred Kraegel Fee Application 0.8 $640.00 

Draft and review November 2017 Monthly Fee Statement. 

12/21/ 2017 Bettina Whyte Mediation 0.6 $660.00 

Call with WF&G, KTBS, Quinn Emanuel and Miller Buckfire re 

next steps 

Bettina Whyte Mediation 1.2 $1,320.00 

Read & respond to emails review COFINA information 

Bettina Whyte Litigation 0.7 $770.00 

Call with WF&G & KTBS re litigation, experts and next steps 

Bettina Whyte Litigation 1.6 $1 ,760.00 

Review Judge Swain's order & WF&G's summaries re Scope 

Motion (ours and other parties) 

12/27 /2017 Bettina Whyte Litigation 0.6 $660.00 

Attend weekly update call w ith WF&G, KTBS to discuss options 

available in light of Scope Motion 

Invoice 1231 17 page 3 of 5 

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i 2/29/2017 Bettina Whyte 

Invoice 1231 17 

Litigation 

Call with M. Feldman re Commonwealth Agent's related to Scope 

Motion 

Total amount of this invoice: 

!::i2.lli§ 

0.2 

24.3 

Fees 

$220.00 

$24,900.00 

$24,900.00 

page 4 of 5 

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Name 

Bettina Whyte 

Fred Kraegel 

Matter 

Mediation 

Mediation 

Case Administration 

Case Administration 

Fee Application 

Litigation 

Invoice 123117 

Fee Summary by Professional 

Fee Summary by Matter 

Hours Rate 

18.2 $1 , 100.00 

6.1 $800.00 

Hours Rate 

12.2 $1,100.00 

1.8 $800.00 

0.9 $1 ,100.00 

1.2 $800.00 

3.1 $800.00 

5.1 $1,100.00 

Fees 

$20,020.00 

$4,880.00 

Fees 

$13,420.00 

$1,440.00 

$990.00 

$960.00 

$2,480.00 

$5,610.00 

ps.g& .5 of 5 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

COFINA 

QTY 

Costs: 

Jmroice 1231172 

DESCRIPTION 

Invoice 1231172 

January 4, 2018 

RATE AMOUNT 

$557.11 

TOTAL DUE $557.11 

page "/ or 3 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice 1231172 

Invoice submitted to: 

CO FINA 

Costs 

12/ 1/2017 Bettina Whyte Postage and Shipping 

Fedex package with Reorg Research documents from NY to SC 

(shipped on 11/20) 

12/9/2017 Bettina Whyte Administrative Expenses 

Monthly invoicing software fee for 1 additional user 

12/19/2017 Bettina Whyte Travel 

Flight Cancellation Fee - to New York to attend Omnibus Hearing 

(Hearing Cancelled) 

12/20/2017 Bettina Whyte Travel 

Flight cancellation fee from New York - Omnibus Hearing 

canceled 

12/31 /2017 Bettina Whyte Miscellaneous Expense 

Monthly overhead expenses 

Invoice -123 1172 

Total amount of this invoice: 

January 4, 2018 

Invoice Total 

$557.11 

QQfil 

$47.11 

$10.00 

$200.00 

$150.00 

$150.00 

$557.11 

$557.11 

pa.g<: 2 of 3 

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Name 

Bettina Whyte 

Expense Type 

Postage and Shipping 

Administrative Expenses 

Travel 

Miscellaneous Expense 

Invoice 1231172 

Cost Summary by Professional 

T' e 

Postage and Shipping 

Administrative Expenses 

Travel 

Miscellaneous Expense 

Total 

Cost Summary by Type 

Cost 

$47.11 

$10.00 

$350.00 

$150.00 

$557.11 

Costs 

$47.11 

$10.00 

$350.00 

$150.00 

page 3 of3 

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EXHIBIT 4-D 

Time and Expense Detail for the January Fee Statement 

Case:17-03283-LTS Doc#:2725 Filed:03/19/18 Entered:03/19/18 16:01:46 Desc: Main

 Document Page 57 of 67
Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

CO FINA 

QTY DESCRIPTION 

36.6 Professional Services: Bettina Whyte 

3.4 Professional Services: Fred Kraegel 

Invoice 13 118 

Invoice 13118 

February 12, 2018 

RATE AMOUNT 

$1,100.00 $40,260.00 

$800.00 $2,720.00 

TOTAL DUE $42,980.00 

page 1 c.f 7 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice 13118 

February 12, 2018 

Invoice submitted to: 

CO FINA 

Invoice Total 

$42,980.00 

Professional Services 

1/3/2018 Bettina Whyte Fee Application 

Prepare and enter time entries 

Fred Kraegel Litigation 

Attend weekly attorney call to discuss litigation strategy re scope 

and next steps 

Bettina Whyte Litigation 

Attend weekly attorney call to discuss litigation strategy re scope 

and next steps 

Bettina Whyte Fee Application 

Review Fee Examiner's Letter and correspond with attorneys re 

same 

1/4/2018 Bettina Whyte Litigation 

Review Commonwealth's Agent's Motion re Clarification of 

Scope 

Bettina Whyte Litigation 

Call with M. Feldman to discuss Commonwealth's Agent's 

Motion and next steps 

Bettina Whyte Litigation 

Call with K. Klee re Commonwealth Agent's Motion and next 

steps 

Bettina Whyte Litigation 

1/5/2018 Fred Kraegel 

Read and respond to emails 

Litigation 

Call with WF&G, KTBS, N. Navarro and B. Whyte re litigation 

strategy related to scope 

Fred Kraegel Fee Application 

Call with B. Whyte re Fee Statement 

Bettina Whyte Litigation 

Call with WF&G, KTBS, N. Navarro and F. Kraegel re litigation 

strategy related to Scope 

Bettina Whyte Litigation 

Call with K. Klee re constitutionality issues related to Scope 

Bettina Whyte Fee Application 

Call with F. Kraegel re fee Statement 

Bettina Whyte Litigation 

Call with K. Klee re litigation issues 

~ 

0.5 

0.4 

0.4 

0.3 

0.8 

0.2 

0.1 

0.2 

0.5 

0.1 

0.5 

0.2 

0.1 

0.2 

~ 

$550.00 

$320.00 

$440.00 

$330.00 

$880.00 

$220.00 

$110.00 

$220.00 

$400.00 

$80.00 

$550.00 

$220.00 

$110.00 

$220.00 

Invoice 131 18 page 2 oi 7 

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Hours Fees 

Bettina Whyte Litigation 0.4 $440.00 

Call with M. Sonkin of National re National's position re Scope 

Order and next steps 

Bettina Whyte Litigation 0.1 $110.00 

Call with M. Feldman re conversations with various COFINA 

stakeholders 

Bettina Whyte Litigation 0.5 $550.00 

Emails with A. Yanez re expert witnesses and emails to potential 

witness 

1/6/2018 Bettina Whyte Mediation 0.3 $330.00 

Call with Judge Houser and M. Feldman re mediations 

Bettina Whyte Mediation 0.3 $330.00 

Follow-up calls and emails with M. Feldman re mediation 

Bettina Whyte Litigation 0.2 $220.00 

Call with K. Klee re litigation issues 

1/7/2018 Bettina Whyte Litigation 0.3 $330.00 

Call with WF&G & KTBS re litigation and mediation process going 

forward 

Bettina Whyte Litigation 0.6 $660.00 

Review draft Objection to Commonwealth Agent's Motion for 

Clarification 

Bettina Whyte Litigation 0.4 $440.00 

Emails and calls with WF&G re COFlNA Objection 

Bettina Whyte Litigation 0.4 $440.00 

Review revised draft COFlNA Objection 

i /8/2018 Bettina Whyte Litigation 0.3 $330.00 

Review and approve COFINA response to Commonwalth Agent's 

Motion for Clarification 

Bettina Whyte Litigation 1.0 $1 ,100.00 

Review all responses filed by various parties to Commonwealth 

Agent's Motion for Clarification 

Bettina Whyte Litigation 0.4 $440.00 

Emails and calls to potential expert witnesses 

1/9/2018 Bettina Whyte Litigation 0.2 $220.00 

Emails with various parties re potential experts 

1/12/2018 Bettina Whyte Litigation 0.3 $330.00 

Review Motions in Support of Commonwealth Agent's Motion 

Bettina Whyte Litigation 0.7 $770.00 

Review Commonwealth Agent's Motion Seeking to File Leave to 

File Revised 2nd Amended Complaint 

Bettina Whyte Litigation 1.1 $i ,210.00 

Read & respond to several emails with WF&G & KTBS re 

Commonwealth Agent's Motion for Leave and next steps 

Bettina Whyte Litigation 0.2 $220.00 

Reach out to potential expert 

Bettina Whyte Litigation 1.4 $1,540.00 

Review various Drafts of COFlNA's Objection to Commonwealth 

Motion for Leave and approve Final 

1/13/2018 Bettina Whyte Mediation 0.3 $330.00 

Review Judge Hauser's Mediation Memo 

Invoice 13118 page 3 o i' 7 

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Hours Fees 

Bettina Whyte Mediation 0.5 $550.00 

Numerous emails with WF&G & KTBS re Mediation Memo 

1/14/2018 Bettina Whyte Litigation 0.3 $330.00 

Review Judge Swain's Order approving Commonwealth Agents 

Motion for Leave 

Bettina Whyte Litigation 0.3 $330.00 

Numerous emails with WF&G & KTBS re Judge Swain's Order 

and next steps 

Bettina Whyte Litigation 1.4 $1,540.00 

Re-Review all court documents related to Scope (motions, 

answers, orders, etc) 

Bettina Whyte Litigation 0.4 $440.00 

Call with WF&G, KTBS, N. Navarro and F. Kraegel re litigations 

next steps and Mediation process 

Fred Kraegel Litigation 0.4 $320.00 

Call with WF&G, KTBS, N. Navarro and B.Whyte re litigation next 

steps and Mediation process 

1/16/2018 Bettina Whyte Litigation 0.5 $550.00 

Call with K. Klee and J. Weiss re litigation arguments 

Bettina Whyte Litigation 0.5 $550.00 

Review M. Feldman's emails to COFINIA constituents and make 

changes 

Bettina Whyte Litigation 0.1 $110.00 

Call with J. Weiss re accounting expert 

Bettina Whyte Litigation 0.2 $220.00 

Call with attorneys re expert witness 

1/17/2018 Bettina Whyte Litigation 0.4 $440.00 

Work on expert witness designations and contracts and discuss 

revisions with S. Hussein 

Bettina Whyte Litigation 1.0 $1,100.00 

Call with WF&G, KTBS and attorneys for COFINA stakeholders 

re litigation positions and future mediation 

Bettina Whyte Litigation 0.7 $770.00 

Attend weekly attorney call with WF&G, KTBS, N. Navarro and F. 

Kraegel re litigation next steps and procedural issues, document 

production, depositions, expert witnesses 

Fred Kraegel Litigation 0.7 $560.00 

Attend weekly attorney call with WF&G, KTBS, N. Navarro and B. 

Whte re litigation next steps and procedural issues, document 

production, depositions, expert witnesses 

1/21/2018 Bettina Whyte Litigation 0.6 $660.00 

Review issues related to extensions of summary judgement and 

discovery; respond to WF&G 

1/22/2018 Bettina Whyte Litigation 0.3 $330.00 

Call with J . Dugan re issues related to extension of summary 

judgement deadlines and discovery 

1/23/2018 Bettina Whyte Litigation 0.2 $220.00 

Call with M. Feldman re status of court filings and discovery 

1/24/2018 Bettina Whyte Litigation 0.8 $880.00 

Review all Motions filed & Replies to Commonwealth Agents 

Motion for Extension 

Invoice 13118 page 4 of I 

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Hours Fees 

Bettina Whyte Litigation 0.2 $220.00 

Review and approve AlixPartners revised engagement letter 

Bettina Whyte Litigation 0.2 $220.00 

Call with A. Yanez re Support for Sr COFINA bondholders' Urgent 

Motion for Hearing 

Bettina Whyte Litigation 0.4 $440.00 

Read and respond to emails 

Bettina Whyte Litigation 0.5 $550.00 

Attend weekly Attorney Call to discuss next steps related to 

litigation and Mediation 

Fred Kraegel Litigation 0.5 $400.00 

Attend weekly Attorney Call to discuss next steps related to 

litigation and Mediation 

1/26/2018 Bettina Whyte Litigation 0.6 $660.00 

Review various legal documents from attorneys 

1/28/2018 Bettina Whyte Mediation 1.2 $1,320.00 

Call and emails with attorneys related to discussion with Judge 

Houser and other parties related to scope within mediation 

Bettina Whyte Mediation 0.7 $770.00 

Review drafts of motion related to scope and mediation 

Bettina Whyte Mediation 0.6 $660.00 

Read and review info related to COFINA issues 

1/29/2018 Bettina Whyte Litigation 0.6 $660.00 

Review Urgent Motion by COFINA Agent and Oversight Board re 

Expanded Authority and approve 

Bettina Whyte Litigation 0.5 $550.00 

Read and respond to emails related to Expanded Authority 

Bettina Whyte Litigation 0.3 $330.00 

Call with K. Klee and M. Feldman re next steps 

Bettina Whyte Litigation 0.3 $330.00 

Read info related to COFINA issues 

Bettina Whyte Mediation 0.3 $330.00 

Review Miller Buckfire analysis re SUT 

1/30/2018 Bettina Whyte Mediation 0.9 $990.00 

Review emails re Urgent Motions related to scope and mediation 

and discussion of various constituents' positions 

Bettina Whyte Mediation 0.3 $330.00 

Review drafts related to Urgent Motion related to scope and 

mediation 

Bettina Whyte Mediation 0.5 $550.00 

Review info related to COFINA matters 

Bettina Whyte Litigation 1.5 $1,650.00 

Review and approve COFINA 2nd Amended Answer 

Bettina Whyte Mediation 0.2 $220.00 

Call with J. Minias re status of COFINA constituents related to 

mediation 

Fred Kraegel Fee Application 0.3 $240.00 

Work related to time entries 

Invoice 13118 page 5 c;' 7 

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 Document Page 62 of 67
Hours Fees 

1/31/2018 Bettina Whyte Fee Application 0.5 $550.00 

Work related to time entries 

Bettina Whyte Mediation 0.1 $110.00 

Call with J. Minias re scope issues 

Bettina Whyte Mediation 0.2 $220.00 

Call with M. Feldman re Ambac's latest Scope Proposal 

Bettina Whyte Litigation 0.4 $440.00 

Read analysis of Judge Swain's dismissal of GO Bondholders' 

claim against Commonwealth 

Bettina Whyte Litigation 1.1 $1,210.00 

Review COFINA draft Summary Judgement brief 

Bettina Whyte Litigation 2.5 $2,750.00 

Review filings of COFINA Parties re Amended Answers and 

Counterclaims to Commonwealth Agent's Complaint 

Bettina Whyte Mediation 0.1 $110.00 

Review revised proposed Order re Immunity Expansion 

Fred Kraegel Litigation 0.5 $400.00 

Attend weekly Attorney update call 

Bettina Whyte Litigation 0.3 $330.00 

Call with KTBS re litigation issues 

Bettina Whyte litigation 0.5 $550.00 

Attend weekly Attorney update call 

40.0 $42,980.00 

Total amount of this invoice: $42,980.00 

fm1oice 13118 page 6 of! 

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Name 

Bettina Whyte 

Fred Kraegel 

Matter 

Fee Application 

Fee Application 

Litigation 

Litigation 

Mediation 

lrwoice 13118 

--- -------

Fee Summary by Professional 

Fee Summary by Matter 

Hours Rate 

36.6 $1 '100.00 

3.4 $800.00 

Hours Rate 

1.4 $1,100.00 

0.4 $800.00 

3.0 $800.00 

28.7 $1 ,100.00 

6.5 $1,100.00 

Fees 

$40,260.00 

$2,720.00 

Fees 

$1,540.00 

$320.00 

$2,400.00 

$31,570.00 

$7,150.00 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

BILL TO: 

CO FINA 

QTY 

Costs: 

Ini-oice 12 1182 

DESCRIPTION 

Invoice 131182 

February 12, 2018 

RATE AMOUNT 

$160.00 

TOTAL DUE $160.00 

pa.ge 1of3 

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Bettina Whyte Consultants LLC 

545 West Sagebrush Drive 

Jackson, Wy 83001 

Invoice submitted to: 

CO FINA 

Costs 

1/9/2018 Bettina Whyte Administrative Expenses 

Monthly invoicing software fee for 1 additional user 

1/31/2018 Bettina Whyte Miscellaneous Expense 

Monthly overhead expenses 

Invoice 131182 

February 12, 2018 

Invoice Total 

$160.00 

.Q.Qfil 

$10.00 

$150.00 

$160.00 

Total amount of this invoice: $160.00 

invoice 131 182 page 2 ot3 

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Name 

Bettina Whyte 

Expense Type 

Administrative Expenses 

Miscellaneous Expense 

Invoice 131182 

Cost Summary by Professional 

-r e 

Administrative Expenses 

Miscellaneous Expense 

Total 

Cost Summary by Type 

Cost 

$10.00 

$150.00 

$160.00 

Costs 

$10.00 

$150.00 

page3 ol,"1 

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