Exhibit D

Budget Plan

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 1 of 17
Exhibit D-1

Budget Plan for the Period of February 1, 2018 through February 28, 2018

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 2 of 17
2

PROJECT 

CATEGORY

TASK 

CODE FEBRUARY FEBRUARY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

ERS (33260/007)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 - 5 $0 - $3,735 0.00 $0.00

Legal Research 202 5 - 10 $3,735 -

$7,470 3.00 $1,877.80

Hearings and other nonfiled communications 

with the Court

203 0 - 5 $0 - $4,450 0.80 $607.20

Communications with 

Claimholders 204 130 - 145 $94,800 -$108,200 135.10 $102,191.60

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 - 10 $0 - $7,470 0.80 $607.20

Documents Filed on 

Behalf of the Board 206 0 - 5 $0 - $3,400 0.00 $0.00

Non-Board Court Filings 207 0 - 5 $0 - $3,735 2.50 $1,897.50

Stay Matters 208 0 - 10 $0 - $7,470 0.00 $0.00

Adversary Proceeding 209 0 - 5 $0.00 -

$3,735 0.00 $0.00

Analysis and Strategy 210 0 - 5 $0 - $3,735 0.00 $0.00

Non-Working Travel 

Time 211 0 - 5 $0 - $3,735 2.20 $1,669.80

General Administration 212 0 - 5 $0 - $3,735 1.80 $468.00

Labor, Pension Matters 213 0 - 10 $0 - $7,470 2.40 $1,821.60

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,470 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 - 10 $0 - $7,470 4.80 $3,643.20

Confirmation 216 0 - 0 $0 - $0 0.00 $0.00

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 3 of 17
3

PROJECT 

CATEGORY

TASK 

CODE FEBRUARY FEBRUARY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

ERS (33260/007)

Tax 217 0 - 5 $0 - $3,735 0.00 $0.00

Employment and Fee 

Applications 218 0 - 10 $0 - $7,470 3.50 $2,107.60

Appeal 219 0 - 10 $0 - $7,470 0.00 $0.00

TOTALS 135 -270 $98,535 –

201,955 156.90 $116,891.50

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 4 of 17
4

Exhibit D-2

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

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 5 of 17
5

PROJECT 

CATEGORY

TASK 

CODE MARCH MARCH

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

ERS (33260/007 and 025)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 - 10 $0 - $7,470 0.20 $151.80

Legal Research 202 25 - 35 $18,675 -

$26,145 26.90 $17,922.10

Hearings and other nonfiled communications 

with the Court

203 0 - 5 $0 - $3,735 0.00 $0.00

Communications with 

Claimholders 204 25 - 40 $18,675 -$29,880 27.00 $20,493.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 5 - 10 $3,735 -

$7,470 2.70 $2,049.30

Documents Filed on 

Behalf of the Board 206 200 - 260 $152,600 -$194,200 209.70 $159,162.30

Non-Board Court Filings

207 40 - 55 $31,830 -

$43,640 38.90 $29,525.10

Stay Matters 208 0 - 5 $0 - $3,735 0.00 $0.00

Adversary Proceeding 209 0 - 10 $0 - $7,470 1.10 $834.90

Analysis and Strategy 210 0 - 10 $0 - $7,470 4.70 $3,567.30

Non-Working Travel 

Time 211 0 - 5 $0 - $3,735 0.00 $0.00

General Administration 212 5 - 10 $1,352 -

$2,600 6.20 $1,612.00

Labor, Pension Matters 213 0 - 5 $0 - $3,735 1.20 $910.80

Legal/ Regulatory 

Matters 214 0 - 5 $0 - $3,735 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 35 - 45 $26,565 -$34,155 44.80 $34,003.20

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 6 of 17
6

PROJECT 

CATEGORY

TASK 

CODE MARCH MARCH

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

ERS (33260/007 and 025)

Confirmation 216 0 $0 0.00 $0.00

Tax 217 0 - 5 $0 - $3,735 0.00 $0.00

Employment and Fee 

Applications 218 5 - 15 $2,680 -$7,240 12.60 $5,471.60

Appeal 219 0 - 10 $0 - $7,470 0.00 $0.00

TOTALS 240 – 540 $256,112 -

$397,620 376 $275,703.40

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 7 of 17
7

Exhibit D-3

Budget Plan for the Period of April 1, 2018 through April 30, 20181

 1 Budgets are only provided for matters Proskauer actually billed time to in a given month. If no time was billed to a given 

matter during the month, no monthly budget has been provided for that matter

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 8 of 17
8

PROJECT CATEGORY TASK 

CODE APRIL APRIL

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 - $7,470 0.00 $0.00

Legal Research 202 0 - 10 $0 - $7,470 0.00 $0.00

Hearings and other nonfiled communications with 

the Court

203 0 - 5 $0 - $3,735 0.00 $0.00

Communications with 

Claimholders 204 0 - 10 $0 - $7,470 1.30 $986.70

Communications with the 

Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 - 5 $0 - $3,735 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 0 -10 $0 - $7,470 0.00 $0.00

Non-Board Court Filings

207 0 - 5 $0 - $3,735 1.20 $910.80

Stay Matters 208 0 - 5 $0 - $3,735 0.00 $0.00

Adversary Proceeding 209 0 - 5 $0 - $3,735 0.00 $0.00

Analysis and Strategy 210 5 - 15 $3,735-

$10,120 5.40 $4,098.60

Non-Working Travel 

Time 211 0 - 5 $0 - $3,735 0.00 $0.00

General Administration 212 0 - 5 $0 - $3,735 0.00 $0.00

Labor, Pension Matters 213 0 - 10 $0 - $7,470 .30 $1,022.00

Legal/ Regulatory Matters 214 0 - 5 $0 - $3,735 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 20 - 45 $15,210 -$34,170 15.40 $11,688.60

Confirmation 216 0-0 $0 - $0 0.00 $0.00

Tax 217 0 - 5 $0 - $3,735 0.00 $0.00

Employment and Fee 

Applications 218 15 - 25 $7,240 -$14,480 20.70 $6,779.20

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 9 of 17
9

PROJECT CATEGORY TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Appeal 219 0 - 10 $0 - $7,470 0.00 $0.00

Fee Applications for Other 

Parties 220 0 - 10 $0 - $7,470 0.00 $0.00

TOTALS 40 - 200 $24,385 –

$144,675 44.30 $25,485.90

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 10 of 17
10

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

ERS – ALTAIR (33260/045)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 5 $0 – $3,735 0.00 $0.60

Legal Research 202 0 – 10 $0 – $7,470 0.70 $531.30

Hearings and other nonfiled communications 

with the Court

203 0 – 5 $0 – $3,735 0.00 $0.00

Communications with 

Claimholders 204 0 – 5 $0 – $7,470 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 5 $0 – $3,735 0.00 $0.80

Documents Filed on 

Behalf of the Board 206 10 – 20 $7,470 –$14,490 17.30 $13,130.70

Non-Board Court Filings 207 5 – 15 $3,735 –

$11,205 6.00 $4,554.00

Stay Matters 208 0 $0 0.00 $0.00

Adversary Proceeding 209 0 $0 0.00 $0.00

Analysis and Strategy 210 0 – 5 $0 – $3,735 0.00 $0.00

Non-Working Travel 

Time 211 0 – 5 $0 – $3,735 0.00 $0.00

General Administration 212 0 – 5 $0 – $2,920 1.10 $286.00

Labor, Pension Matters 213 0 – 5 $0 – $3,735 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 $0 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 5 $0 – $3,735 0.00 $0.00

Tax 217 0 – 5 $0 – $3,735 0.00 $0.00

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 11 of 17
11

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

ERS – ALTAIR (33260/045)

Employment and Fee 

Applications 218 0 – 5 $0 – $3,735 0.00 $0.00

Appeal 219 0 $0 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 5 $0 – $3,735 0.00 $0.00

TOTALS 15 – 120 $11,205 -

$88,495 25.10 $18,503.40

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 12 of 17
12

Exhibit D-4

Budget Plan for the Period of May1, 2018 through May 31, 20182

 2 Budgets are only provided for matters Proskauer actually billed time to in a given month. If no time was billed to a given 

matter during the month, no monthly budget has been provided for that matter

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 13 of 17
13

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

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 – $7,590 1.50 $1,138.50

Legal Research 202 0 – 5 $0 – $3,735 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 0 – 5 $0 – $3,735 0.20 $151.80

Communications with 

Claimholders 204 0 – 5 $0 – $3,735 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 5 $0 – $3,735 0.70 $531.30

Documents Filed on 

Behalf of the Board 206 0 – 15 $0 – $11,502 0.00 $0.00

Non-Board Court Filings

207 0 – 10 $0 – $7,590 0.00 $0.00

Stay Matters 208 0 - 5 $0 - $3,800 0.00 $0.00

Adversary Proceeding 209 0 $0 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 2.30 $1,745.70

Non-Working Travel 

Time 211 0 – 5 $0 – $3,735 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 0.00 $0.00

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 5 - 15 $3,800 -$11,502 7.40 $5,616.60

Confirmation 216 0 - 5 $0 - $3,800 0.00 $0.00

Tax 217 0 - 5 $0 - $3,800 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 14 of 17
14

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 5 $0 – $3,735 0.00 $0.00

TOTALS 5 - 145 $3,800-

$109,954 12.10 $9,183.90

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 15 of 17
15

Exhibit D-5

Staffing Plan for the Compensation Period

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 16 of 17
16

Staffing Plan for the Compensation Period

Category of Timekeeper3 Number of 

Timekeepers Expected 

to Work on The Matter 

During the Budget Period4

Average Hourly Rate5

Partners 14 $759

Senior Counsel 0 $759

Associates 10 $759

Law Clerks 1 $260

Paraprofessionals 8 $260 

 3 Attorney Practice Groups: BSGR&B (8); Litigation (12); Corporate (5).

4 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.

5 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 another, lower blended rate (currently $260) for all other professionals, no annual step increases will 

be applicable to the rates charged in this matter. As detailed in the Second Interim Application, Proskauer’s rates 

under the Engagement Letter increased from $730 per hour for attorneys and $250 per hour for paraprofessionals 

to $759 per hour for attorneys and $260 per hour for paraprofessionals on January 1, 2018, during the second 

interim compensation period. Rates have not increased during this Compensation Period.

Case:17-03283-LTS Doc#:3573-4 Filed:07/16/18 Entered:07/16/18 22:14:13 Desc:

Exhibit D Page 17 of 17