UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

 

 ) PROMESA

In re ) 

) 

Title III 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO

et al.,

1

) 

) 

) 

) 

) 

) 

) 

No. 17-BK-3283 (LTS) 

Re: 20458, 20467, 20827 

Debtors. ) (Jointly Administered) 

 ) 

 

SUPPLEMENTAL DECLARATION OF KATHERINE STADLER PURSUANT 

TO THE PUERTO RICO RECOVERY ACCURACY IN DISCLOSURES ACT 

I, Katherine Stadler, hereby declare under penalty of perjury: 

1. I am a shareholder with Godfrey & Kahn, S.C. (“Godfrey & Kahn”), a 

law firm with its principal offices at 833 East Michigan Street in Milwaukee, Wisconsin, 

and One East Main Street in Madison, Wisconsin, and other offices in Wisconsin and in 

Washington, D.C. I am authorized to make this Declaration on behalf of myself, the Fee 

Examiner Brady C. Williamson, and Godfrey & Kahn in compliance with the Order 

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 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 (the “Commonwealth”) (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); (v) 

Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780-LTS) (Last Four 

Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy 

Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed 

as Bankruptcy Case numbers due to software limitations). 

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Approving List of Material Interested Parties Pursuant to the Puerto Rico Recovery 

Accuracy in Disclosures Act [Dkt. No. 20467] (the “PRRADA Compliance Order”), 

entered on March 30, 2022. This Supplemental Declaration is based on my personal 

knowledge and if called to testify, I could and would testify competently to the written 

statements made in this Declaration. 

2. The Court appointed another firm shareholder, Brady C. Williamson (the 

“Fee Examiner”), in the October 6, 2017, Order Pursuant to PROMESA Sections 316 and 

317 and Bankruptcy Code Section 105(A) Appointing a Fee Examiner and Related Relief

[Dkt. No. 1416] (the “Fee Examiner Order”). 

3. On October 26, 2017, I submitted the Affidavit of Katherine Stadler in 

Conjunction with Godfrey & Kahn, S.C.’s Application for Appointment as Counsel to the 

Fee Examiner [Dkt. No. 1548, Ex. A] (the “Godfrey & Kahn Disclosure Affidavit”). 

4. On May 16, 2022, I submitted the Declaration of Katherine Stadler 

Pursuant to the Puerto Rico Recovery Accuracy in Disclosures Act [Dkt. No. 20827] (the 

“Initial Godfrey & Kahn PRRADA Declaration”). 

5. On June 2, 2022, I received communication from the Office of the United 

States Trustee requesting clarification of certain of the disclosure items listed in the 

Initial Godfrey & Kahn PRRADA Declaration (the “U.S. Trustee Inquiries”). After 

discussions with the Office of the United States Trustee and further inquiries within my 

firm, I hereby supplement the Initial Godfrey & Kahn PRRADA Declaration with the 

attached Appendix B: Responses to Inquiries from the Office of the United States 

Trustee. 

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6. Other than as supplemented herein, all representations and disclosures in 

the Initial Godfrey & Kahn PRRADA Declaration remain true and correct. 

Dated this 8th day of August, 2022. 

GODFREY & KAHN, S.C. 

 s/ Katherine Stadler 

Katherine Stadler 

One East Main Street, Suite 500 

Madison, Wisconsin 53703 

Telephone: (608) 257-3911 

Facsimile: (608) 257-0609 

E-mail: kstadler@gklaw.com 

Counsel to the Fee Examiner

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APPENDIX B 

RESPONSES TO INQUIRIES FROM THE OFFICE OF THE 

UNITED STATES TRUSTEE 

Initial Godfrey & 

Kahn PRRADA 

Declaration 

Paragraph 

Statement Inquiry from the Office of the 

United States Trustee 

Response 

¶2 The Fee Examiner 

is a shareholder of 

G&K. 

Please more specifically identify 

Mr. Williamson’s position, title, 

and financial interest in G&K. 

Is the compensation Mr. 

Williamson will receive as the 

Fee Examiner in these cases a 

source of revenue for G&K? 

Please identify what, if any, 

additional protections, or 

processes are in place (or that 

G&K would recommend be put 

in place) concerning the Fee 

Examiners review and 

examination of G&K’s fee 

applications given that G&K is 

providing counsel to the Fee 

Examiner in these cases, and 

given that the Fee Examiner 

appears to have a direct 

economic interest in the approval 

of G&K’s fees? 

Godfrey & Kahn, S.C. is a 

Wisconsin Service Corporation 

established pursuant to section 

180.1903 of the Wisconsin 

Statutes. Each Godfrey & Kahn 

shareholder has a financial 

interest in the overall financial 

performance of the firm and 

shares in the firm’s profits based 

on a subjective year-end 

assessment of the firm’s 

compensation committee 

(approved by the firm’s board of 

directors) as to each shareholder’s 

overall contributions. 

As disclosed in the initial 

retention papers [Dkt. No. 1548], 

the fee examiner charges a flat fee 

of $17,500 per month for his 

work on these cases. The 

attorneys and paraprofessionals 

working on these cases charge 

their standard hourly billing rates 

for 2018. Neither the fee 

examiner nor his counsel has 

raised hourly rates (except in 

connection with attorney 

promotions) throughout the 

course of these proceedings. 

Both the Fee Examiner’s fees and 

those of his counsel constitute 

revenue for Godfrey & Kahn, 

S.C., not individual revenue. 

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Initial Godfrey & 

Kahn PRRADA 

Declaration 

Paragraph 

Statement Inquiry from the Office of the 

United States Trustee 

Response 

Although the Fee Examiner is a 

member of Godfrey & Kahn, both 

Godfrey & Kahn and the Fee 

Examiner will exercise billing 

judgment to ensure that only 

those fees that are reasonable and 

necessary to the estate are 

included in Godfrey & Kahn’s fee 

applications. Further, Godfrey & 

Kahn acknowledges (consistent 

with 28 U.S.C. 2176) that the 

United States Trustee has the 

statutory authority to review the 

fee applications and file any 

motion it deems appropriate 

regarding that compensation with 

the Court. 

¶ 9 Appendix A 

includes a list of 

MIP with which 

G&K has a current 

or “recent” 

relationship. 

What is “recent”? Please more 

specifically identify the 

lookback period that G&K used, 

including whether that lookback 

period was from the date of 

filing, date of employment, or 

the date of the PRRADA 

declaration. 

Godfrey & Kahn disclosed 

relationships that existed as of 

October 2015—two years prior to 

the Fee Examiner’s appointment 

and the commencement of work 

on these cases. 

¶11 A shareholder of 

G&K, Paul 

Griepentrog, as 

trustee for a family 

trust, invested in a 

mutual fund that 

“previously held 

Puerto Rican 

government 

bonds.” The 

disclosures 

indicate that G&K 

previously 

implemented an 

“ethical wall” for 

this representation. 

Please further identify when the 

family trust stopped investing in 

the mutual funds that held Puerto 

Rican government bonds, and/or 

when the mutual fund excluded 

the Puerto Rican government 

bonds from the fund? 

Please also identify when the 

ethical wall established? 

The family trust divested mutual 

funds that, in turn, held Puerto 

Rican Government bonds in late 

2019. The ethical wall was 

established as of the date of 

Godfrey & Kahn’s initial 

disclosures—October 26, 2017. 

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Initial Godfrey & 

Kahn PRRADA 

Declaration 

Paragraph 

Statement Inquiry from the Office of the 

United States Trustee 

Response 

Appendix A (p.16 

of 17) 

US Bank, NA – 

G&K states that its 

billings in the last 

2 years to G&K 

were less than .5% 

of its revenues in 

2015 and 2016. 

Please provide the percentage of 

billings in comparison to more 

recent revenues than 2015 and 

2016, preferably for 2020 and 

2021. Alternatively, please 

explain why G&K believes the 

2015 and 2016 revenues are the 

most appropriate period. 

Data for 2015 and 2016 were 

disclosed because they were the 

two most recent calendar years 

relevant to the disclosure at the 

time of Godfrey & Kahn’s 

retention. For the years 2020 and 

2021, billings to U.S. Bank, N.A. 

constituted less than one percent 

of annual firm revenues. 

Appendix A (p.11 

of 17) 

Ernst & Young, 

LLP – G&K 

presently serves as 

co-counsel on 

unrelated 

transactional 

matters. 

Please provide more detail 

concerning the co-counsel 

relationship with Ernst & 

Young, LLP, and describe in 

more detail the representation 

provided through that co-counsel 

relationship. Please also confirm 

whether any of the parties 

represented in those matters are 

involved in the PROMESA 

matters. 

Ernst and Young serves as a 

financial advisor to a Wisconsin 

manufacturing client in a pending 

transaction on which Godfrey & 

Kahn serves as lead transaction 

counsel. Because Godfrey & 

Kahn’s conflicts database does 

not have a separate financial 

advisor party designation, the 

professional’s name appeared in 

the “Other/Co-counsel” field in 

the conflicts report. The 

manufacturing client is not 

involved in PROMESA matters. 

Appendix A Please identify any of the 

“interest parties” on Exhibit A to 

the declaration, or the matters on 

which G&K is employed in 

relation to those interested 

parties, that have or will 

constitute more than 1% of 

G&K’s annual revenues at any 

point since the filing of these 

cases. 

None 

27537086.4 

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