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 NILDA M. NAVARRO-CABRER, AS 

LOCAL COUNSEL TO BETTINA M. WHYTE, 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 Nilda M. Navarro-Cabrer

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 2017 Fee Statement

Exhibit 4-B – Time and Expense Detail for the November 2017 Fee Statement

Exhibit 4-C – Time and Expense Detail for the December 2017 Fee Statement

Exhibit 4-D – Time and Expense Detail for the January 2018 Fee Statement

Exhibit 5 – Comparable Compensation Disclosures

Exhibit 6 – Budget and Staffing Plans 

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SUMMARY SHEET TO THE SECOND INTERIM APPLICATION OF NAVARROCABRER FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED 

AND REIMBURSEMENT OF EXPENSES INCURRED AS LOCAL COUNSEL TO THE 

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

Name of Applicant Nilda M. Navarro Cabrer

Authorized to Provide Professional Services to Bettina M. Whyte, as COFINA Agent

Time period covered by this application October 1, 2017 through January 31, 

2018

Total compensation incurred this period $102,662.50 1

Total compensation sought this period after all voluntary 

reductions

$102,587.502

Total expenses sought this period $784.42

Petition date May 5, 2017 for COFINA (as defined 

below)

Retention date August 16, 2017

Date of order approving- employment November 3, 2017 (Docket No. 1612), 

nunc pro tunc to August 16, 2017

Total compensation approved by interim order to date $35,962.50

Total expenses approved by interim order to date $431.50

Blended rate in this application for all attorneys $370.18

Blended rate in this application for all timekeepers $345.21

Compensation sought in this application already paid 

pursuant to the interim compensation order but not yet 

allowed

$67,380.00

(90% of Fees, less $75.00 which 

Navarro-Cabrer is writing off, see 

footnote 2.)

Expenses sought in this application already paid 

pursuant to the interim compensation order but not yet 

allowed

$367.40 

 1 This does not include $1,687.50, representing 4.5 hours of work that has been written off in the exercise of 

billing discretion and is reflected as “No Charge” on the billing records, and also does not include an 

additional $2,925.00 representing 7.8 hours of work that has been written off in the exercise of billing 

discretion and does not appear on the billing records at all.

2 Navarro-Cabrer received no objection or response to her Monthly Fee Statements for the time period 

covered by this Application, but the Debtors erroneously paid $75.00 less than requested for the months of 

October, November and December, 2017 (that is, $25.00 less per month). Navarro-Cabrer is writing off the 

$75.00 not paid, and is only seeking payment of the remaining amount that was held back for those three

(3) months and of the fees and expenses incurred in January 2018, which have not been paid.

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Number of professionals included in this application 3 

If applicable, number of professionals in this application 

not included in staffing plans approved by client

1 3

If applicable, difference between fees budgeted and 

compensation sought for this period

Fees Budgeted: $126,440.75

Fees Sought: $102,587.50

Difference: $ 23,853.25

Number of professionals billing fewer than 10 hours to 

the case during this period

None

Are any rates higher than those approved or disclosed at 

retention? If yes, calculate and disclose the total 

compensation sought in this application using the rate 

originally disclosed in the retention application.

No

This is an interim application.

The total time expended for monthly and interim fee application preparation for the Application

Period is approximately 38.70 hours and the corresponding compensation requested is 

approximately $9,662.50. Time billed to the 0005 (Fee Applications and Retentions) category 

includes (i) time expended for fee application preparation, and (ii) time expended for fee-related 

tasks not relating to fee application preparation, such as analysis and correspondence concerning 

Fee Examiner memoranda, analysis of the Fee Examiner’s motion for an amended Interim 

Compensation Order, and communications with co-counsel an others concerning compliance 

with the Interim Compensation Order and the COFINA Protections Order (as defined below). 

Accordingly, even though the total amount listed in this paragraph is necessarily less than the 

total amount of fees in category 0005, this amount is accurate.

[Remainder of Page Intentionally Left Blank.]

 3 Due to a conflict in schedule, an associate that was not included in the staffing plan had to perform certain 

limited and specific tasks, as explained in detail in the summary of services rendered regarding mediation, 

Billing Code 00004. See footnote 9 on page 17.

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PRIOR INTERIM OR MONTHLY FEE PAYMENTS TO DATE

Requested Paid

Date 

Payment 

Received

Monthly Fee Statement Paid Fees Expenses Fees Expenses

12/4/17 Monthly Fee Statement for the 

period of August 16, 2017 

through August 30, 2017 

$10,925.00 $62.50 $9,832.50 $62.50

12/4/17 Monthly Fee Statement for the 

period of September 1, 2017 

through September 30, 2017

$25,062.25 $369.00 $22,531.254 $369.00

12/27/17 Monthly Fee Statement for the 

period of October 1, 2017 

through October 31, 2017

$17,662.50 $323.10 $15,871.255 $323.10

1/24/18 Monthly Fee Statement for the 

period of November 1, 2017 

through November 30, 2017

$33,837.50 $20.50 $30,428.756 $20.50

2/13/18 Monthly Fee Statement for the 

period of December 1, 2017 

through December 31, 2017

$23,450.00 $23.80 $21,080.007 $23.80

Total fees and expenses PAID to date: $99,743.75 $798.90

 4 The Debtors paid $25.00 less for the month of September, 2017. No reason was given for this deduction, 

which Navarro-Cabrer is writing off. Navarro-Cabrer is only seeking payment of the remaining 10% that 

was held back.

5 The Debtors paid $25.00 less for the month of October, 2017. No reason was given for this deduction,

which Navarro-Cabrer is writing off. Navarro-Cabrer is only seeking payment of the remaining 10% that 

was held back.

6 The Debtors paid $25.00 less for the month of November, 2017. No reason was given for this deduction, 

which Navarro-Cabrer is writing off. Navarro-Cabrer is only seeking payment of the remaining 10% that 

was held back.

7 The Debtors paid $25.00 less for the month of December, 2017. No reason was given for this deduction, 

which Navarro-Cabrer is writing off. Navarro-Cabrer is only seeking payment of the remaining 10% that 

was held back.

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

Nilda M. Navarro Cabrer, d/b/a Navarro-Cabrer Law Offices (“Navarro–Cabrer”), as 

Local Counsel to Bettina M. Whyte, the COFINA Agent (the “COFINA Agent”) in the abovecaptioned 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 $102,587.50 and reimbursement for actual and necessary expenses in 

connection with such services in the amount of $784.42, for the period of October 1, 2017 

through January 31, 2018 (the “Application Period”). Navarro-Cabrer submits this Application 

pursuant to sections 316 and 317 of the Puerto Rico Oversight, Management, and Economic 

Stability Act (“PROMESA”),1 48 U.S.C. §§ 2176, 2177; sections 105(a) and 503(b) of chapter 

11 of the United States Code (the “Bankruptcy Code),2 Rule 2016(a) of the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”),

3 Rule 2016-1 of the Bankruptcy Rules for the 

United States Bankruptcy Court for the District of Puerto Rico (the “Local Rules”)4, the First 

Amended Order Setting Procedures for Interim Compensation and Reimbursement of Expenses 

of Professionals (“Interim Compensation Order”) [Dkt. No. 1715] and the United States 

Trustee’s Guidelines for Reviewing Applications for Compensation and Reimbursement of 

Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Large Chapter 11 Cases Effective as of 

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

2 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.

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

section 310 of PROMESA.

4 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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November 1, 2013 (the “UST Guidelines”)5 and the Fee Examiner’s Fee Review – Timeline and 

Process Memo dated November 10, 2017. In support of the Application, Navarro-Cabrer 

respectfully represents: 

PRELIMINARY STATEMENT 

1. Navarro-Cabrer’s services to the COFINA Agent continue to be

substantial, necessary and beneficial to the COFINA Agent and have materially advanced the 

Commonwealth-COFINA Dispute. During the Application Period, Navarro-Cabrer has worked 

diligently on behalf of the COFINA Agent, including among other things: (i) providing required 

services as local counsel in compliance with Rule 83A (f) of the Local Rules of the District 

Court for the District of Puerto Rico (“Local District Court Rules”) and Rule 2090-1 of the 

Local Rules, to advance the Commonwealth-COFINA Dispute6; (ii) providing local counsel 

expertise and perspective; (iii) reviewing, analyzing and revising all motions and pleadings to be 

filed on behalf of the COFINA Agent, as required by the Local District Court Rules; (iv)

conducting discovery as to third parties located in Puerto Rico, negotiating productions with the 

parties in Puerto Rico who were the subject of the such requests; and (iv) regularly discussing 

strategy and key issues in the Commonwealth-COFINA Dispute with the COFINA Agent and 

her other professionals. Throughout the Application Period, the variety and complexity of the 

issues involved in these cases and the need to address many of those issues on an expedited 

basis, have required Navarro-Cabrer to devote substantial time on a daily basis. For a significant 

part of the Application Period, Navarro-Cabrer’s office was without electric power, internet and 

 5 Pursuant to the Interim Compensation Order and Local Rule 2016-1, Navarro-Cabrer is required to comply 

with the UST Guidelines.

6 Terms used but not defined herein shall have the meaning ascribed to them in the Stipulation and Order 

Approving Procedure to Resolve Commonwealth-COFINA Dispute (the “Commonwealth-COFINA 

Stipulation”).

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telephone services, due to the devastation caused by Hurricane María. To continue providing 

legal services and support as local counsel to the COFINA Agent, Navarro-Cabrer relocated to 

temporary facilities with the required services, including a power generator.

7

2. Navarro-Cabrer’s services to the COFINA Agent during the Application 

Period were reasonable and necessary, and Navarro-Cabrer respectfully requests that the Court 

approve the fees and expenses requested in this Application.

JURISDICTION AND VENUE

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

section 306(a) of PROMESA.

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

5. Navarro-Caber 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), the Interim 

Compensation Order and the UST Guidelines.

BACKGROUND

A. General Background 

6. 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.

 7 Electric power was restored at Navarro-Cabrer’s office by the end of November 2017, and telephone and 

internet were restored in December 2017. Nevertheless, given the frequency of power failures and 

intermittent internet service, Navarro-Cabrer continues to operate from temporary facilities equipped with 

the required services, including a power generator, to insure the continuity of legal services.

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7. 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. 

8. 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.

9. 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.

10. 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. Navarro-Cabrer’s Retention by the COFINA Agent

11. On August 10, 2017, the Court entered the Commonwealth-COFINA 

Stipulation. The Commonwealth-COFINA Stipulation appointed Bettina M. Whyte as the 

COFINA Agent and authorized her to retain such legal and other professionals as she reasonably 

deems appropriate to meet her responsibilities and to compensate such professionals in 

conformity with PROMESA section 316 and any interim compensation procedures ordered by 

the Court. The Commonwealth-COFINA Stipulation appointed Willkie Farr & Gallagher LLP 

(“WF&G”) as lead counsel to the COFINA Agent and Klee, Tuchin, Bogdanoff & Stern LLP 

(“KTB&S”) as special municipal bankruptcy counsel to the COFINA Agent. 

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12. Rule 83A (f) of the Local District Court Rules and Rule 2090-1 of the 

Local Rules, require the COFINA Agent to retain Puerto Rico counsel to appear in litigation in 

this forum. Said Rules require attorneys admitted por hac vice to remain associated with local 

counsel and require local counsel to sign all filings submitted to the Court and to attend all 

proceedings. 

13. In compliance with said Rules and pursuant to the CommonwealthCOFINA Stipulation, on August 16, 2017, the COFINA Agent engaged Navarro-Cabrer as local 

counsel in the Title III Cases to, among other things, endorse the requests for admission pro hac 

vice of the lead counsel and the special municipal bankruptcy counsel to the COFINA Agent;

consult as to the interpretation of Puerto Rico law; appear as local counsel at hearings; and 

perform those tasks for which the COFINA Agent, the lead counsel and the special municipal 

bankruptcy counsel to the COFINA Agent choose to assign and request Navarro-Cabrer’s

involvement as local counsel. On November 3, 2017 [Dkt No. 1612], the Court approved, nunc 

pro tunc, the COFINA Agent’s retention of Navarro-Cabrer as local counsel, “without need for 

further application or order”.

14. The Commonwealth-COFINA Stipulation authorized the applicable 

Debtor (in Navarro-Cabrer’s case, COFINA) to compensate the legal professionals retained, for 

the professional fees and the actual and necessary out-of-pocket expenses incurred, subject to 

application to this Court as set forth herein. The Commonwealth-COFINA Stipulation further 

provides that the Commonwealth must make such payments within fourteen (14) days of 

receiving notice of nonpayment. As set forth more fully below, pursuant to the Interim 

Compensation Order (as defined below), Navarro-Cabrer has filed four (4) monthly fee 

statements during the Application Period and has been paid 90% of 100% of the fees (as 

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described above) and 100% of the expenses requested pursuant to the October Fee Statement and 

November Fee Statement.8 As of the date of this Application, Navarro-Cabrer has not received 

payment for her January Fee Statement.

SUMMARY OF PROFESSIONAL COMPENSATION 

AND REIMBURSEMENT OF EXPENSES REQUESTED

15. 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, Navarro-Cabrer 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 $103,371.92 (the “Application 

Amount”), which includes (a) compensation of $102,587.50 in fees for services rendered to 

COFINA and (b) reimbursement of $784.42 in actual and necessary expenses in connection with 

these services. As of the date hereof, Navarro-Cabrer has been paid all amounts for the 

Application Period other than $35,624.52, which represents (i) 10% of Navarro-Cabrer’s fees 

that have been “held back” for the period of October 1, 2017 through October 31, 2017; (ii) 10% 

of Navarro-Cabrer’s fees that have been “held back” for the period of November 1, 2017 through 

November 30, 2017; (iii) 10% of Navarro-Cabrer’s fees that have been “held back” for the 

period of of December 1, 2017 through December 31, 2017; and (iv) 100% of Navarro-Cabrer’s 

fees and 100% of Navarro-Cabrer’s expenses for the period of January 1, 2018 through January 

31, 2018 (any amounts that remain unpaid as of the date of an order approving this Application, 

the “Holdback”).

 8 Navarro-Cabrer is writing off $75.00 not paid due an inadvertent error.

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PRIOR INTERIM AWARDS AND REQUESTS

16. Navarro-Cabrer filed her first interim fee application on December 15, 

2017 [Dkt. No. 2038] for interim allowance of compensation for services rendered and 

reimbursement of expenses incurred from August 16, 2017 through September 30, 2017. On 

February 14, 2017, the Fee Examiner sent a confidential letter report to Navarro-Cabrer (“Fee 

Examiner’s Letter Report”), making several observations, comments, and suggestions for 

future fee applications, but did not recommend any deductions to the fees or expenses requested 

in Navarro-Cabrer’s first interim fee application. Pursuant the Omnibus Order Awarding Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the First Interim Compensation Period from May 3 through September 30, 2017 [Dkt. No. 

2685], the Court awarded to Navarro-Cabrer the interim fees and expenses requested, that is 

$35,962.50 in fees and $431.50 in expenses. 

NAVARRO-CABRER’S FEES AND EXPENSES FOR THE APPLICATION PERIOD

17. Navarro-Cabrer’s services in these cases have materially advanced the 

Commonwealth-COFINA Dispute. Throughout the Application Period, the variety and 

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

required Navarro-Cabrer, in the discharge of her professional responsibilities, to devote 

substantial time on a daily basis

18. Specifically, Navarro-Cabrer requested compensation reflects the 

requisite time, skill and effort Navarro-Cabrer expended during the Application Period towards, 

inter alia: (a) providing required services as local counsel in compliance with the Local District 

Court Rules and the Local Rules; (b) contributing to various pleadings and motions on behalf of 

the COFINA Agent, including responses to the scope motions filed in the CommonwealthCOFINA Dispute (“Scope Motions”) and responses to the Amended Complaints filed by the 

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Commonwealth Agent; (c) conducting legal research and analysis as to Puerto Rico Law in 

connection with the Commonwealth-COFINA Dispute; (d) continuing discovery procedures as 

to third parties located in Puerto Rico; and (e) providing local counsel expertise and perspective.

19. Navarro-Cabrer respectfully submits that its efforts on behalf of the 

COFINA Agent during the Interim Period have been both (i) at the request of the COFINA 

Agent, and (ii) not duplicative of work performed by the COFINA Agent’s other professionals.

MONTHLY FEE STATEMENTS

20. 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 were received, the Debtors were 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 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’s 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 

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

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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. 

21. In compliance with the Interim Compensation Order, Navarro-Cabrer 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”), Navarro-Cabrer requested payment of $ 16,219.35,

representing the total of (i) $15,896.25, which is 90% of the fees requested 

for services rendered (i.e., $17,662.50) plus (ii) $323.10, 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”), 

Navarro-Cabrer requested payment of $ 30,453.75, representing the total 

of (i) $30,453.75, which is 90% of the fees requested for services rendered 

(i.e., $ 33,837.50) plus (ii) $20.50, representing 100% of the expenses 

incurred during the period. 

(c) Pursuant to the Monthly Fee Statement for the period December 1, 

2017 through December 31, 2017 (the “December Fee Statement”),

Navarro-Cabrer requested payment of $ 21,128.80, representing the total 

of (i) $ 21,105.00, which is 90% of the fees requested for services 

rendered (i.e., $23,450.00) plus (ii) $23.80, 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”), NavarroCabrer requested payment of $ 25,358.27, representing the total of (i) $

24,941.25, which is 90% of the fees requested for services rendered (i.e., $ 

27,712.50) plus (ii) $417.02, representing 100% of the expenses incurred 

during the period. 

22. Navarro-Cabrer did not receive any objection to the October, November, 

December or January Fee Statements. A review of the Court Docket reflects that there is no 

answer, objection, or other responsive pleading to these four (4) Fee Statements. In accordance 

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with the Interim Compensation Order, Navarro-Cabrer received payment of $16,194.35 relating 

to the October Fee Statement; $30,449.25 relating to the November Fee Statement; and 

$21,103.80 relating to the December Fee Statement. As of the date of this Application, NavarroCabrer has not received payment of her January Fee Statement.

FEES AND EXPENSES INCURRED DURING APPLICATION PERIOD

23. Annexed hereto as Exhibit 1 is the Certification of Nilda M. NavarroCabrer pursuant to the Local Rules (the “Certification”).

24. Annexed hereto as Exhibit 2 is a summary sheet listing each attorney and 

paraprofessional who has worked on these cases during the Application Period, his or her hourly 

billing rate during the Application Period, and the amount of Navarro-Cabrer’s fees attributable 

to each individual. 

25. Navarro-Cabrer also maintains records of all actual and necessary out-ofpocket 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.

26. Navarro-Cabrer maintains written records of the time expended by 

attorneys and paraprofessionals carrying out professional services to the Debtors. 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 Navarro-Cabrer during the Application Period, the aggregate amount of hours and 

fees expended for each of those matters, and the budgeted amount of hours and fees.

27. In accordance with the UST Guidelines, Navarro-Cabrer recorded her

services rendered and disbursements incurred in different project matters that reasonably could 

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

application period.

28. No agreement or understanding exists between Navarro-Cabrer and any 

other entity for the sharing of compensation to be received for services rendered in or in 

connection with these cases. 

29. The fees charged by Navarro-Cabrer in these chapter 11 cases are billed in 

accordance with her existing billing rates and procedures. The hourly rates of Navarro-Cabrer in 

these Title III Cases are commensurate with the complexity, importance, and nature of the 

problems, issues, and tasks addressed, and with the demands imposed by the expedited nature 

and extraordinary environment—legal and practical—of these proceedings. Navarro-Cabrer’s 

hourly rates in this matter are comparable to the hourly rates charged in the Title III Cases and in 

comparable non-bankruptcy by similarly-skilled local counsel and substantially lower than those 

fees charged in the competitive national legal market. Consistent with the UST Guidelines, 

Exhibit 5 discloses the blended hourly rate for all non-bankruptcy timekeepers and the blended 

hourly rate for timekeepers who billed to the Debtors during the Application Period. 

SUMMARY OF SERVICES RENDERED

30. Recitation of each and every item of professional services that NavarroCabrer performed during the Application Period would unduly burden the Court. Hence, the 

following summary highlights the major areas to which Navarro-Cabrer devoted substantial time 

and attention during the Application Period. The full breadth of Navarro-Cabrer’s services is 

reflected in Navarro-Cabrer’s time records, copies of which are annexed hereto as Exhibits 4(A)-

(D).

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A. COFINA Bond Litigation - Billing Code: 00001

(Fees: $51,050.00 Hours Billed:139)

31. 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.

32. The Commonwealth Agent subsequently commenced an adversary 

proceeding against the COFINA Agent, attacking the ownership, other rights and 

constitutionality of COFINA’s sales and use tax revenue.

33. During the Application Period, Navarro-Cabrer, as local counsel to the 

COFINA Agent, spent a significant amount of time providing services required to comply with

Rule 83A (f) of the Local District Court Rules and Rule 2090-1 of the Local Rules, and to assist 

the COFINA Agent’s discharge of her duty to litigate and/or settle the Commonwealth-COFINA 

Dispute. Navarro-Cabrer has assisted the COFINA Agent, the lead counsel to the COFINA 

Agent and the municipal bankruptcy counsel to the COFINA Agent in various ways, including 

but not limited to, providing local counsel expertise and perspective. 

34. Navarro-Cabrer conferred with the COFINA Agent, the lead counsel to 

the COFINA Agent, the special municipal bankruptcy counsel to the COFINA Agent, and 

counsel for other COFINA constituents. 

35. To comply with the Local District Court Rules and Local Rules that 

require local counsel to sign all filings, Navarro-Cabrer spent time reviewing, analyzing and 

revising all motions and pleadings to be filed on behalf of the COFINA Agent, including but not 

limited to the objection to the Commonwealth Agent’s motion for reconsideration of the 

December 21, 2017 ruling on the Scope Motions and the response to the Commonwealth Agent’s 

Second Amended Complaint. In order to responsibly sign all filings summited to the Court as 

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required by the Local District Court Rules and the Local Rules and to remain informed of all 

legal arguments that might implicate the Commonwealth-COFINA Dispute, Navarro-Cabrer was 

required to examine and analyze all pleadings and filings relevant to the COFINA Agent. 

Navarro-Cabrer also attended hearings as required by the Local District Court Rules and the 

Local Rules, including the January 10, 2018 hearing of the motion to clarify the Scope Motion in 

the Adversary Proceeding against the COFINA Agent. To reduce expenses, rather than traveling 

to New York for the hearing, Navarro-Cabrer attended the hearing in United States District Court 

for the District of Puerto Rico, via closed circuit. 

36. During the Application Period, Navarro-Cabrer conducted legal research 

as to various issues of Puerto Rico law in connection with the development of various arguments

for the COFINA Agent’s motion for summary judgment. Navarro-Cabrer also began analyzing 

and conducting legal research as to the procedure for certifying questions of Puerto Rico law to 

the Supreme Court of Puerto Rico. Navarro-Cabrer worked diligently and efficiently in 

connection with this matter, delegating work to a paraprofessional when appropriate. 

B. Case Administration - Billing Code: 00002

(Fees: N/A / Hours Billed: N/A)

37. Navarro-Cabrer expended no time addressing case administration during 

the Application Period. 

C. COFINA Meetings/Creditor Communications-Billing Code: 00003

(Fees: $375.00/ Hours Billed:1)

38. This Subject Matter reflects reasonable time spent in communications with 

local counsel for the Senior COFINA Bondholder Coalition and other COFINA holders. 

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D. Mediation - Billing Code: 00004

(Fees: $16,387.50 / Hours Billed: 49.3)

39. This Subject Matter includes all time spent on issues related to the

mediation and negotiation of the Commonwealth-COFINA Dispute. In particular, in November, 

2017, the COFINA Agent requested Navarro-Cabrer to expand her role as local counsel to

provide information and analysis as to economic and political developments in Puerto Rico 

relevant to the Commonwealth-COFINA Dispute and the mediation process. In November, 2017, 

Navarro-Cabrer commenced participating in weekly conference calls with the COFINA Agent 

and co-counsel regarding mediation strategy, as well as analyzing memoranda and information 

sent by the mediation team.

40. At the request of the COFINA Agent, Navarro-Cabrer attended (via 

webcast) the House Committee of Natural Resources hearings as to the Oversight Board’s role in 

the recovery of Puerto Rico and the need for transparent financial accountability in Puerto Rico; 

and two hearings held by the Oversight Board in Puerto Rico in November 2107 and January 

2018, on the liquidity of the Commonwealth, its instrumentalities and entities, and other 

economic issues relevant to the Commonwealth-COFINA Dispute.

9 Navarro-Cabrer drafted 

Memoranda regarding said hearings and provided local perspective and insight as to issues 

discussed at the hearings that are relevant to the mediation and negotiation of the 

Commonwealth-COFINA Dispute. Also at the COFINA Agent’s request, Navarro-Cabrer 

listened to the Governor’s televised message to the country and drafted a Memorandum 

summarizing and analyzing the message.

E. Fee Applications & Retention - Billing Code: 00005

(Fees: $12,425.00 / Hours Billed: 46.20)

 9 Due to a conflict in schedule, an associate under Navarro-Cabrer’s supervision attended the hearing held by 

the Oversight Board in Puerto Rico in November 2017, to obtain information relevant to the 

Commonwealth-COFINA Dispute and report back to the COFINA Agent and the mediation team.

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41. This Subject Matter includes all matters related to the retention and 

compensation of the COFINA Agent’s professionals. Specifically, time billed to this Subject 

Matter during the Compensation Period includes analysis of the Court’s amended order as to

compensation of professionals in these Title III Cases; study of the Fee Examiner's Status Report 

as to Interim Fee Application and Memorandum regarding the fee review process; 

communications with co-counsel; and preparation and service of Navarro-Cabrer’s Monthly Fee

Statements, limited to the tasks not required for lawyers practicing in areas other than bankruptcy 

as a condition to getting paid. This Subject Matter also includes time spent during the 

Application Period drafting the First Interim Fee Application. Navarro-Cabrer delegated several 

appropriate tasks related to application and retention to a paraprofessional, minimizing the costs 

incurred.

F. Fee Application & Retention Objections - Billing Code: 00006

(Fees: $1,050.00 / Hours Billed: 3.4)

42. This category reflects reasonable time spent preparing the Statements of 

No Objection. Navarro-Cabrer delegated appropriate tasks related to application and retention 

objections to a paraprofessional, minimizing the costs incurred.

G. Budget - Billing Code: 00007

(Fees: $2,450.00 / Hours Billed: 9)

43. This category reflects reasonable time spent preparing the required 

budgets. Navarro-Cabrer delegated appropriate tasks to a paraprofessional, minimizing the costs 

incurred.

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H. Discovery/Fact Analysis - Billing Code: 00008

(Fees: $18,925.00 / Hours Billed: 55.8)

44. During the Application Period, Navarro-Cabrer assisted the COFINA 

Agent with discovery addressed to third parties located in Puerto Rico, including revising and 

serving multiple Subpoenas Duces Tecum to third parties in Puerto Rico, in connection with the 

adversary proceeding against the COFINA Agent; filing the required Notices; participating in the 

negotiation of productions with the third parties located in Puerto Rico who were the subject of 

the such requests; reviewing deposition subpoenas to deponents located in Puerto Rico and 

coordinating the service of the deposition subpoenas. Navarro-Cabrer delegated appropriate tasks 

to a paraprofessional, minimizing the costs incurred.

I.Non-Working Travel - Billing Code: 00009

(Fees: N/A / Hours Billed: N/A)

45. Navarro-Cabrer expended no time in non-working travel during the 

Application Period. 

EVALUATING NAVARRO-CABRER’S SERVICES

46. 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—

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(1) the time spent on such services;

(2) the rates charged for such services;

(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).

47. Navarro-Cabrer respectfully submits that the services as local counsel for 

which she seeks compensation in this Application were necessary for and beneficial to the 

COFINA Agent. Navarro-Cabrer was engaged as local counsel to the COFINA Agent due to her 

knowledge and expertise as to Puerto Rico law, Puerto Rico Constitutional provisions relevant to 

the Commonwealth-COFINA dispute, and the Local District Court Rules and Local Rules.10

During the Application Period, Navarro-Cabrer has provided local counsel expertise and 

 10 Since 1999, Navarro-Cabrer has served as Member of the District Court Examination Committee,

appointed by the United States District Court for the District of Puerto Rico, in charge of Local District 

Court Rules and Civil Procedure. Since 2006, she has been an Adjunct Professor at the University of Puerto

Rico Law School, where she teaches Civil Procedure and trial advocacy courses. Navarro-Cabrer has an 

LL.M. degree from Harvard University (1985); a J.D. degree from the University of Puerto Rico (1983 

Magna Cum Laude), where she was the Editor in Chief of the Law Review; and a BA from Georgetown 

University (Magna Cum Laude, 1980). After graduating from law school, she served as law clerk to the 

Hon. Jose Trias-Monge, Chief Justice of the Supreme Court of Puerto Rico, and to the Hon. Stephen G. 

Breyer at the United States Court of Appeals for the First Circuit. 

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perspective to the COFINA Agent in a variety of challenging legal issues, often requiring 

research and analysis of Puerto Rico law. 

48. Navarro-Cabrer further submits that the services rendered to the COFINA 

Agent were performed efficiently and effectively. Indeed, the small size of Navarro-Cabrer Law 

Offices guarantees that there is no duplication or overlap in work performed, precludes 

overlapping billing by multiple attorneys, and results in reduced fees. Finally, Navarro-Cabrer

submits that the compensation requested herein is reasonable in light of the nature, extent and 

value of such services to the COFINA Agent 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.

49. Courts typically employ the “lodestar” approach to calculate awards of 

attorneys’ fees. See New York State Ass’n for Retarded Children, Inc. v. Casey, 711 F.2d 1136, 

1140 (2d Cir. 1983); In re West End Fin. Advisors, LLC, No. 11-11152, 2012 Bankr. LEXIS 

3045, at *11 (Bankr. S.D.N.Y. July 2, 2012); In re Drexel Burnham Lambert Group, Inc., 133 

B.R. 13, 21-22 (Bankr. S.D.N.Y. 1991) (“In determining the reasonableness of the requested 

compensation under § 330, Bankruptcy Courts now utilize the lodestar method”). “The lodestar 

amount is calculated by multiplying the number of hours reasonably expended by the hourly rate, 

with the ‘strong presumption’ that the lodestar product is reasonable under § 330.” Drexel, 133 

B.R. at 22 (citations omitted). 

50. In determining the reasonableness of the services for which compensation 

is sought, the court should note that:

the appropriate perspective for determining the necessity of the 

activity should be prospective: hours for an activity or project 

should be disallowed only where a Court is convinced it is 

readily apparent that no reasonable attorney should have 

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undertaken that activity or project or where the time devoted 

was excessive.

Id. at 23; see also In re Cenargo Int’l PLC, 294 B.R. 571, 595-96 (Bankr. S.D.N.Y. 2003) (“The 

Court’s benefit of ‘20/20 hindsight’ should not penalize professionals.”). 

51. Moreover, courts should be mindful that professionals “must make 

practical judgments, often with severe time constraints, on matters of staffing, assignments, 

coverage of hearings and meetings, and a wide variety of similar matters.” Drexel, 133 B.R. 

at 23. These judgments are presumed to be made in good faith. Id. 

52. Navarro-Cabrer has made and and will continue to make efforts to comply 

with the requests made by the Fee Examiner. For example, following the Fee Examiner’s request 

in the Fee Examiner’s Letter Report sent on February 14, 2017, Navarro-Cabrer made the 

required adjustments so that commencing with the Fee Statement for the month of February 

2018, the electronic billing data for Navarro-Cabrer will use ABA billing codes. In addition, 

Navarro-Cabrer has done her best to provide more detailed descriptions of the tasks performed 

and to segregate all individual tasks to facilitate review. However, given that Navarro-Cabrer 

only learned of the Fee Examiner’s requests after she had already submitted the four (4) monthly 

fee statements for the Application Period, Navarro-Cabrer did not have the opportunity to 

include the Fee Examiner’s requests for time incurred during the Application Period. 

NAVARRO-CABRER’s REQUEST FOR INTERIM COMPENSATION

53. Navarro-Cabrer submits that this request for interim allowance of 

compensation is reasonable. The services rendered by Navarro-Cabrer, as highlighted above, 

were necessary, resulting in substantial progress and success in these cases. The services 

rendered by Navarro-Cabrer during the Application Period were performed diligently and 

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efficiently, with no duplication or overlap. When appropriate, Navarro-Cabrer delegated tasks to 

a paraprofessional, which resulted in reduced fees and enhanced cost efficiency. 

54. Navarro-Cabrer has rendered advice with skill and efficiency, providing 

insight and expertise as to Puerto Rico law relevant to the Commonwealth-COFINA dispute, and 

the required knowledge and expertise with the Local District Court Rules.

55. The professional services performed by Navarro-Cabrer on behalf of the 

COFINA Agent during the Application Period required an aggregate expenditure of 303.70

hours, consisting of 251.6 hours expended by partners; 14.4 by associates; and 37.7 hours 

expended by paraprofessionals.

56. For the Application Period, allowance of compensation in the amount 

requested will result in a blended hourly billing rate for attorneys of $370.18 and a total blended 

hourly billing rate (including paraprofessionals) of $337.71. 

57. Navarro-Cabrer’s hourly rates and fees charged are consistent with the 

market rate for comparable services and commensurate with the complexity, importance, and 

nature of the problems, issues, and tasks addressed, and with the demands imposed by the 

expedited nature and extraordinary environment—legal and practical—of these proceedings. 

Navarro-Cabrer’s hourly rates in this matter are comparable to the hourly rates charged in the 

Title III Cases by comparably-skilled local counsel and substantially lower than those fees 

charged in the competitive national legal market. In addition, the small size of Navarro-Cabrer 

Law Offices guarantees efficiency and precludes duplication of effort or overlapping billing by 

multiple attorneys. 

DISCUSSION OF BUDGET AND STAFFING PLAN

58. In accordance with the UST Guidelines, Navarro-Cabrer prepared monthly

budgets and staffing plans covering the Application Period, copies of which are annexed hereto 

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as part of Exhibit 6. These budgets were provided to and approved by the COFINA Agent.

Given that most of Navarro-Cabrer’s work as local counsel during the Application Period 

depended on tasks delegated by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent, Navarro-Cabrer submitted the budgets for October, November and 

December 2017, in aggregate amounts. On December 13, 2017, Navarro-Cabrer received a copy 

of a Memorandum from the Fee Examiner to the PROMESA Title III Professionals, dated 

November 10, 2017, describing certain budget requirements. Following said requirements, 

commencing with the budget for January 2018, Navarro-Cabrer submitted budgets by subject 

matter to the Fee Examiner.

59. The estimated amount of fees Navarro-Cabrer expected to incur during the 

Application Period was approximately $126,440.75. Navarro-Cabrer’s fees incurred during the 

Application Period were $23,853.25 less than budgeted by Navarro-Cabrer from the actual fees 

incurred by Navarro-Cabrer during the Application Period, after the voluntary deductions taken 

by Navarro-Cabrer. 

60. Navarro-Cabrer provided necessary and beneficial services to the 

COFINA Agent during the course of the Interim Period. The small size of Navarro-Cabrer Law 

Offices precludes duplication of effort or overlapping billing by multiple attorneys, resulting in 

efficiency and reduced fees. When appropriate, Navarro-Cabrer delegated work to a 

paraprofessional. 

61. Navarro-Cabrer further respectfully submits that the COFINA Agent was 

provided with Navarro-Cabrer’s monthly invoices for her review and has expressed no objection 

to those invoices.

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DISBURSEMENTS

62. Navarro-Cabrer incurred actual and necessary out-of-pocket expenses 

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

Navarro-Cabrer respectfully requests allowance of such reimbursement in full.

63. The disbursements for which Navarro-Cabrer seeks reimbursement 

include the duplicating, charged at $0.10 per page based upon the cost of supplies.

PROCEDURE

64. In accordance with the Interim Compensation Order, Navarro-Cabrer 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 2002.11 

Navarro-Cabrer submits that no other or further notice is required.

65. No previous application for the relief sought herein has been made to this 

or any other court. 

[Remainder of Page Intentionally Left Blank.]

 11 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, Navarro-Cabrer respectfully requests that this Court enter an order: 

(a) allowing interim approval of compensation to Navarro-Cabrer for services 

rendered from October 1, 2017 through January 31, 2018, inclusive, in the amount 

of $102,587.50;

(b) allowing interim approval of reimbursement to Navarro-Cabrer of actual, 

necessary expenses incurred in connection with the rendition of such services 

from A October 1, 2017 through January 31, 2018, inclusive, in the amount of 

$784.42;

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

Navarro-Cabrer that remain unpaid, including all Holdbacks; and

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

Dated: San Juan, Puerto Rico

March 19, 2018

/s/ Nilda M. Navarro-Cabrer

Nilda M. Navarro-Cabrer

USDC – PR No. 201212

NAVARRO-CABRER LAW OFFICES

El Centro I, Suite 206

500 Muñoz Rivera Avenue

San Juan, Puerto Rico 00918

Telephone: (787) 360-9584 (787)764-9595

Facsimile: (787) 765-7575

Email: navarro@navarrolawpr.com

Local Counsel to the COFINA Agent

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EXHIBIT 1

CERTIFICATION OF NILDA M. NAVARRO CABRER

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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 NILDA M. NAVARRO-CABRER PURSUANT TO

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

APPLICATIONS FOR COMPENSATION IN PUERTO RICO BANKRUPTCY CASES

I, Nilda M. Navarro Cabrer Esq., certify as follows:

1. I am a an attorney duly licensed and in good standing in the 

Commonwealth of Puerto Rico, member of the bar of the District Court for the District of Puerto 

Rico, d/b/a Navarro-Cabrer Law Offices (“Navarro–Cabrer”), local counsel to the COFINA 

Agent in the above-captioned cases. 

2. I submit this certification in conjunction with Navarro–Cabrer’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 

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

Rico, the Bankruptcy Rules, the Bankruptcy Code, the Guidelines for Reviewing Applications 

for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in 

Larger Chapter 11 Cases (the “UST Guidelines”) and the Interim Compensation Order 

(collectively, the “Guidelines”).

3. I am the professional with the responsibility for Navarro–Cabrer’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, I have read 

Navarro–Cabrer’s Application; 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; except to the extent the fees 

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

at rates and in accordance with practices customarily employed by Navarro–Cabrer and generally 

accepted in matters of this nature.

5. I believe that the COFINA Agent has reviewed Navarro–Cabrer’s 

Monthly Fee Statements that form the basis for the Application and has not objected to the 

amounts requested therein. Such Monthly Fee Statements were provided to the Notice Parties as 

required by the Interim Compensation Order and no objections were filed or received.

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 attorney or paraprofessional, the date on 

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

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

the services rendered by Navarro–Cabrer 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 

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. No agreement or understanding exists between Navarro-Cabrer and any 

person for a division of compensation or reimbursement received or to be received herein or in 

connection with these cases.

9. Navarro-Cabrer has sought to keep its fees and expenses at a reasonable 

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

represent the Debtors.

10. The following is provided in response to the request for additional 

information set forth in Section C.5 of the UST Guidelines.

Question: Did you agree to any variations from, or alternatives to, your standard 

or customary billing rates, fees or terms for services pertaining to this engagement 

that were provided during the application period?

Response: No.

Question: If the fees sought in this fee application as compared to the fees 

budgeted for the time period covered by this fee application are higher by 10% or 

more, did you discuss the reasons for the variation with the client?

Response: N/A. For the Application Period, Navarro-Cabrer is not seeking fees 

that exceeded the overall budgets by 10% or more. 

Question: Have any of the professionals included in this fee application varied 

their hourly rate based on the geographic location of the bankruptcy case?

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Response: No.

Question: Does the fee application include time or fees related to reviewing or 

revising time records or preparing, reviewing, or revising invoices? (This is 

limited to work involved in preparing and editing billed records that would not be 

compensable outside of bankruptcy and does not include reasonable fees for 

preparing a fee application.) If so, please quantify by hours and fees.

Response: No.

Question: Does this fee application include time or fees for reviewing time 

records to redact any privileged or other confidential information?

Response: No.

Question: Does this fee application include rate increases since retention?

Response: No.

Dated: San Juan, Puerto Rico

March 19, 2018

 /s/ Nilda M. Navarro-Cabrer

Nilda M. Navarro-Cabrer

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EXHIBIT 2

SUMMARY OF PROFESSIONALS FOR THE APPLICATION PERIOD

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COMPENSATION BY INDIVIDUAL

Name Department Bar 

Admission 

Date1

Position Hourly 

Rate

Hours

Billed

No 

Charge 

Hours

Fees Billed

PARTNERS

Nilda M. NavarroCabrer Litigation 1984 Partner $375.00 251.60 4.5 $94,350.00

Ayleen Charles Litigation 1994 Associate $250.00 14.40 0.00 $ 3,600.00

PARAPROFESSIONALS

Rosa M. Rivera Litigation N/A Paralegal $125.00 37.7 0.00 $ 4,712.50

 1 Unless otherwise indicated, the admission date included herein reflects the earliest admission of each 

attorney to the Puerto Rico Bar.

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EXHIBIT 3

SUMMARY OF EXPENSES FOR THE APPLICATION PERIOD

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

Disbursement Amount

Postage/Messenger/Overnight Delivery $29.12

Local Transportation --

Local Meals --

Other Out of Town Travel --

Lodging --

Airfare / Train --

Reproduction $70.30

Air Freight --

Data Acquisition (includes Legal Research) --

Court Reports / Other Fees --

Outside Consultants (including outside copy 

services and e-discovery provider) --

Transcript Costs --

Miscellaneous Disbursements --

Filing Fees --

Teleconferencing --

Process Server $340.00

Deposition fees and mileage for deponent $45.00

Pro hac vice fee $300.00

Total: $784.42

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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 Budgeted 

Hours*

Budgeted 

Fees*

COFINA Bond Litigation 139 $51,050.00

Case Administration -- --

Meetings/Creditor 

communications 1.00 $375.00

Mediation 49.30 $16,387.50

Fee Applications and 

Retention 46.20 $12,425.00

Fee Application and 

Retention Objections 3.40 $1,050.00

Budget 9.00 $2,450.00

Discovery/Fact Analysis 55.80 $18,925.00

Non-Working Travel -- --

TOTAL 303.70 $102,662.50** 375 $126,440.75

* Given that most of Navarro-Cabrer’s work as local counsel for the Application Period 

depended on tasks delegated by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent, and that the majority of the work was regarding in COFINA Bond 

Litigation, Navarro-Cabrer submitted the budgets for October, November and December, 2017, 

in aggregate amounts. These budgets were provided to and approved by the COFINA Agent. On 

December 13, 2017, Navarro-Cabrer received copy of a Memorandum from the Fee Examiner, 

dated November 10, 2017, describing certain budget requirements. Following said requirements, 

commencing with the budget for January 2018, Navarro-Cabrer submitted budgets by subject 

matter to the Fee Examiner.

** Navarro-Cabrer is writing off $75.00 not paid due an inadvertent error.

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EXHIBIT 4-A

TIME AND EXPENSE DETAIL FOR THE OCTOBER 2017 FEE STATEMENT

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We appreciate your business Page 1 of

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Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

11-13-2017

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 17103163

Invoice Period: 10-01-2017 - 10-31-2017

RE: Multiple Matters

00000 - Expenses

00001 - Litigation/Adversary Proceeding

00005 - Fee Application and Retention

00006 - Fee Application Retention and Objections

00008 - Discovery/Facts Analysis

00000 - Expenses

Expenses

Date Description Price Qty Amount

10-02-2017 Messenger service 20.80 1 20.80

10-13-2017 Process server to serve Subpoenas to UBS, BPPR, Santander and O&B 35.00 4 140.00

10-13-2017 Copies in house 0.10 123 12.30

10-19-2017 Process server to serve Subpoena to the Treasury Department 50.00 1 50.00

10-20-2017 Process server to serve Subpoena to the Department of Justuice 50.00 1 50.00

10-20-2017 Process server to serve Subpoena to the Treasury Department through 

the Department of Justuice

50.00 1 50.00

Total Expenses 323.10

00001 - Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

10-03-2017 NN Review Debtor's objection to Bondholder's Motion and Court 

Orders

0.300 112.50

10-03-2017 NN Review Motion re scheduling, Oversight Board's response and 

U.S. Motion for Extension

0.200 75.00

10-03-2017 NN Prepare for conference call re P.R. applicable law; Study 

relevant documents in preparation

0.900 337.50

10-03-2017 NN Confer with D. Bussel and J. Weiss re P.R. law 0.400 150.00

10-04-2017 NN Legal research re applicable PR law 4.600 1,725.00

10-04-2017 NN Draft analysis of Puerto Rico Law to respond to questions as to 

applicable law

1.700 637.50

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Date Timekeeper Description Hours Amount

10-05-2017 NN Email correspondence with D. Bussel re reduced operation of 

District Court in Puerto Rico due to hurricane

0.100 37.50

10-05-2017 NN Study Court dockets to identify any recent filings relevant to 

COFINA Agent

0.200 75.00

10-05-2017 NN Review Notice of Appearance of Syncore in adversary 

proceeding against COFINA Agent

0.100 37.50

10-05-2017 NN Confer with D. Bussel re new developments in Puerto Rico 

relevant to litigation

0.200 75.00

10-06-2017 NN Review Stipulation and Proposed Orders filed by Fiscal Agency 

in adversary proceeding against COFINA Agent

0.100 37.50

10-09-2017 NN Study Court docket to identify new Motions and Orders relevant 

to COFINA Agent

0.200 75.00

10-09-2017 NN Study various Motions and Court Orders 0.900 337.50

10-09-2017 NN Confer with A. Ambeault re pending matters 0.100 37.50

10-09-2017 NN Email correspondence with C. Koenig re Replies to be filed 0.200 75.00

10-09-2017 NN Study COFINA Agent's drafts of Reply to Agent's Motion re 

payment of fees and Reply in support of retention of Centerview

0.500 187.50

10-10-2017 NN Review final Replies filed on behalf of COFINA Agent 0.300 112.50

10-10-2017 NN Review Commonwealth Agent Motion in support to Motion of 

COFINA Agent

0.100 37.50

10-10-2017 NN Email correspondence with S. Silver re PR law 0.200 75.00

10-11-2017 NN Review COFINA Senior Bondholders Informative Motion re 

COFINA's Agent Motion

0.100 37.50

10-11-2017 NN Review Order approving Stipulation for exchange of confidential 

information filed by PR Fiscal Agency

0.100 37.50

10-12-2017 NN Review joinder of National Public Finance Committee to Motion 

of COFINA Bondholders re Motion of COFINA Agent

0.100 37.50

10-12-2017 NN Study Stipulation and proposed Order in interpleader action case 

and supporting documents re COFINA

1.200 450.00

10-13-2017 NN Analyze Order directing Debtor's to submit revised proposed 

Order re case management and various Motions and Stipulations

0.600 225.00

10-16-2017 NN Review Orders and Motions 0.200 75.00

10-17-2017 NN Study Court Dockets to identify recent Motions and Orders 

relevant to COFINA Agent

0.200 75.00

10-17-2017 NN Review Court Order re October 25 hearing 0.100 37.50

10-17-2017 NN Study Court Order scheduling hearing as to retention of local 

counsel for COFINA Agent and other issues

0.300 112.50

10-18-2017 NN Email correspondence with A. Yanez, D. Bussel and other cocounsel re October 25 hearing0.200 75.00

10-19-2017 NN Revise draft of Informative Motion re October 25 hearing 0.200 75.00

10-19-2017 NN Study Order denying application of COFINA Agent for retention 

of Financial Advisor

0.100 37.50

10-19-2017 NN Study dockets to identify any new filings relevant to COFINA 

Agent

0.100 37.50

10-19-2017 RR Email correspondence with A. Ambeault re October hearing 0.100 12.50

10-20-2017 NN Review statement of Committee of Unsecured Creditors in 

support of Motion for Order re disasters funds and related 

Motions, Objections and Orders

0.500 187.50

10-20-2017 NN Review various Informative Motions filed by Committee, 

Commonwealth Agent, COFINA Senior Bondholders and FOMB 

re October 25 hearing

0.400 150.00

10-20-2017 NN Review Statement of Official Committee of Retired Employees in 

support of Motion for Order re relief funds

0.100 37.50

10-20-2017 NN Review Informative Motion of COFINA Agent re October 25 

hearing

0.100 37.50

10-20-2017 NN Review Motions filed by Ambac, BNYM, AAFAA, Ad Hoc GO 

Group, ER and National re October 25 hearing

0.400 150.00

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Date Timekeeper Description Hours Amount

10-20-2017 NN Review Motion of USA re FEMA's Motion and various Motions re 

October 25 hearing

0.800 300.00

10-20-2017 NN Study Joint Statement of Commonwealth Agent and COFINA 

Agent in adversary proceeding and proposed Order

0.100 37.50

10-20-2017 NN Review corrected Joint Informative Motion of Commonwealth 

Agent and COFINA Agent and proposed Order

0.100 37.50

10-20-2017 NN Study Court Dockets to identify new filings relevant to COFINA 

Agent

0.100 37.50

10-23-2017 NN Email correspondence with C. Koenig re Amended Informative 

Motion of COFINA Agent as to October 25 hearing

0.100 37.50

10-23-2017 NN Review amended COFINA Agent's Motion re hearing 0.100 37.50

10-23-2017 NN Review Order denying Motion for Reconsideration 0.100 37.50

10-23-2017 NN Study AAFAF's Motion for leave to file Sur-reply and proposed 

Sur-reply

0.200 75.00

10-24-2017 NN Review various motions filed as to October 25 hearing 0.500 187.50

10-24-2017 NN Review Court Order granting leave to file Sur-reply 0.100 37.50

10-24-2017 NN Study Notice of Agenda for October 25 hearing 0.200 75.00

10-24-2017 NN Review various Court Orders approving Stipulations 0.100 37.50

10-24-2017 NN Study Order amending case management procedure and Third 

Amended Notice, Case Management and Administrative 

Procedure

0.400 150.00

10-24-2017 NN Review Urgent Motion of FGIC regarding proposed 90 day stay 

of all litigation

0.100 37.50

10-24-2017 NN Review Motion to be heard on November 15 hearing 0.100 37.50

10-25-2017 NN Review Joint Notice and Stipulation amending deadline 0.100 37.50

10-25-2017 NN Review various Motions and transcript requests 0.300 112.50

10-25-2017 NN Attend hearing re Urgent Motion as to disaster relief funds and 

hearing regarding COFINA Agent Motion confirming retention of 

local counsel and immunity

4.700 1,762.50

10-25-2017 NN Study Minutes of hearing 0.100 37.50

10-26-2017 NN Study Amended Complaint against COFINA Agent and compare 

to original Complaint

1.200 450.00

10-26-2017 NN Review Orders approving Stipulations and extending dates 0.200 75.00

10-26-2017 NN Review FOMB's Informative Motion regarding Amended 

Proposed Order as to relief and Amended Proposed Order

0.100 37.50

10-26-2017 NN Review Order regarding November 15 hearing 0.100 37.50

10-26-2017 NN Review Order granting FOMB's Urgent Motion 0.100 37.50

10-26-2017 NN Study draft of proposed Order approving COFINA's Agent 

Motion pursuant to Sec. 105 and draft of Motion in adversary 

proceeding regarding proposed amendments

0.300 112.50

10-27-2017 NN Review applications of Fee Examiner to retain counsel and local 

counsel and exhibits

0.300 112.50

10-27-2017 NN Review second Supplemental Verified Statement of COFINA 

Bondholder's coalition

0.100 37.50

10-28-2017 NN Study dockets to identify new filings relevant to COFINA Agent 0.100 37.50

10-28-2017 NN Review Notice of correspondence received by Court 0.100 37.50

10-30-2017 NN Review Urgent Informative Motion re statement made at hearing 

to COFINA Agent

0.100 37.50

10-30-2017 NN Study Court dockets to identify any new Motions and Orders 

relevant to COFINA Agent

0.100 37.50

10-30-2017 NN Review various Stipulations and Motions filed 0.200 75.00

10-30-2017 NN Review Court Order 0.100 37.50

10-31-2017 NN Email correspondence with co-counsel re draft of Answer to 

Complaint

0.100 37.50

10-31-2017 NN Study COFINA Agent's Answer and Counterclaim in adversary 

proceeding

0.800 300.00

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Date Timekeeper Description Hours Amount

10-31-2017 NN Study Court dockets to identify Motions and Orders relevant to 

COFINA Agent and review relevant Orders and Motions

0.200 75.00

10-31-2017 NN Study Joint Motion of Commonwealth submitting proposed 

Scheduling Order and draft Order in adversary proceeding 

against COFINA Agent

0.300 112.50

10-31-2017 NN Read various Orders, Stipulations and Motions 0.300 112.50

10-31-2017 NN Study Objection to Willkie Farr's First Fee Statement 0.300 112.50

10-31-2017 NN Review Court Order amending schedule in adversary proceeding 

against COFINA Agent

0.100 37.50

10-31-2017 NN Study emergency Motion of Fee Examiner to amend Interim 

Compensation Order and draft Order and Notice of request to be 

heard

0.400 150.00

Total Fees 11,337.50

Time Summary

Timekeeper Hours Rate Amount

NN 30.200 375.00 11,325.00

RR 0.100 125.00 12.50

Total Fees 11,337.50

00005 - Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

10-06-2017 RR Prepare Monthly Interim Fee Statement for September 2017 2.600 325.00

10-06-2017 NN Revise Detailed Fee Statement for September 2017 0.100 37.50

10-06-2017 NN Email correspondence with P. Shalhoub and D. Bussel re 

monthly invoice in LEDES format

0.200 75.00

10-09-2017 NN Email correspondence with J. Weiss and P. Shalhoub re Interim 

Application Fee

0.100 37.50

10-10-2017 NN Email correspondence with A. Ambeault re Interim Fee 

Application

0.300 112.50

10-10-2017 NN Confer with A. Cedeno and R. Rivera re Interim Application Fee 

and invoice in LEDES format

0.200 75.00

10-10-2017 RR Confer with A. Cedeno and N. Navarro re Interim Fee 

Application in LEDES format

0.200 25.00

10-11-2017 NN Email correspondence with N. Eite (UST) re Interim Fee 

Application

0.100 37.50

10-12-2017 NN Revise and finalize Monthly Fee Application 0.600 225.00

10-12-2017 RR Draft Monthly Fee Application and its exhibits 1.400 175.00

10-16-2017 NN Email correspondence with N. Eitel (UST) re LEDES format for 

First Monthly Fee Statement

0.100 37.50

10-27-2017 NN Email correspondence with A. Ambeault regarding Interim Fee 

Application

0.200 75.00

Total Fees 1,237.50

Time Summary

Timekeeper Hours Rate Amount

NN 1.900 375.00 712.50

RR 4.200 125.00 525.00

Total Fees 1,237.50

00006 - Fee Application Retention and Objections

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Professional Services

Date Timekeeper Description Hours Amount

10-26-2017 NN Email correspondence with A. Ambeault regarding No Objection 

Statement

0.100 37.50

10-26-2017 NN Email correspondence with J. Weiss and S. Pearson regarding 

No Objection Statement

0.100 37.50

10-31-2017 NN Draft No Objection Statement to September Monthly Statement 0.400 150.00

10-31-2017 NN Email correspondence with J. Weiss and S. Pearson regarding 

No Objection Statement

0.200 75.00

Total Fees 300.00

Time Summary

Timekeeper Hours Rate Amount

NN 0.800 375.00 300.00

Total Fees 300.00

00008 - Discovery/Facts Analysis

Professional Services

Date Timekeeper Description Hours Amount

10-03-2017 NN Review Motion on consent to adjourn PMA Motion to quash 

Subpoena

0.100 37.50

10-03-2017 NN Review Order re PMA Motion to Quash Subpoena 0.100 37.50

10-10-2017 NN Review non-party Hawkins Delafield response and objection to 

Subpoena from COFINA Agent

0.200 75.00

10-10-2017 NN Email correspondence with A. Ambeault re Subpoenas duces 

tecum

0.100 37.50

10-12-2017 NN Revise draft of Subpoena to O'Neill & Borges 0.300 112.50

10-12-2017 NN Draft email to A. Ambeault re Subpoenas 0.300 112.50

10-12-2017 NN Review Motion to Consent to further adjourn PMA's Motion to 

Quash Subpoena in adversary proceeding as to COFINA Agent 

and Order re Motion to Adjourn

0.200 75.00

10-12-2017 RR Confer with process server to inquire as to availability of Service 

in various sites after hurricane Maria

0.200 25.00

10-13-2017 RR Instruct process servers as to service of four Subpoenas Duces 

Tecum

0.100 12.50

10-13-2017 NN Email correspondence with J. Worthington re Subpoenas 0.200 75.00

10-13-2017 NN Revise Subpoena chart to include information as to Subpoenas 

served in PR

0.200 75.00

10-13-2017 NN Study served Subpoenas upon UBS, Popular Securities, 

Santander Securities and O'Neill & Borges to verify correction of 

information entered by process server

0.300 112.50

10-13-2017 RR Consolidate four Notices of Subpoenas with corresponding 

Subpoenas and exhibits to prepare for filing

1.300 162.50

10-13-2017 RR Enter required information in CM/ECF system to file four Notices 

of Subpoena and exhibits to O'Neil & Borges, Popular Securities 

UBS and Santander Securities

0.700 87.50

10-13-2017 NN Email correspondence with A. Gouzoules re Subpoenas to be 

served in PR

0.500 187.50

10-13-2017 NN Various telephone calls to Santander Securities and BPPR to 

coordinate serving of Subpoenas for document production

0.500 187.50

10-13-2017 NN Telephone calls to UBS to coordinate service of Subpoena 0.200 75.00

10-13-2017 NN Revise and finalize four Notices of Subpoena and Subpoenas to 

O'Neil & Borges, Popular Securities, UBS and Santander 

Securities

1.700 637.50

10-16-2017 NN Various calls and emails to inquire where and to whom to serve 0.800 300.00

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Date Timekeeper Description Hours Amount

Subpoenas to Dept. of Justice and Treasury Dept. after hurricane

10-16-2017 NN Email correspondence with A. Gouzoules re Subpoenas served 

upon UBS, Popular, Santander and O'Neill & Borges

0.200 75.00

10-17-2017 NN Email correspondence with A. Gouzoules re Subpoenas to 

Justice Department and to Treasury Department

0.100 37.50

10-18-2017 NN Email correspondence with A. Gouzoules re Subpoena to 

Treasury Department and to Justice Department

0.100 37.50

10-18-2017 NN Revise Notices of Subpoenas and exhibits to Secretary of 

Justice and Secretary of Treasury of PR

0.900 337.50

10-19-2017 NN Telephone call from process server re problems with serving 

Subpoena to Justice Department due to power outage

0.100 37.50

10-19-2017 NN Email correspondence with A. Gouzoules re pending Subpoenas 

and alternate procedure for service due to hurricane

0.500 187.50

10-19-2017 NN Finalize for service Subpoenas duces tecum to Secretary of 

Justice and to Secretary of Treasury

0.200 75.00

10-19-2017 NN Instruct process server as to service of Subpoenas in alternate 

locations

0.100 37.50

10-19-2017 RR Provide required information to CM/ECF system to file Notice 

Subpoena duces tecum to Secretary of Treasury

0.200 25.00

10-19-2017 RR Coordinate service of Subpoena to Department of Treasury 0.200 25.00

10-19-2017 NN Email correspondence with J. Worthington re Subpoena to 

Secretary of Treasury

0.100 37.50

10-19-2017 NN Update chart of Subpoenas to include information as to 

Subpoena served upon the Treasury Department

0.100 37.50

10-20-2017 NN Email correspondence with J. Worthington 0.100 37.50

10-20-2017 NN Coordinate service of Subpoena to Secretary of Justice in 

alternate site due to power outage

0.200 75.00

10-20-2017 NN Email correspondence with A. Gouzoules re service of 

Subpoena to Secretary of Justice

0.100 37.50

10-20-2017 NN Revise chart of Subpoena to include information as to Subpoena 

to Secretary of Justice

0.100 37.50

10-20-2017 RR Provide required information to CM/ECF system to file Notice of 

Subpoena to Secretary of Justice

0.200 25.00

10-24-2017 NN Review second Motion to consent to adjourn PMA's Motion in 

adversary proceeding against COFINA Agent and proposed 

Order

0.100 37.50

10-25-2017 NN Review Order further adjourning PMA's Motion to Quash 

Subpoena in adversary proceeding against COFINA Agent

0.100 37.50

10-25-2017 NN Email correspondence with M. Rohan (UBS counsel), A. 

Gouzoules and A. Yanez re Subpoena to UBS

0.500 187.50

10-26-2017 NN Revise chart of 3rd party Subpoenas to include new 

developments

0.300 112.50

10-26-2017 NN Email correspondence with A. Gouzoules regarding Amended 

Subpoena chart

0.100 37.50

10-26-2017 NN Study letter from O'Neill & Borges re objection to Subpoena 

duces tecum

0.100 37.50

10-26-2017 NN Email correspondence with A. Yanez, A. Gouzoules and J. 

Dugan re letter from O'Neill & Borges as to Subpoena

0.300 112.50

10-26-2017 NN Email correspondence with O'Neill & Borges regarding Subpoena 0.200 75.00

10-26-2017 NN Email correspondence with O'Neill & Borges, J. Dugan and A. 

Yanez to set up conference call to discuss Subpoena

0.200 75.00

10-27-2017 NN Study Santander's responses and objections to COFINA Agent's 

Subpoena

0.400 150.00

10-27-2017 NN Email correspondence with J. Dugan and A. Gouzoules 

regarding pending document production

0.200 75.00

10-30-2017 NN Confer with J. Dugan in preparation for conference call with 

O'Neill & Borges

0.100 37.50

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Date Timekeeper Description Hours Amount

10-30-2017 NN Conference call with M. Muñiz and E. Nieves (O'Neill & Borges) 

and J. Dugan re Subpoena

0.300 112.50

10-30-2017 NN Email correspondence with J. Dugan re pending Subpoenas 0.100 37.50

10-30-2017 NN Review Urgent Motion of Committee of Unsecured Creditors 

requesting authorization to pursue discovery

0.200 75.00

Total Fees 4,787.50

Time Summary

Timekeeper Hours Rate Amount

NN 11.800 375.00 4,425.00

RR 2.900 125.00 362.50

Total Fees 4,787.50

Total for this Invoice 17,985.60

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(Itemized expenses for the period of October 1, 2017 through October 31, 2017)

Date Expense Amount Description

10/02/17 Messenger $20.80 Messenger Service

10/13/17 Process server $140.00 Process server to serve Subpoenas to UBS, 

BPPR, Santander and O&B

10/13/17 Copies $12.30 123 in house copies 

10/19/17 Process server $50.00 Process server to serve Subpoena to the 

Treasury Department

10/20/17 Process server $50.00 Process server to serve Subpoena to the 

Department of Justice

10/20/17 Process server $50.00 Process server to serve Subpoena to the 

Treasury Department through the 

Department of Justice

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EXHIBIT 4-B

TIME AND EXPENSE DETAIL FOR THE NOVEMBER 2017 FEE STATEMENT

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Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

12-14-2017

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 17113063

Invoice Period: 11-01-2017 - 11-30-2017

RE: Multiple Matters

00000 - Expenses

00001 - Litigation/Adversary Proceeding

00003 - Meetings/Creditor Communications

00004 - Mediation

00005 - Fee Application and Retention

00006 - Fee Application Retention and Objections

00007 - Budget

00008 - Discovery/Facts Analysis

00000 - Expenses

Expenses

Date Description Price Qty Amount

11-30-2017 Copies in house 0.10 205 20.50

Total Expenses 20.50

00001 - Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

11-01-2017 NN Study COFINA Agent's motion submitting proposed Order and 

proposed Order 1557

0.100 37.50

11-01-2017 NN Correspond with A. Yanes and C. Koenig re pending matters 0.100 37.50

11-01-2017 NN Correspond with co-counsel re December 20 hearing 0.200 75.00

11-02-2017 NN Review Santander's Motion re November 15th hearing 0.100 37.50

11-02-2017 NN Study various litigation updates sent by D. Bussel 0.400 150.00

11-03-2017 NN Read Court Order granting COFINA Agent's motion re immunity 

and confirming retention of local counsel

0.100 37.50

11-03-2017 NN Study update reports sent by Willkie Farr 0.200 75.00

11-03-2017 NN Read Objection to Aurelious Motion to Dismiss 0.200 75.00

11-03-2017 NN Read Response to Urgent Motion of Oversight Board for Order 0.100 37.50

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Date Timekeeper Description Hours Amount

confirming Chief Transformation Agent

11-03-2017 NN Analyze COFINA Senior Bondholders' draft Answer to Complaint 

against COFINA Agent

0.600 225.00

11-03-2017 NN Read FOMB's Opposition to Motion to Dismiss 0.200 75.00

11-03-2017 NN Study various Oppositions to Motion to Dismiss filed by 

Unsecured Creditors Committee, COFINA Senior Bondholders 

and AAFAF

0.800 300.00

11-03-2017 NN Read Court Order re Urgent motion of Fee Examiner 0.100 37.50

11-04-2017 NN Study Commonwealth Agent's answers and defenses to 

COFINA Agent's Amended Counterclaim

0.300 112.50

11-04-2017 NN Correspond with S. Hussein re draft of Opposition to scope 

motion

No Charge

11-06-2017 NN Analyze update reports sent by Willkie Farr 0.300 112.50

11-06-2017 NN Review draft Answer and Counterclaim for COFINA Subordinate 

Bondholders

0.200 75.00

11-06-2017 NN Review Notice re US participation to defend PROMESA 0.100 37.50

11-06-2017 NN Read various Notices of Intervention filed in adversary 

proceeding against COFINA Agent

0.300 112.50

11-06-2017 NN Read Mutual Fund Group's and PR Fund's Answer to 

Counterclaim in adversary proceeding against COFINA Agent

0.200 75.00

11-06-2017 NN Read COFINA Senior Bondholders Motion to Intervene and 

Answer and Counterclaim in adversary proceeding against 

COFINA Agent

0.300 112.50

11-06-2017 NN Review Motions to Intervene filed by Ambac, National Public 

Finance and Hoc Group

0.100 37.50

11-06-2017 NN Study Ambac's Answer to Amended Complaint and 

Counterclaim against Commonwealth Agent

0.300 112.50

11-06-2017 NN Study Fee Examiner's proposed amended Order for Interim 

Compensation

0.100 37.50

11-07-2017 NN Read various motions re upcoming hearings to analyze scope of 

issues before the Court relevant to COFINA Agent

0.600 225.00

11-07-2017 NN Study Ad Hoc Group Go Bondholders' Answer in Intervention 

and Counterclaim against COFINA Agent

0.400 150.00

11-07-2017 NN Study Court Dockets to identify Motions and Orders relevant to 

COFINA Agent

0.200 75.00

11-08-2017 NN Weekly conference call with B. Whyte and co-counsel re strategy 0.700 262.50

11-08-2017 NN Analyze update as to new developments sent by Willkie Farr 0.600 225.00

11-08-2017 NN Analyze charts comparing defenses and claims of various 

interventors in adversary proceeding against COFINA Agent

0.500 187.50

11-08-2017 NN Read various motions re Omnibus Hearing 0.400 150.00

11-08-2017 NN Read, analyze and compare various Motions for Summary 

Judgment and Statements of Undisputed Facts filed by COFINA 

Senior Bondholders, Mutual Fund Group, BNYM, Ambac and 

Assured Guaranty in Adversary Proceeding against COFINA

2.900 1,087.50

11-09-2017 NN Read Court Order re upcoming hearings 0.100 37.50

11-09-2017 NN Study update sent by Willkie Farr re new developments 0.100 37.50

11-10-2017 NN Read email from B. Whyte re new developments 0.100 37.50

11-11-2017 NN Study Agenda for November 13 hearing and Court Order re 

hearing

0.200 75.00

11-13-2017 NN Correspond with B. Whyte and co-counsel re November 13 

hearing and new developments in PR

0.400 150.00

11-13-2017 NN Attend hearing in San Juan 3.400 1,275.00

11-13-2017 NN Read summary of hearing 0.100 37.50

11-13-2017 NN Read various motions re hearing 0.200 75.00

11-14-2017 NN Read update of recent developments sent by Willkie Farr 0.100 37.50

11-14-2017 NN Analyze QTCB Noteholder Group's Motion to Strike or Dismiss 0.200 75.00

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Date Timekeeper Description Hours Amount

8th cause of action of COFINA Agent's Complaint

11-14-2017 NN Analyze AAFAF's Motion to Dismiss 0.300 112.50

11-14-2017 NN Analyze Ambac's Motion to Strike claims of Commonwealth 

agent

0.200 75.00

11-14-2017 NN Analyze Ad Hoc Group of GO Bondholders' Motion to Dismiss 0.200 75.00

11-14-2017 NN Analyze UCC Joinder to Scope Motion 0.200 75.00

11-14-2017 NN Analyze FOMB's motion 0.300 112.50

11-14-2017 NN Study Court dockets to identify new motions relevant to COFINA 

Agent

0.200 75.00

11-14-2017 NN Review order requesting status report 0.100 37.50

11-14-2017 NN Study agenda for November 15 hearing 0.200 75.00

11-15-2017 NN Review Amended Agenda for hearing 0.100 37.50

11-15-2017 NN Attend Omnibus hearing 5.800 2,175.00

11-15-2017 NN Correspond with B. Whyte and co-counsel re new developments 0.200 75.00

11-15-2017 NN Analyze draft of Answer to GO Bondholder intervention 

Complaint

0.200 75.00

11-15-2017 NN Analyze draft of Response to Intervention by Retiree Committee 0.200 75.00

11-15-2017 NN Study Court Dockets to identify new filings relevant to COFINA 

Agent

0.100 37.50

11-15-2017 NN Read C Koenig email re Nov 15 hearing 0.100 37.50

11-16-2017 NN Read written remarks of Judge Housser re mediation 0.100 37.50

11-16-2017 NN Review Bennazar's Interim Fee Application 0.200 75.00

11-16-2017 NN Read Court Order denying Motion to Stay proceedings 0.100 37.50

11-16-2017 NN Read Court Minutes of November 15 hearing 0.100 37.50

11-16-2017 NN Correspond with B. Whyte re new developments in PR 0.200 75.00

11-16-2017 NN Analyze various motions and Orders in adversary proceeding 

against COFINA

0.300 112.50

11-17-2017 NN Study case updates sent by Willkie Farr 0.200 75.00

11-17-2017 NN Read Court Order re scope motions 0.100 37.50

11-17-2017 NN Analyze Court Opinion and Order denying FOMB's Urgent 

Motion to confirm appointment of CTO

0.300 112.50

11-17-2017 NN Correspond with S. Hussein re drafts of Responses to 

Interventions

0.100 37.50

11-17-2017 NN Weekly conference call with B. Whyte and co-counsel 0.500 187.50

11-17-2017 NN Read Reply in support of Aurelious Motion to Dismiss 0.100 37.50

11-20-2017 NN Read case update report sent by Willkie Farr 0.100 37.50

11-20-2017 NN Read Standing Order re separation of mediation and litigation 0.100 37.50

11-20-2017 NN Review revised draft of Responses to GO Bondholders 

intervention

0.100 37.50

11-20-2017 NN Correspond with S. Hussein re draft of Responses to GO 

Bondholder intervention

0.100 37.50

11-20-2017 NN Read Judge Housser's Notice re breach of mediation 

confidentiality

0.100 37.50

11-20-2017 NN Correspond with B. Whyte re new developments 0.100 37.50

11-20-2017 NN Read Order approving Stipulation to extend Stipulation as to 

production and exchange of confidential information to 

intervenors in adversary proceeding against COFINA Agent

0.100 37.50

11-21-2017 NN Review COFINA Agent's Response to intervention of Retiree 

Committee as filed

0.100 37.50

11-21-2017 NN Review COFINA Agent's Answer and Defenses to Ad Hoc Group 

of GO Bondholders intervention as filed

0.200 75.00

11-21-2017 NN Correspond with S. Pearson re travel arrangements for 

December 20 hearing

0.100 37.50

11-21-2017 NN Read case update sent by Willkie Farr 0.100 37.50

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Date Timekeeper Description Hours Amount

11-21-2017 NN Read Commonwealth Agent's reservation of rights to Ambac 0.100 37.50

11-21-2017 NN Read Commonwealth Agent's Answer to the Complaints filed by 

Public Finance Guarantee Corp., Mutual Fund Group and 

COFINA Senior Bondholders coalition

0.400 150.00

11-21-2017 NN Read Fee Examiner's amended Order authorizing employment 

of counsel

0.100 37.50

11-21-2017 NN Correspond with co-counsel re weekly conference call 0.100 37.50

11-22-2017 NN Correspond with S. Hussein re issues regarding PR Law 0.500 187.50

11-22-2017 NN Legal research and analysis of PR Law relevant to GO-COFINA 

dispute

1.400 525.00

11-22-2017 NN Read Court Order appointing new Judge to Mediation Team 0.200 75.00

11-27-2017 NN Study Court Dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

11-27-2017 NN Read Order granting AAFAF Motion to Intervene in adversary 

proceeding against COFINA Agent

0.100 37.50

11-28-2017 NN Read Court Order 0.100 37.50

11-28-2017 NN Legal research and study of PR Supreme Court cases to 

respond to questions re PR Law relevant to GO-COFINA dispute

4.600 1,725.00

11-28-2017 NN Review Willkie Farr's draft of Urgent Motion seeking payment 0.200 75.00

11-28-2017 NN Correspond with C. Koenig re Local Rules 0.200 75.00

11-29-2017 NN Study Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

11-29-2017 NN Read Court Order re December 14 hearing 0.100 37.50

11-29-2017 NN Read update sent by Willkie Farr 0.100 37.50

11-29-2017 NN Read Mutual Fund Group's Answer to GO Group Complaint and 

Answer to cross claim of COFINA Senior Bondholders in 

adversary proceeding against COFINA Agent

0.300 112.50

11-30-2017 NN Read Urgent Motion filed by Commonwealth for extension of 

deadlines

0.100 37.50

11-30-2017 NN Read Supplemental Certification of Bennazar in support of 

application for compensation

0.100 37.50

11-30-2017 NN Read Court Order granting Urgent Motion for extension of 

deadlines

0.100 37.50

11-30-2017 NN Read Commonwealth Agent's Informative Motion re hearing on 

December 5 as to Motion to Dismiss GO's complaint in 

adversary proceeding filed by Aurelious against Commonwealth 

and FOMB

0.100 37.50

11-30-2017 NN Correspond with B. Whyte and co-counsel re December 20 

hearing

0.300 112.50

11-30-2017 NN Study Ad Hoc Group of GO Bondholders' response to COFINA 

Agent's Counterclaim

0.800 300.00

Total Fees 14,587.50

Time Summary

Timekeeper Hours Rate Amount

NN 38.900 375.00 14,587.50

Total Fees 14,587.50

00003 - Meetings/Creditor Communications

Professional Services

Date Timekeeper Description Hours Amount

11-02-2017 NN Correspond with R. Escalera (COFINA bondholders counsel) 0.100 37.50

11-03-2017 NN Confer with R. Escalera (local counsel for Senior COFINA 

Bondholders) re recent developments

0.200 75.00

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Date Timekeeper Description Hours Amount

11-08-2017 NN Confer with M. Fernández (local counsel for Mutual Fund Group) 

re new developments

0.400 150.00

11-13-2017 NN Confer with M. Fernández, local counsel for Mutual Fund Group 

re hearings

0.300 112.50

Total Fees 375.00

Time Summary

Timekeeper Hours Rate Amount

NN 1.000 375.00 375.00

Total Fees 375.00

00004 - Mediation

Professional Services

Date Timekeeper Description Hours Amount

11-01-2017 NN Correspond with D. Bussel re mediation 0.100 37.50

11-02-2017 NN Confer with D. Bussel re strategy and pending matters 0.500 187.50

11-02-2017 NN Email correspondence with D. Bussel and B. Whyte re new 

developments

0.200 75.00

11-02-2017 NN Correspond with C. Koenig re mediation update 0.100 37.50

11-02-2017 NN Study recent mediation updates 0.200 75.00

11-04-2017 NN Read news reports sent by B. Whyte re developments in PR 0.200 75.00

11-04-2017 NN Correspond with D. Bussel 0.100 37.50

11-05-2017 NN Read report sent by B. Whyte as to recent developments with 

FOMB

0.200 75.00

11-06-2017 NN Email correspondence with D. Bussel re new developments 0.100 37.50

11-07-2017 NN Correspond with B. Whyte re recent developments in Puerto 

Rico

0.400 150.00

11-07-2017 NN Read Memorandum with update re mediation and C. Koenig's 

email

0.200 75.00

11-07-2017 NN Attend (via webcast) at COFINA Agent's request, the House 

Committee of Natural Resources hearing re FOMB's role in PR 

recovery

3.700 1,387.50

11-07-2017 NN Draft Memorandum with summary and notes as to House 

Committee Resource hearing in PR for FOMB and recovery

2.900 1,087.50

11-07-2017 NN Confer with D. Bussel re new developments and strategy 0.500 187.50

11-07-2017 NN Correspond with co-counsel re update as to Creditors 0.200 75.00

11-07-2017 NN Correspond with D. Bussel renew developments 0.200 75.00

11-07-2017 RR Verify information needed for summary of House Committee of 

National Resources hearing

0.700 87.50

11-07-2017 NN Read Order re mediation 0.100 37.50

11-08-2017 NN Correspond with B. Whyte re National Resources Committee 

hearing in PR

0.100 37.50

11-08-2017 NN Review SUT analysis in preparation for weekly call 0.200 75.00

11-08-2017 NN Correspond with B. Whyte and co-counsel re SUT 0.200 75.00

11-08-2017 NN Research as to bill submitted by Governor re SUT in October to 

asses GO-COFINA dispute

0.500 187.50

11-08-2017 NN Observe Governor's press conference re SUT 0.800 300.00

11-09-2017 NN Analyze summary of Fiscal Plan Creditors session and slide deck 0.200 75.00

11-14-2017 RR Obtain information required for summary of National Resources 

Committee hearing

0.500 62.50

11-14-2017 NN Review information sent by B. Whyte re new developments in PR 0.100 37.50

11-14-2017 NN Attend via web cast the National Resources Committee hearing 

re need for transparent financial accountability in PR, at the 

3.300 1,237.50

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Date Timekeeper Description Hours Amount

request of the COFINA Agent

11-14-2017 NN Draft Memorandum with notes, comments and analysis as to 

National Resources Committee hearing

1.800 675.00

11-14-2017 NN Read summary of FOMB Creditor's session 0.100 37.50

11-14-2017 NN Review written testimony of Governor Roselló and PREPA's 

Director before Senate Committee and summary of hearing

0.300 112.50

11-20-2017 NN Analyze Memorandum re revised fiscal plan 0.200 75.00

11-20-2017 NN Conference call with B. Whyte and co-counsel re new 

developments

0.500 187.50

11-21-2017 NN Read update sent by B. Whyte re mediation 0.100 37.50

11-22-2017 NN Read article re PR sent by B. Whyte re new developments in PR 0.100 37.50

11-27-2017 NN Correspond with B. Whyte as to FOMB session in PR 0.100 37.50

11-27-2017 AC Confer with N. Navarro re FOMB session and case background 

in preparation to attend FOMB session in PR

0.400 100.00

11-28-2017 AC Register to attend FOMB's hearing in Puerto Rico and confer to 

confirm space

0.200 50.00

11-28-2017 NN Confer with A. Charles re FOMB session and case background 0.400 150.00

11-29-2017 NN Read news report sent by B. Whyte 0.100 37.50

11-29-2017 NN Review SUT collection tracker report 0.100 37.50

11-29-2017 AC Review court docket and study relevant pleadings and 

documents to familiarize with issues relevant to COFINA Agent 

in preparation to attend FOMB's hearing in PR and assist in 

cases

2.400 600.00

11-30-2017 AC Attend morning session and afternoon session of FOMB hearing 

in PR at COFINA Agent's request

7.800 1,950.00

11-30-2017 AC Draft Memorandum summarizing the various panels in the 

FOMB sessions in PR

3.300 825.00

11-30-2017 AC Confer with N. Navarro re FOMB hearing and Memorandum re 

same

0.300 75.00

11-30-2017 NN Review AAFAF Fiscal Year 2018 Cash Flow sent by B. Whyte 0.200 75.00

11-30-2017 NN Confer with A. Charles re session held by FOMB in Puerto Rico 

and information needed to be covered in memorandum

0.300 112.50

11-30-2017 NN Read and revise draft of memorandum from A. Charles re FOMB 

session and confer with Charles re draft

0.300 112.50

11-30-2017 NN Correspond with B. Whyte and co-counsel re FOMB hearing in 

PR

0.100 37.50

Total Fees 11,250.00

Time Summary

Timekeeper Hours Rate Amount

AC 14.400 250.00 3,600.00

NN 20.000 375.00 7,500.00

RR 1.200 125.00 150.00

Total Fees 11,250.00

00005 - Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

11-04-2017 NN Correspond with J. Weiss re Interim Fee Application 0.200 75.00

11-08-2017 RR Prepare October Monthly Fee Statement 1.600 200.00

11-08-2017 RR Work on Monthly Fee Statement 0.700 87.50

11-09-2017 NN Study First Amended Order setting procedures re Interim 

Compensation

0.200 75.00

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Date Timekeeper Description Hours Amount

11-09-2017 NN Correspond with S. Pearson re monthly fee statements 0.100 37.50

11-13-2017 NN Correspond with J. Weiss re monthly fee statement 0.100 37.50

11-13-2017 NN Revise October fee statement 0.500 187.50

11-13-2017 RR Work on October fee statement 1.300 162.50

11-16-2017 NN Correspond with J. Weiss re fee application 0.300 112.50

11-28-2017 NN Correspond with D. Bussel re possible motion as to unpaid fees 0.100 37.50

Total Fees 1,012.50

Time Summary

Timekeeper Hours Rate Amount

NN 1.500 375.00 562.50

RR 3.600 125.00 450.00

Total Fees 1,012.50

00006 - Fee Application Retention and Objections

Professional Services

Date Timekeeper Description Hours Amount

11-21-2017 RR Prepare Statement of No Objection as to October Fee Statement 0.400 50.00

11-21-2017 NN Revise and finalize Statement of No Objection as to October fee 

statement

0.200 75.00

11-21-2017 NN Correspond with J. Weiss re Statement of No Objection 0.200 75.00

11-28-2017 NN Read Email correspondence with from S. Pearson notifying No 

Objection Statements

0.300 112.50

11-29-2017 NN Correspond with B. Whyte and co-counsel re pending fee 

statements

0.500 187.50

Total Fees 500.00

Time Summary

Timekeeper Hours Rate Amount

NN 1.200 375.00 450.00

RR 0.400 125.00 50.00

Total Fees 500.00

00007 - Budget

Professional Services

Date Timekeeper Description Hours Amount

11-01-2017 NN Correspond with co-counsel re budget 0.200 75.00

11-04-2017 NN Prepare budgets requested by COFINA 1.000 375.00

11-04-2017 NN Correspond with S. Hussein re requested budget 0.200 75.00

11-20-2017 NN Correspond with J. Weiss re budgeting 0.200 75.00

11-20-2017 NN Confer with J. Weiss and S. Pearson re budgeting 0.100 37.50

Total Fees 637.50

Time Summary

Timekeeper Hours Rate Amount

NN 1.700 375.00 637.50

Total Fees 637.50

00008 - Discovery/Facts Analysis

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Professional Services

Date Timekeeper Description Hours Amount

11-01-2017 NN Correspond with A. Gouzoules re pending responses to 

Subpoenas served in PR

0.100 37.50

11-02-2017 NN Correspond with S. Hussein and J. Rivera Font (counsel for 

Santander) re Santander's objections to Subpoena for 

production of documents

0.500 187.50

11-02-2017 NN Telephone conference with J. Daniels (counsel for AAFAF) re 

production of documents from the PR Treasury Department

0.100 37.50

11-02-2017 NN Correspond with J. Daniels (AAFAF) re response to Subpoena 0.200 75.00

11-02-2017 NN Read Unsecured Creditors Objection to Urgent Motion of FGIC 

for 90 day stay and limited joinder to motion authorizing 

discovery

0.200 75.00

11-02-2017 NN Correspond with J. Daniels (AAFAF) re response to Subpoena 

served by COFINA Agent and PR Treasury Department

0.200 75.00

11-02-2017 NN Read Court Order granting in part and denying in part motion to 

conduct examination of GDB

0.100 37.50

11-03-2017 NN Read Debtor's motion in support of objections to discovery and 

Omnibus status report re discovery

0.200 75.00

11-03-2017 NN Preliminary review of Department of Justice's Response to 

Subpoena for production of documents

0.100 37.50

11-04-2017 NN Read Limited Joinder of Committee of Unsecured Creditors to 

Ambac's Motion re discovery re SUT

0.100 37.50

11-04-2017 NN Read Limited Joinder of Committee of Unsecured Creditors to 

Urgent Renewed Motion by Ad Hoc Group of GA Bondholders 

and others authorizing examination

0.100 37.50

11-04-2017 NN Analyze UBS' Responses and Objections to Subpoena Duces 

Tecum

0.500 187.50

11-04-2017 NN Correspond with UBS re responses to Subpoenas 0.100 37.50

11-04-2017 NN Analyze PR DOJ's Responses and Objections to Subpoenas 

Duces Tecum

0.800 300.00

11-04-2017 NN Correspond with S. Hussein re UBS' and the DOJ's respective 

Responses and Objection to Subpoenas

0.400 150.00

11-06-2017 NN Correspond with S. Hussein and A. Gouzoules re responses to 

Subpoenas served in PR

0.500 187.50

11-06-2017 NN Prepare for conference call to discuss various responses to 

Subpoenas served in PR

0.300 112.50

11-06-2017 NN Confer with A. Gouzoules and J. Dugan re DOJ's response to 

Subpoena for production of documents from various third parties 

in PR

0.300 112.50

11-06-2017 NN Correspond with M. Rohan (UBS) re UBS's response to 

Subpoena for production of documents

0.200 75.00

11-06-2017 NN Correspond with S. Hussein and M. Muñoz (O'Neill & Borges) re 

O&B's response to Subpoena

0.200 75.00

11-06-2017 NN Analyze PR Treasury Department's responses and objections to 

Subpoena for production of documents

1.200 450.00

11-07-2017 NN Correspond with M. Muñiz re Subpoena to O'Neill & Borges 0.100 37.50

11-07-2017 NN Confer with counsel for Santander, J. Dugan and S. Hussein re 

Santander's responses to Subpoena

0.200 75.00

11-07-2017 NN Correspond with J. Dugan and S. Hussein re Treasury 

Department's responses to Subpoena for production of 

documents

0.200 75.00

11-07-2017 NN Correspond with J. Haysworth (Santander) re Santander's 

responses to Subpoena for production of documents

0.200 75.00

11-07-2017 NN Read various discovery motions 0.300 112.50

11-08-2017 NN Correspond with M. Rohan (UBS) re UBS' responses and 

objections to Subpoena for production of documents

0.200 75.00

11-08-2017 NN Correspond with J. Dugan and A. Gouzoules re Subpoena for 0.200 75.00

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Date Timekeeper Description Hours Amount

production of documents to Santander

11-08-2017 NN Study Third Party Subpoena chart prepared by KTBS 0.100 37.50

11-08-2017 NN Analyze Subpoena duces tecum from Commonwealth Agent to 

UBS in preparation for conference call with UBS

0.200 75.00

11-08-2017 NN Confer with M. Muñiz (O'Neill & Borges), S. Hussein and J. 

Dugan re O'Neill & Borges responses to Objections to Subpoena 

for production of documents

0.200 75.00

11-08-2017 NN Correspond with J. Hayworth and co-counsel re search terms for 

Santander responses to Subpoena for production of documents

0.100 37.50

11-08-2017 NN Correspond with M. Muñiz re O'Neill & Borges' responses and 

objections to Subpoena fro production of documents

0.300 112.50

11-09-2017 NN Email correspondence with M. Muñiz (O'Neill & Borges) re 

O'Neill & Borges responses to Subpoena

0.100 37.50

11-09-2017 NN Prepare for meet and confer with UBS re Subpoena for 

production of documents

0.200 75.00

11-09-2017 NN Meet and confer with counsel for UBS re response and objection 

to Subpoena

0.200 75.00

11-13-2017 NN Correspond with S. Hussein re UBS Subpoena for production of 

documents

0.100 37.50

11-14-2017 NN Correspond with co-counsel re UBS' responses to subpoena 0.500 187.50

11-14-2017 NN Confer with counsel for UBS re Responses and Objections to 

COFINA Agent's Subpoena

0.200 75.00

11-15-2017 NN Correspond with J. Weiss re UBS' Responses and Objections to 

Subpoena for document production

0.100 37.50

11-16-2017 NN Correspond with UBS counsel re Subpoena 0.100 37.50

11-16-2017 NN Confer with counsel for UBS and J. Weiss re UBS' Responses to 

Subpoena for document production

0.200 75.00

11-16-2017 NN Draft letter to counsel for UBS re UBS' Objection and Responses 

to Subpoena

0.500 187.50

11-17-2017 NN Correspond with S. Hussein re PR Treasury Department's 

Responses and Objections to Subpoena for production of 

documents

0.300 112.50

11-17-2017 NN Correspond with J. Weiss re letter to UBS as to Responses and 

Objections to Subpoena for production of documents

0.200 75.00

11-17-2017 NN Read Court Order re discovery Motions 0.100 37.50

11-17-2017 NN Revise and finalize letter to UBS counsel re Responses and 

Objections to Subpoena for production of documents

0.300 112.50

11-17-2017 NN Correspond with counsel for PR Treasury Department re 

Responses and Objections to Subpoena for production of 

documents

0.100 37.50

11-17-2017 NN Read Stipulation re extending Stipulation as to production and 

exchange of confidential information to intervenors in adversary 

proceeding against COFINA Agent

0.100 37.50

11-21-2017 NN Correspond with counsel for PR Treasury Department as to 

Responses and Objections to the Subpoena served by the 

COFINA Agent

0.800 300.00

11-21-2017 NN Confer with Justine Daniels (O'Melveny), counsel for the PR 

Treasury Department, 

 to coordinate meet and confer re Objections to Subpoena

0.100 37.50

11-28-2017 NN Correspond with counsel for PR Treasury Department re 

Subpoena for production of documents

0.200 75.00

11-28-2017 NN Prepare for meet and confer with Treasury Department re 

Responses and Objections to COFINA Agent's Subpoena for 

production of documents

0.300 112.50

11-28-2017 NN Confer with J. Daniels, N. Villavicencio (PR Treasury 

Department) and J. Dugan re Responses and Objections to 

COFINA Agent's Subpoena for production of documents

0.400 150.00

11-29-2017 NN Read third motion to further adjourn PMA's Motion to Quash 0.100 37.50

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Date Timekeeper Description Hours Amount

Subpoena in adversary proceeding against COFINA Agent

11-29-2017 NN Read Urgent renewed motion of GO Bondholders, AMBAC and 

others to compel Commonwealth, the Board and AAFAF to 

produce documents and exhibits

0.200 75.00

11-29-2017 NN Read Ambac's Motion for order to take discovery from FOMB, 

AAFAF, the Commonwealth and COFINA re SUT

0.200 75.00

11-30-2017 NN Read proposed Order filed by Siemens re deposition of 

corporate designee of GDB

0.100 37.50

11-30-2017 NN Read S. Hussein email confirming agreement reached at meet 

and confer with PR Treasury Department

0.100 37.50

11-30-2017 NN Read email from J. Heyworth (counsel for Santander Securities) 

re Santander's response to COFINA Agent's Subpoena for 

production of documents

0.100 37.50

Total Fees 5,475.00

Time Summary

Timekeeper Hours Rate Amount

NN 14.600 375.00 5,475.00

Total Fees 5,475.00

Total for this Invoice 33,858.00

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(Itemized expenses for the period of November 1, 2017 through November 30, 2017)

Date Expense Amount Description

11/30/17 Copies $20.50 205 in house copies

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EXHIBIT 4-C

TIME AND EXPENSE DETAIL FOR THE DECEMBER 2017 FEE STATEMENT

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We appreciate your business Page 1 of

10

Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

01-03-2018

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 17123163

Invoice Period: 12-01-2017 - 12-31-2017

RE: Multiple Matters

00000 - Expenses

00001 - Litigation/Adversary Proceeding

00004 - Mediation

00005 - Fee Application and Retention

00006 - Fee Application Retention and Objections

00007 - Budget

00008 - Discovery/Facts Analysis

00000 - Expenses

Expenses

Date Description Price Qty Amount

12-29-2017 Copies in house 0.10 238 23.80

Total Expenses 23.80

00001 - Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

12-01-2017 NN Correspond with S. Hussein re draft of Opposition to Scope 

Motions in adversary proceeding against COFINA Agent

0.200 75.00

12-01-2017 NN Analyze draft of Opposition to Scope Motions in adversary 

proceeding against COFINA Agent

1.200 450.00

12-01-2017 NN Correspond with co-counsel re December 20 hearing 0.200 75.00

12-01-2017 NN Read Court Order re December 20 hearing 0.100 37.50

12-01-2017 NN Read Court Order granting in part and denying in part motion to 

conduct examination of GDB

0.100 37.50

12-04-2017 NN Correspond with S. Hussein re draft of Opposition to Scope 

motion

0.200 75.00

12-05-2017 NN Study COFINA Senior Bondholders' Omnibus Opposition to 

Scope Motions and Appendix A

0.600 225.00

12-05-2017 NN Commence drafting Memorandum re PR law responding to co- 1.200 450.00

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Date Timekeeper Description Hours Amount

counsel's questions

12-05-2017 NN Review COFINA Agent's Opposition to Scope Motion as filed 0.300 112.50

12-05-2017 NN Study National Public Finance Guarantee Corp.'s Opposition to 

Scope motions

0.200 75.00

12-05-2017 NN Read Joinder of Assured Guaranty to QTCB Noteholder's Motion 

to Dismiss 8th cause of action of COFINA Agent's Counterclaim

0.100 37.50

12-05-2017 NN Study Ambac's Omnibus Objection to Scope motions 0.300 112.50

12-05-2017 NN Study Mutual Fund Group's Objection to Scope Motion 0.100 37.50

12-05-2017 NN Study Commonwealth Agent's Objection to Scope Motions re 

claims of Commonwealth Agent

0.300 112.50

12-05-2017 NN Legal research re PR Law to respond to co-counsel questions 

and study applicable case law of PR Supreme Court relevant to 

GO-COFINA dispute

2.300 862.50

12-05-2017 NN Correspond with S. Hussein re legal research as to PR law 0.100 37.50

12-06-2017 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

12-06-2017 NN Conclude drafting Memorandum as to PR law, analyzing case 

law of Supreme Court of PR in response to questions relevant to 

GO-COFINA dispute

4.400 1,650.00

12-06-2017 NN Correspond with S. Hussein re PR law 0.100 37.50

12-06-2017 NN Study US Memorandum of law in support of Constitutionality of 

PROMESA

0.300 112.50

12-07-2017 NN Study update of Title III cases status report sent by WF&G 0.100 37.50

12-08-2017 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

12-08-2017 NN Read FGIC Motion re December 14 hearing 0.200 75.00

12-08-2017 NN Read Retiree Committee motion re December 14 hearing 0.100 37.50

12-08-2017 NN Analyze FOMB's Response to Motion for Summary Judgment in 

adversary proceeding against COFINA

0.200 75.00

12-08-2017 NN Read case update sent by WF&G 0.200 75.00

12-09-2017 NN Read ERS Secured Creditors' Informative Motion re December 

14 hearing

0.100 37.50

12-10-2017 NN Read Ad Hoc Group of Go Bondholder's Motion re December 14 

hearing

0.100 37.50

12-11-2017 NN Read multiples motions as to the December 14 hearing to asses 

issues to be presented at hearing relevant to the COFINA Agent

0.600 225.00

12-11-2017 NN Analyze Omnibus Reply of Interventor QTCB Noteholder Group 

to objections of COFINA Agent to Motion to Dismiss certain 

causes of action in adversary proceeding against COFINA Agent

0.200 75.00

12-11-2017 NN Analyze FOMB's Reply re Scope Motions in adversary 

proceeding against COFINA Agent and chart re scope motion 

attached to Reply

0.300 112.50

12-11-2017 NN Read case update sent by WF&G re summary judgment dispute 

in adversary proceeding

0.200 75.00

12-11-2017 NN Read email from C. Koenig re Oversight Board's Reply to 

Opposition or scope Motion

0.100 37.50

12-12-2017 NN Read Omnibus Reply of Commonwealth Agent to Scope 

Motions, Oppositions and Objections of COFINA Agent and 

Intervenors

0.100 37.50

12-12-2017 NN Read update report re Scope Motions and Replies sent by WF&G 0.100 37.50

12-12-2017 NN Read AAFAF's Omnibus Reply in Support of Motion to Dismiss 

in adversary proceeding against COFINA Agent

0.200 75.00

12-12-2017 NN Read update report re Scope Motions and replies sent by WF&G 0.100 37.50

12-14-2017 NN Review draft of Motion re Omnibus hearing to be filed on behalf 

of COFINA Agent

0.100 37.50

12-14-2017 NN Correspond with C. Koenig and co-counsel re Motion to be filed 

re Omnibus hearing

0.100 37.50

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Date Timekeeper Description Hours Amount

12-14-2017 NN Read Court Minutes re December 14 hearing 0.100 37.50

12-15-2017 NN Read multiple motions re Omnibus hearing 0.400 150.00

12-15-2017 NN Read Order re Scope Motions in adversary proceeding against 

COFINA Agent

0.100 37.50

12-16-2017 NN Review Interim Fee Applications filed by local counsel to various 

parties

0.700 262.50

12-19-2017 NN Study Agenda for Omnibus hearing 0.200 75.00

12-20-2017 NN Correspond with co-counsel re amended Notice of hearing 0.200 75.00

12-20-2017 NN Read email sent by A. Ambeault (WF&G) in preparation for 

Omnibus hearing

0.100 37.50

12-20-2017 NN Attend Omnibus hearing 2.500 937.50

12-20-2017 NN Review draft of amended Notice of hearing re Interim 

Applications

0.100 37.50

12-20-2017 NN Correspond with A. Ambeault (WF&G) re draft of amended 

Notice of hearing

0.100 37.50

12-20-2017 NN Read H. Honig's email with re Omnibus hearing 0.100 37.50

12-20-2017 NN Read AAFAF's Informative Motion re disclosure of cash 

balances and analyze 5 step process to evaluate cash position 

and summary of account balances

0.200 75.00

12-20-2017 NN Read Court Minutes re Omnibus hearing 0.100 37.50

12-21-2017 NN Correspond with co-counsel and B. Whyte re Court Order as to 

scope motions

0.200 75.00

12-21-2017 NN Analyze Court Order re Scope Motions 0.300 112.50

12-21-2017 NN Read update as to new Court Order sent by WF&G 0.100 37.50

12-22-2017 NN Analyze chart of Commonwealth's claims and chart of COFINA 

Agent's counterclaims after the Order

0.300 112.50

12-22-2017 NN Read Urgent Motion to Compel Commonwealth to comply with 

Order re Interim Compensation filed by Official Committee of 

Retired Employees

0.100 37.50

12-23-2017 NN Read urgent Motion for expedited hearing filed by Official 

Committee of Retired Employees

0.100 37.50

12-23-2017 NN Study FOMB's Reply to U.S. Memorandum in support of 

constitutionality of PROMESA

0.300 112.50

12-23-2017 NN Read Debtor's first Omnibus motion for approval of Stipulation 0.100 37.50

12-23-2017 NN Read American Federation Reply to U.S. Memorandum in 

support of constitutionality of PROMESA

0.100 37.50

12-28-2017 NN Read Motion to withdraw as counsel for COFINA Senior 

Bondholders filed in adversary proceeding against COFINA 

Agent

0.100 37.50

12-28-2017 NN Read Court Order granting in part and denying in part motion to 

conduct examination of GDB

0.100 37.50

Total Fees 8,437.50

Time Summary

Timekeeper Hours Rate Amount

NN 22.500 375.00 8,437.50

Total Fees 8,437.50

00004 - Mediation

Professional Services

Date Timekeeper Description Hours Amount

12-01-2017 NN Analyze update sent by WF&G re PR CDL financing 0.200 75.00

12-04-2017 NN Study news reports sent by B. Whyte re new developments in 

PR relevant to GO-COFINA dispute

0.300 112.50

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Date Timekeeper Description Hours Amount

12-05-2017 NN Read update report sent by WF&G 0.100 37.50

12-05-2017 NN Read report sent by B. Whyte as to recent developments with 

FOMB

0.200 75.00

12-05-2017 NN Analyze H. Honig's Summary of FOMB's session in NY 0.200 75.00

12-06-2017 NN Analyze summary as to FOMB's 11th Board meeting and 

relevant documents

0.600 225.00

12-06-2017 NN Analyze C. Koeing's Summary of Second Mediation session 0.100 37.50

12-08-2017 NN Read Report re COFINA Trustee disclosure of market value of 

debt service account

0.100 37.50

12-13-2017 NN Read analysis re PR cash flow dip sent by WF&G 0.100 37.50

12-19-2017 NN Correspond with B. Whyte re new developments in PR relevant 

to GO-COFINA dispute

0.400 150.00

12-19-2017 NN Analyze news as to AAFAF revealing amount in public coffers 

sent by B. Whyte

0.200 75.00

Total Fees 937.50

Time Summary

Timekeeper Hours Rate Amount

NN 2.500 375.00 937.50

Total Fees 937.50

00005 - Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

12-04-2017 NN Correspond with J. Weiss re Interim Fee Application 0.200 75.00

12-07-2017 RR Prepare draft of November fee statement 1.600 200.00

12-07-2017 NN Correspond with A. Ambeault re WF&G fee application 0.200 75.00

12-08-2017 NN Review and revise November fee statement 1.200 450.00

12-11-2017 RR Obtain information needed for preparing First Interim Fee 

Application and work with draft of First Interim Fee Application

3.200 400.00

12-11-2017 NN Commence drafting First Interim Fee Application 4.300 1,612.50

12-12-2017 NN Confer with S. Pearson re First Interim Fee Application 0.300 112.50

12-12-2017 NN Conclude drafting First Interim Fee Application 5.500 2,062.50

12-12-2017 NNC Correspond with J. Weiss and S. Pearson the Interim Fee 

Application

0.300 No Charge

12-13-2017 NN Correspond with C. Koenig and co-counsel re First Interim Fee 

Application and Fee Examiner's Memorandum not previously 

notified

0.500 187.50

12-13-2017 NN Study Fee Examiner required Cover Sheet for Interim Fee 

Application, proposed stipulation re confidential information and 

related correspondence

0.300 112.50

12-13-2017 NN Revise Interim Fee Application to comply with Fee Examiner's 

requirements set forth in Memorandum from Fee Examiner

3.400 1,275.00

12-13-2017 NN Study Fee Examiner's Status Report as to Interim Fee 

Application and Memorandum re fee review process attached in 

order to revise First Interim Fee Application to comply with 

Memorandum

0.600 225.00

12-14-2017 RR Draft index of exhibits for First Interim Fee Application 0.200 25.00

12-14-2017 RR Prepare Cover for Interim Fee Application requested by Fee 

Examiner and review necessary documents to compile 

information needed

0.600 75.00

12-14-2017 NN Review revised draft of Stipulated Disclosure and Protective 

Order sent by counsel for the Fee Examiner

0.100 37.50

12-15-2017 NN Review B. Whyte Interim Fee Application to verify compliance 0.300 112.50

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Date Timekeeper Description Hours Amount

with Local Rules in order to sign it as local counsel for filing in 

Court as required by Local Rules

12-15-2017 NN Read Notice of Hearing to consider application for allowance of 

Interim Compensation to COFINA Agent applicants

0.100 37.50

12-15-2017 NN Draft Certification to include with First Interim Fee Application 0.600 225.00

12-15-2017 NN Final revision to Interim Fee Application and exhibits 1.900 712.50

12-15-2017 NN Review KTBS' Interim Fee Application to verify compliance with 

Local Rules in order to sign it as local counsel as required by 

Local Rules

0.300 112.50

12-15-2017 NN Review WF&G's Interim Fee Application to verify compliance 

with Local Rules in order to sign it as local counsel as required 

by Local Rules

0.400 150.00

12-15-2017 NN Correspond with A. Ambeault (WF&G) and co-counsel re 

required notices of the Interim Fee Application

0.300 112.50

12-15-2017 RR Prepare for filing and file the First Interim Fee Application in CM/

ECF System

0.300 37.50

12-15-2017 RR Verify correction of amounts, information and cites included in 

First Interim Fee Application

2.300 287.50

12-15-2017 RR Prepare the various exhibits for the First Interim Fee Application, 

including Summary of Professionals, Summary of Expenses and 

Summary of Time by billing category and comparable 

compensation disclosure

1.800 225.00

12-15-2017 NNC Work on First Interim Fee Application 3.500 No Charge

12-15-2017 NNC Correspond with co-counsel from WF&G and KTBS re Interim 

Fee Application

0.500 No Charge

12-18-2017 NN Correspond with co-counsel re Interim Fee Application 0.200 75.00

12-28-2017 NN Review revised draft of Stipulated Disclosure and Protective 

Order sent by counsel for the Fee Examiner

0.100 37.50

12-28-2017 NN Correspond with co-counsel from WF&G and KTBS re Interim 

Fee Applications and notices

0.500 187.50

Total Fees 9,237.50

Time Summary

Timekeeper Hours Rate Amount

NN 21.300 375.00 7,987.50

NNC 4.300 0.00 0.00

RR 10.000 125.00 1,250.00

Total Fees 9,237.50

00006 - Fee Application Retention and Objections

Professional Services

Date Timekeeper Description Hours Amount

12-23-2017 RR Prepare No Objection Statement 0.500 62.50

12-23-2017 NN Revise No Objection Statement 0.200 75.00

12-23-2017 NN Correspond with S. Pearson re service of No Objection 

Statement

0.100 37.50

Total Fees 175.00

Time Summary

Timekeeper Hours Rate Amount

NN 0.300 375.00 112.50

RR 0.500 125.00 62.50

Total Fees 175.00

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00007 - Budget

Professional Services

Date Timekeeper Description Hours Amount

12-01-2017 NN Correspond with co-counsel re budget 0.200 75.00

12-04-2017 NN Prepare budget requested by COFINA 1.000 375.00

12-04-2017 NN Correspond with S. Hussein re requested budget 0.200 75.00

12-18-2017 RR Correspond with S. Pearson (KTBS) re budget requirements by 

Fee Examiner

0.200 25.00

12-18-2017 RR Review memo for Fee Examiner re budget requirements 0.100 12.50

12-20-2017 RR Work on case monthly budget 0.400 50.00

12-20-2017 NN Revise monthly budget 0.200 75.00

12-20-2017 NN Correspond with S. Pearson (KTBS) re budget 0.200 75.00

Total Fees 762.50

Time Summary

Timekeeper Hours Rate Amount

NN 1.800 375.00 675.00

RR 0.700 125.00 87.50

Total Fees 762.50

00008 - Discovery/Facts Analysis

Professional Services

Date Timekeeper Description Hours Amount

12-04-2017 NN Read limited Joinder of Committee of Unsecured Creditors to 

Ambac's motion re discovery re SUT

0.100 37.50

12-04-2017 NN Read Limited Joinder of Committee of Unsecured Creditors to 

Urgent Renewed Joint Motion by Ad Hoc Group of GO 

Bondholders and others authorizing examination

0.100 37.50

12-05-2017 NN Correspond with J. Weiss re pending production of documents 

from UBS

0.100 37.50

12-05-2017 NN Read COFINA Senior Bondholders' Statement in Support of 

Ambac's Motion re discovery

0.100 37.50

12-05-2017 NN Read FGIC's Joinder to Urgent Renewed Joint Motion filed by 

Ad Hoc Group of GO Bondholders and others re examination

0.100 37.50

12-05-2017 NN Read Joinder of FGIC to Ambac's Motion re discovery 0.100 37.50

12-06-2017 NN Correspond with J. Weiss and counsel for UBS re responses to 

Subpoena for production of documents

0.200 75.00

12-06-2017 NN Read letter to counsel for PR Treasury re pending production 0.100 37.50

12-06-2017 NN Read AAFAF's Objection to Ambac's Rule 2004 Motion 0.100 37.50

12-06-2017 NN Read ERS' Secured Creditors Joinder to Urgent Motion re 

discovery and WTBC Noteholders Joinder and Statement in 

Support and Joinder re discovery

0.200 75.00

12-06-2017 NN Read Retiree Committee Urgent Limited Response to Urgent 

Motion re discovery

0.100 37.50

12-06-2017 NN Read Objection and Responses of FOMB Commonwealth and 

AAFAF to Urgent Motion re discovery

0.200 75.00

12-07-2017 NN Read FOMB's Joinder to Ambac's discovery motion 0.100 37.50

12-08-2017 NN Read Assured's Limited Joinder to Motion re discovery 0.100 37.50

12-08-2017 NN Read Mutual Fund Group limited response to discovery motion 0.100 37.50

12-08-2017 NN Confer with S. Hussein re Interrogatories to Commonwealth 

Agent and other pending discovery matters

0.200 75.00

12-08-2017 NN Revise draft of Interrogatories to Commonwealth Agent 0.300 112.50

12-08-2017 NN Correspond with counsel for UBS re pending document 0.200 75.00

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Date Timekeeper Description Hours Amount

production

12-08-2017 NN Read letter from J. Daniels (O'Melveny) counsel for PR Treasury 

re response to Subpoena for production of documents and list of 

search terms

0.200 75.00

12-09-2017 NN Corresponde with J, Weiss re UBS's pending production of 

documents

0.100 37.50

12-11-2017 RR Work on chart of document production 0.700 87.50

12-11-2017 NN Correspond with J. Weiss and UBS counsel re UBS pending 

responses to Subpoena

0.100 37.50

12-11-2017 NN Correspond with A. Gouzoules re status of Subpoenas served 

on PR

0.500 187.50

12-11-2017 NN Correspond with J. Dugan re pending production from third 

parties in PR

0.200 75.00

12-11-2017 NN Confer with M. Muñiz (O'Neill & Borges) re status of document 

production

0.300 112.50

12-11-2017 NN Study discovery files to report on current status of discovery 

requests from third parties in PR

0.700 262.50

12-11-2017 NN Correspond with J. Dugan re pending production from third 

parties in PR

0.200 75.00

12-11-2017 NN Confer with M. Muñiz (O'Neill & Borges) re status of document 

production

0.200 75.00

12-11-2017 NN Correspond with counsel for Santander re status of document 

production

0.200 75.00

12-11-2017 NN Read Joint Status report re renewed Joint Motion for Order 

authorizing discovery

0.100 37.50

12-11-2017 NN Read Reply Brief in support of Urgent Renewed Joint Motion for 

Order authorizing discovery

0.200 75.00

12-12-2017 NN Confer with Rivera-Font (Santander's local counsel) re status of 

Santander response to Subpoena Duces Tecum

0.200 75.00

12-12-2017 NN Correspond with counsel for Santander re status of production of 

documents

0.100 37.50

12-12-2017 NN Correspond with A. Gouzoules (co-counsel) re Subpoena Duces 

Tecum to the UCC

0.200 75.00

12-12-2017 NN Revise draft of Notice of Subpoena Duce Tecum to the UCC, 

draft of Subpoena and Exhibit with list of documents requested

0.400 150.00

12-12-2017 NN Analyze Ambac's Reply to Opposition to discovery motion to 

identify issues relevant to pending discovery requested by 

COFINA Agent

0.300 112.50

12-13-2017 NN Correspond with M. Muñiz (counsel for O&B) re O&B's pending 

production of documents in response to Subpoena

0.200 75.00

12-15-2017 NN Correspond with M. Rohan (counsel for UBS) and J. Weiss 

(KTBS) re UBS responses to the Subpoena Duces Tecum

0.100 37.50

12-21-2017 RR Confer with process server to coordinate service of deposition 

Subpoenas to Banco Popular, GDB, PR Treasury Department, 

Justice Department and Executive office

0.500 62.50

12-21-2017 RR Confer with N. Navarro to coordinate service of 8 deposition 

Subpoenas

0.300 37.50

12-21-2017 NN Correspond with A. Gouzoules (WF&G) re possible need to 

revise deposition Subpoenas in light of recent Court Order as to 

Scope Motions

0.500 187.50

12-21-2017 NN Correspond with S. Hussein (WF&G) re Subpoenas for 

depositions to be served in PR

0.200 75.00

12-21-2017 NN Read Order authorizing discovery 0.100 37.50

12-21-2017 NN Read 4th Motion on consent to further adjourn PMA's Motion to 

Quash Subpoena in adversary proceeding against COFINA 

Agent

0.100 37.50

12-21-2017 NN Read Order further adjourning PMA's Motion to Quash 0.100 37.50

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Date Timekeeper Description Hours Amount

12-21-2017 NN Confer with R. Rivera (paralegal) to coordinate service of 8 

deposition Subpoenas and provide instructions as to service and 

filing

0.300 112.50

12-21-2017 NN Correspond with A. Gouzoules (WF&G) re deposition 

Subpoenas to be served in PR and re coordination of depositions

0.300 112.50

12-23-2017 NN Correspond with M. Muñiz (O'Neill & Borges) re production of 

documents

0.300 112.50

12-23-2017 NN Read Joint Motion re Rule 2004 Examination 0.100 37.50

12-23-2017 NN Correspond with S. Hussein re pending deposition Subpoenas 

and documents produced by O'Neill & Borges

0.100 37.50

12-29-2017 NN Preliminary review of documents produced by O'Neill & Borges 

to identify categories of documents produced

0.800 300.00

Total Fees 3,900.00

Time Summary

Timekeeper Hours Rate Amount

NN 9.900 375.00 3,712.50

RR 1.500 125.00 187.50

Total Fees 3,900.00

Total for this Invoice 23,473.80

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(Itemized expenses for the period of December 1, 2017 through December 31, 2017)

Date Expense Amount Description

12/29/2017 Copies $23.80 Photocopies made in house for the month of 

December

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EXHIBIT 4-D

TIME AND EXPENSE DETAIL FOR THE JANUARY 2018 FEE STATEMENT

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12

Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

02-15-2018

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 18013163

Invoice Period: 01-01-2018 - 01-31-2018

RE: Multiple Matters

00000 - Expenses

00001 - Litigation/Adversary Proceeding

00004 - Mediation

00005 - Fee Application and Retention

00006 - Fee Application Retention and Objections

00007 - Budget

00008 - Discovery/Facts Analysis

00000 - Expenses

Expenses

Date Description Price Qty Amount

01-10-2018 Deposition fees and mileage for deponent 45.00 1 45.00

01-10-2018 In house copies 0.10 137 13.70

01-12-2018 Process server fees for deposition Subpoena 50.00 1 50.00

01-29-2018 Messenger service to the Offices of Reichard & Calaf 8.32 1 8.32

01-30-2018 Application for Admission Pro Hac Vice for R. Pfister 300.00 1 300.00

Total Expenses 417.02

00001 - Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

01-02-2018 NN Review Court Dockets to identify any new filings relevant to the 

COFINA Agent

0.300 112.50

01-03-2018 NN Read Aurelius' Sur-Reply re Motion to Dismiss 0.300 112.50

01-03-2018 NN Weekly conference call with B. Whyte and co-counsel re pending 

matters

0.400 150.00

01-03-2018 NN Read COFINA Senior Bondholder Coalition's Motion in AP of 

BNYM v COFINA

0.100 37.50

01-03-2018 NN Read Court Order re COFINA Senior Bondholder Coalition's 

Motion in AP of BNYM v COFINA

0.100 37.50

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Date Timekeeper Description Hours Amount

01-03-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

01-04-2018 NN Read updates of new developments relevant to GO-COFINA 

dispute sent by WF&G

0.200 75.00

01-04-2018 NN Analyze Commonwealth Agent's Urgent Motion to clarify Scope 

Order re GO-COFINA dispute and Second Amended Complaint 

included with Motion

1.400 525.00

01-04-2018 NN Read Commonwealth Agent's Urgent Motion to Expedite 

consideration of Motion to Clarify Scope

0.100 37.50

01-04-2018 NN Read Court Order scheduling hearing in AP against COFINA 

Agent re Urgent Motion to clarify Scope

0.100 37.50

01-04-2018 NN Correspond with co-counsel and B. Whyte re Commonwealth 

Agent's Motion to clarify Scope Order re GO-COFINA dispute

0.500 187.50

01-04-2018 NN Read case update sent by WF&G 0.100 37.50

01-04-2018 NN Read Court Order re January 10 hearing on Motion to Dismiss 0.100 37.50

01-05-2018 NN Read Ambac's Informative Motion re Scope Motion hearing in 

AP against COFINA Agent

0.100 37.50

01-05-2018 NN Revise draft of COFINA Agent's Informative Motion as to hearing 

in AP against COFINA Agent

0.100 37.50

01-05-2018 NN Correspond with A. Ambeault (WK&G) re draft of COFINA 

Agent's Informative Motion as to hearing in AP COFINA Agent

0.100 37.50

01-05-2018 NN Read Informative Motion of AFSCME re hearing 0.100 37.50

01-05-2018 NN Prepare for conference call to discuss strategy to address 

Commonwealth Agent's motion for clarification of Scope Order 

and review relevant documents

0.800 300.00

01-05-2018 NN Conference call with B. Whyte and co-counsel re 

Commonwealth Agent's Motion for clarification of Scope Order

0.400 150.00

01-05-2018 NN Read COFINA Senior Bondholders' Motion re hearing in AP 

against COFINA Agent

0.100 37.50

01-05-2018 NN Read Ad Hoc Group of GO Bondholders Motion re hearing in AP 

against COFINA Agent

0.100 37.50

01-05-2018 NN Read multiple motions filed as to January 10 hearing on Motion 

to Dismiss Article III Petition

0.500 187.50

01-06-2018 NN Read BNYM's Omnibus Reply in support of motion for Summary 

Judgment in AP filed by BNYM against COFINA to assess 

issues relevant to the COFINA Agent

0.200 75.00

01-06-2018 NN Read COFINA Senior Bondholder's Motion for Voluntary 

Dismissal without prejudice of Cyrus Capital from the 

interpleader action

0.100 37.50

01-06-2018 NN Read Mutual Funds Group and PR Fund's Reply in support of 

Motion for Summary Judgment in AP filed by BNYM against 

COFINA to assess issues relevant to the COFINA Agent

0.200 75.00

01-06-2018 NN Read Joint Reply Memorandum of Law of COFINA Senior 

Bondholders' Coalition and Whitebox in support of Joint Motion 

for Summary Judgment in AP filed by BNYM against COFINA to 

assess issues relevant to the COFINA Agent

0.400 150.00

01-06-2018 NN Review Mutual Fund Group, PR Funds and Assured's Response 

to the COFINA Senior Parties' "Counterstatement of Relevant 

Facts" to assess issues relevant to the COFINA Agent

0.100 37.50

01-06-2018 NN Read Joint Omnibus Reply Statement of Undisputed Material 

Facts of the COFINA Senior Bondholders' Coalition and 

Whitebox to assess issues relevant to the COFINA Agent

0.200 75.00

01-06-2018 NN Read COFINA Senior Bondholders' Motion for Voluntary 

Dismissal without prejudice of Cyrus Capital from the AP against 

the COFINA Agent and proposed order

0.100 37.50

01-07-2018 NN Review Court dockets to identify any new filings relevant to the 

COFINA Agent

0.300 112.50

01-07-2018 NN Correspond with S. Hussein (WF&G) re draft of Opposition to 0.500 187.50

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Date Timekeeper Description Hours Amount

Commonwealth Agent's Motion to clarify Scope Order

01-07-2018 NN Analyze draft of Opposition to Commonwealth Agent's Motion to 

clarify Scope Order sent by WF&G in order to provide comments

1.200 450.00

01-07-2018 NN Read new draft of Opposition to Commonwealth Agent's Motion 

to clarify Scope Order sent by WF&G

0.200 75.00

01-08-2018 NN Correspond with S. Hussein re draft of Opposition to 

Commonwealth Agent's Motion to clarify Scope Order sent by 

WF&G

0.100 37.50

01-08-2018 NN Analyze revised draft of Opposition to Commonwealth Agent's 

Motion to clarify Scope Order sent by WF&G

0.300 112.50

01-08-2018 NN Read litigation update sent by WF&G 0.100 37.50

01-08-2018 NN Review Court dockets to identify any new filings relevant to 

COFINA Agent

0.300 112.50

01-08-2018 NN Read Order granting Cyrus voluntary dismissal in AP against 

COFINA Agent

0.100 37.50

01-08-2018 NN Analyze COFINA Senior Bondholders' Objection to 

Commonwealth Agent's Motion for Reconsideration re Scope 

Order in AP against COFINA Agent

0.300 112.50

01-08-2018 NN Read Ambac's Objection to Commonwealth Agent's Motion for 

Reconsideration re scope Order in AP against COFINA Agent

0.200 75.00

01-08-2018 NN Read Joinder of National Public Finance Guarantee Corp. to 

COFINA Agent's Objection to Commonwealth Agent's Motion for 

Clarification of Scope Order

0.100 37.50

01-08-2018 NN Read Court's Notice of correspondence and exhibits 0.100 37.50

01-08-2018 NN Read Ad Hoc Group of GO Bondholders' Response to 

Commonwealth Agent's Motion for Clarification of Scope Order

0.100 37.50

01-08-2018 NN Read Debtors' Statement in response to Commonwealth 

Agent's Motion for Clarification of Scope Order

0.100 37.50

01-08-2018 NN Study chart sent by WF&G of various responses to the 

Commonwealth Agent's Motion for Clarification of Scope Order 

and summaries of the arguments

0.300 112.50

01-09-2018 NN Read Second Amended Informative Motion of FOMB re January 

10 hearing in main proceeding

0.100 37.50

01-09-2018 NN Review Court dockets to identify any new filings relevant to 

COFINA Agent

0.200 75.00

01-09-2018 NN Read Second Amended Informative Motion of Commonwealth 

Agent re hearing in AP against COFINA Agent

0.100 37.50

01-09-2018 NN Read Joinder of Official Committee of Retires Employees to the 

Commonwealth Agent's Urgent Motion for Clarification of Scope 

Order in AP against COFINA Agent

0.100 37.50

01-09-2018 NN Analyze Commonwealth Agent's Reply in support of Urgent 

Motion for Clarification of Scope Order in AP against COFINA 

Agent

0.200 75.00

01-09-2018 NN Analyze Ad Hoc Group of GO Bondholders' Reply re 

Commonwealth Agent's Urgent Motion for Clarification of Scope 

Order in AP against COFINA Agent

0.100 37.50

01-09-2018 NN Correspond with B. Whyte and co-counsel re replies filed in AP 

against COFINA Agent

0.300 112.50

01-09-2018 NN Read various updates sent by WF&G re new developments in 

AP against COFINA Agent

0.300 112.50

01-09-2018 NN Read Limited Objection of QTCN Noteholder Group to COFINA 

Agent's and COFINA Senior Bondholders' Objections to the 

Commonwealth Agent's Clarification Motion

0.100 37.50

01-10-2018 NN Attend hearing in San Juan (via closed circuit) as to Motion to 

Dismiss Article III cases and as to Motion to clarify Scope 

Motions in AP against COFINA Agent

4.600 1,725.00

01-10-2018 NN Read report sent by WF&G re hearing 0.100 37.50

01-10-2018 NN Read Court Order denying Motion for clarification of Scope Order 0.100 37.50

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Date Timekeeper Description Hours Amount

01-11-2018 NN Correspond with co-counsel and B. Whyte re Order as to Motion 

to clarify Scope Order in AP against COFINA Agent

0.300 112.50

01-11-2018 NN Read Court Minutes of January 10 hearing in AP against 

COFINA Agent

0.100 37.50

01-11-2018 NN Analyze Commonwealth Agent's Urgent Motion seeking leave to 

file Revised Second Amended Complaint against COFINA Agent 

and proposed Amended Complaint

0.700 262.50

01-11-2018 NN Correspond with B. Whyte and co-counsel re Commonwealth 

Agent's revised complaint and strategy

0.400 150.00

01-11-2018 NN Read litigation updates sent by WF&G 0.200 75.00

01-12-2018 NN Revise draft of Objection to Commonwealth Agent's Motion for 

Leave to File Amended Complaint

0.300 112.50

01-12-2018 NN Correspond with B. Whyte and co-counsel re draft of Objection 

to Commonwealth Agent's Motion for Leave to File Amended 

Complaint

0.500 187.50

01-12-2018 NN Review revised version of draft of Objection to Commonwealth 

Agent's Motion for Leave to File Amended Complaint

0.300 112.50

01-12-2018 NN Correspond with S. Hussein (WF&G) re Objection to 

Commonwealth Agent's Motion For Leave to File Amended 

Complaint

0.300 112.50

01-12-2018 NN Read Objection of the COFINA Senior Bondholder's Coalition to 

the Commonwealth Agent's Urgent Motion Seeking Leave to File 

Revised Amended Complaint

0.100 37.50

01-12-2018 NN Read Joinder of National Public Finance Guarantee Corp to 

COFINA Agent’s Objection to Commonwealth Agent’s Motion 

Seeking Leave to File Amended Complaint

0.100 37.50

01-12-2018 NN Read Ambac's Joinder to COFINA Agent's Objection to 

Commonwealth Agent's Urgent Motion Seeking Leave to File 

Amended Complaint

0.100 37.50

01-12-2018 NN Read update sent by WF&G re litigation 0.100 37.50

01-13-2018 NN Analyze Commonwealth Agent's Reply to COFINA Agent 0.200 75.00

01-13-2018 NN Read Order granting COFINA Senior Bondholders' Motion for 

Voluntary Dismissal

0.100 37.50

01-13-2018 NN Read second Order extending deadlines under Order scheduling 

briefing

0.100 37.50

01-14-2018 NN Analyze Court Order granting Commonwealth Agent's Motion to 

Amend Complaint

0.300 112.50

01-14-2018 NN Correspond with B. Whyte and co-counsel re Court Order 0.500 187.50

01-14-2018 NN Confer with B. Whyte and co-counsel re Court Order and strategy 0.200 75.00

01-15-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

01-16-2018 NN Read update re litigation sent by WF&G 0.100 37.50

01-16-2018 NN Study Amended Complaint filed by Commonwealth Agent 

against COFINA Agent

0.400 150.00

01-16-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

01-16-2018 NN Read Notice of hearing on Motion of National Finance 

Guarantee Corporation

0.100 37.50

01-17-2018 NN Correspond with co-counsel and counsel for Commonwealth 

Agent re Amended Complaint against COFINA Agent

0.300 112.50

01-17-2018 NN Study Court Order re February 7 Omnibus hearing 0.100 37.50

01-17-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.400 150.00

01-17-2018 NN Review Third Supplemental Verified Statement of Senior 

COFINA Bondholders' Coalition

0.100 37.50

01-17-2018 NN Weekly conference call with B. Whyte and co-counsel re strategy 

and pending matters

0.600 225.00

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Date Timekeeper Description Hours Amount

01-18-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

01-18-2018 NN Brief review of Notice of Filing of Wolfe's First Interim Fee 

Application for Compensation as Contractor to FOMB

0.100 37.50

01-19-2018 NN Review Court dockets to identify any new filings relevant to 

COFINA Agent

0.300 112.50

01-23-2018 NN Study various case updates sent by WF&G 0.500 187.50

01-23-2018 NN Analyze Commonwealth Agent's Urgent Motion to extend 

deadlines in AP against COFINA Agent and proposed Order 

and Motion to expedite consideration of Urgent Motion

0.400 150.00

01-23-2018 NN Read Court scheduling Order re Commonwealth Agent's Urgent 

Motion for Amendment of deadlines in AP against COFINA Agent

0.100 37.50

01-23-2018 NN Analyze Ambac's Urgent Motion for Leave to Amend its 

Counterclaim and for clarification re Scope of Second Amended 

Complaint in AP against COFINA Agent, draft Order and 

Ambac's Answer

0.700 262.50

01-23-2018 NN Read Ambac's Urgent Motion to expedite consideration of its 

Urgent Motion for Leave to Amend its Counterclaims and 

proposed Order

0.200 75.00

01-23-2018 NN Correspond with co-counsel re draft of Statement in Support of 

Commonwealth Agent's Urgent Motion for Amendment of 

deadlines

0.300 112.50

01-23-2018 NN Review draft of COFINA Agent's Statement in support of 

Commonwealth Agent's Urgent Motion for Amendment of 

deadlines

0.200 75.00

01-23-2018 NN Read Mutual Fund Group's limited objection to Commonwealth 

Agent's Urgent Motion for Amendment of deadlines

0.100 37.50

01-23-2018 NN Read COFINA Senior Bondholders' Objection to Motion to 

Amend scheduling Order for the Commonwealth-COFINA 

Dispute and Urgent Motion to expedite consideration of Urgent 

Cross-Motion and proposed Order

0.500 187.50

01-23-2018 NN Read Ambac's Objection to Commonwealth Agent's Urgent 

Motion for Amendment of deadlines in AP COFINA Agent

0.200 75.00

01-23-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.400 150.00

01-24-2018 NN Read Motion for Leave to file proposed Order in AP against 

COFINA Agent

0.100 37.50

01-24-2018 NN Read Ad Hoc's Group of GO Bondholders' Joinder to Mutual 

Fund Group's limited objection to Commonwealth Agent's Urgent 

Motion

0.100 37.50

01-24-2018 NN Read Commonwealth Agent's Reply in AP against COFINA 

Agent

0.200 75.00

01-24-2018 NN Read limited Reply of Debtors, FOMB and AAFAF in support of 

Commonwealth Agent's Urgent Motion for Amendment of 

Deadlines

0.100 37.50

01-24-2018 NN Review draft of COFINA Agent's statement in support of Cross 

Motion

0.100 37.50

01-24-2018 NN Correspond with S. Hussein (WF&G) re draft of COFINA Agent's 

statement in support of Cross Motion

0.100 37.50

01-24-2018 NN Weekly call with B. Whyte and co-counsel re new developments 

and strategy

0.400 150.00

01-24-2018 NN Correspond with co-counsel re new developments and strategy 0.500 187.50

01-25-2018 NN Read various case updates sent by WF&G 0.300 112.50

01-25-2018 NN Revise draft of COFINA Agent's Urgent Motion for extension of 

deadlines for Summary Judgment and Urgent Motion for 

expedite consideration with proposed Order

0.200 75.00

01-25-2018 NN Correspond with co-counsel re draft of motions to be filed and 

new development

0.500 187.50

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Date Timekeeper Description Hours Amount

01-25-2018 NN Read Order denying COFINA Senior Bondholders' Coalition's 

Urgent Crossmotion for a status conference in AP against 

COFINA Agent

0.100 37.50

01-25-2018 NN Analyze Order amending scheduling Order in AP against 

COFINA Agent

0.100 37.50

01-25-2018 NN Read National Public Finance Guarantee Corporation's 

Opposition to GDB's Urgent Motion for an extension to oppose 

National's Rule 2004 Motion

0.100 37.50

01-25-2018 NN Read Court Order re GDB's Motion 0.100 37.50

01-25-2018 NN Review Notice of filing of revised Order establishing deadlines 

and procedures for filing proofs of claim and approving form and 

manner of notice

0.100 37.50

01-25-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

01-25-2018 NN Read Order denying Ambac's Urgent Motion for leave to amend 

its Counterclaims and for clarification re Scope of Second 

Amended Complaint

0.200 75.00

01-25-2018 NN Review final version of COFINA Agent's Urgent Motion for 

extension of deadlines and Urgent Motion for expedite 

consideration as filed

0.100 37.50

01-25-2018 NN Correspond with S. Hussein (WF&G) re pending motions 0.100 37.50

01-26-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

01-26-2018 NN Read statement of the Ad Hoc Group of GO Bondholders in 

support of COFINA Agent's Urgent Motiion for extension of 

deadlines

0.100 37.50

01-26-2018 NN Read Order scheduling expedited summary judgment briefing on 

COFINA Agent's Urgent Motion

0.100 37.50

01-26-2018 NN Read Notice of correspondence received by the Court and brief 

review of correspondence

0.100 37.50

01-26-2018 NN Read FGIC's Informative Motion re February 7 Omnibus Hearing 0.100 37.50

01-26-2018 NN Analyze Title III case updates sent by WF&G 0.300 112.50

01-27-2018 NN Read Debtor's response to COFINA Agent's Motion for 

Extension of Summary Judgment Deadlines

0.100 37.50

01-27-2018 NN Revise draft of COFINA Agent's Reply in support of Motion for 

Extension of Summary Judgment deadlines

0.200 75.00

01-27-2018 NN Correspond with counsel and B. Whyte re draft 0.200 75.00

01-27-2018 NN Read final version of COFINA Agent's Reply in support of Motion 

for Extension of Summary Judgment deadlines

0.100 37.50

01-27-2018 NN Read Order re PREPA's Motion for Extension of Deadlines 0.100 37.50

01-28-2018 NN Read case updates sent by WF&G 0.200 75.00

01-28-2018 NN Correspond with co-counsel and B. Whyte re new developments 0.300 112.50

01-28-2018 NN Read Order amending deadline for Summary Judgment briefing 

in AP against COFINA Agent

0.100 37.50

01-28-2018 NN Review FOMB's post-petition financing Motion re PREPA 0.600 225.00

01-29-2018 NN Read case updates sent by WF&G 0.200 75.00

01-30-2018 RR Trip to USDC to process payment for Application for Admission 

Pro Hac Vice for R. Pfister and obtain receipt required for filing

1.200 150.00

01-30-2018 RR Finalize for filing and file Application for Admission Pro Hac Vice 

for R. Pfister and corresponding receipt

0.300 37.50

01-30-2018 RR Correspond with S. Hussein (WF&G) re application Pro Hac Vice 

for R. Pfister

0.300 37.50

01-30-2018 RR Confer with S. Husssein (WF&G) re application for admission 

Pro Hac Vice for R. Pfister

0.100 12.50

01-30-2018 NN Revise draft of Application for Admission Pro Hac Vice for R. 

Pfister and Order

0.100 37.50

01-30-2018 NN Correspond with S. Hussein (WF&G) re Application Pro Hac 0.200 75.00

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Date Timekeeper Description Hours Amount

Vice for R. Pfister

01-30-2018 NN Analyze updates sent by WF&G re developments in Title III 

litigation relevant to COFINA Agent

0.400 150.00

01-30-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

01-30-2018 NN Read Ad Hoc Group of Go Bondholders', Ambac's and others 

Reply Brief in support of production and use of fiscal plan 

development matierials

0.100 37.50

01-30-2018 NN Review draft of COFINA Agent's Second Amended Answer and 

Counterclaims

0.500 187.50

01-30-2018 NN Correspond with S. Hussein (WF&G) re COFINA Agent's 

Second Amended Answer and Complaint

0.100 37.50

01-30-2018 NN Review PREPA's Motion for Order to enlarge time to file notice 

of removal

0.100 37.50

01-31-2018 NN Analyze Opinion and Order dismissing the GO Bondholders' AP 0.300 112.50

01-31-2018 NN Review NPFG's Answer, Affirmative Defenses, and 

Counterclaims in AP against COFINA Agent and compare with 

previous one

0.400 150.00

01-31-2018 NN Review Mutual Fund Group and PR Funds Amended Answer 

and Counterclaims in AP against COFINA Agent and compare 

with previous one

0.300 112.50

01-31-2018 NN Read case updates sent by WF&G 0.300 112.50

01-31-2018 NN Read Order Amending Standing Order re matters before Judge 

Dein

0.100 37.50

01-31-2018 NN Correspond with co-counsel and B. Whyte re Amended Answers 

and Counterclaims filed in AP against COFINA Agent

0.200 75.00

01-31-2018 NN Commence analyzing draft of Motion for Summary Judgment 

and reviewing PR case law cited in draft

2.800 1,050.00

01-31-2018 NN Correspond with co-counsel re draft of Motion for Summary 

Judgment

0.300 112.50

01-31-2018 RR Legal research re PR law for Motion for Summary Judgment 2.300 287.50

Total Fees 16,687.50

Time Summary

Timekeeper Hours Rate Amount

NN 43.100 375.00 16,162.50

RR 4.200 125.00 525.00

Total Fees 16,687.50

00004 - Mediation

Professional Services

Date Timekeeper Description Hours Amount

01-12-2018 NN Read update re new developments with fiscal plan relevant to 

COFINA Agent and mediation sent by WF&G

0.100 37.50

01-15-2018 NN Review draft letter to Judge Housser 0.200 75.00

01-15-2018 NN Correspond with B. Whyte and co-counsel re draft of letter to 

Judge Housser

0.100 37.50

01-17-2018 NN Read updates sent by WF&G re SUT and COFINA relevant to 

mediation

0.200 75.00

01-17-2018 NN Correspond with B. Whyte re January 19 FOMB's hearing 0.500 187.50

01-17-2018 NNC Confer with A. Charles (associate) re FOMB hearing and 

information relevant to COFINA Agent and mediation

0.200 No Charge

01-19-2018 NN Attend via live stream the FOMB session on liquidity and draft 

Memorandum re relevant issues to the COFINA Agent and 

mediation

5.200 1,950.00

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Date Timekeeper Description Hours Amount

01-19-2018 NN Read report sent by WF&G re FOMB's hearing 0.200 75.00

01-22-2018 NN Read article re new developments with FOMB and AAFAF sent 

by B. Whyte relevant to mediation

0.200 75.00

01-22-2018 NN Correspond with B. Whyte and co-counsel re Governor's 

message and implications relevant to COFINA Agent and 

mediation

0.300 112.50

01-22-2018 NN Watch Governor's message at B. Whyte's request to asses any 

possible impact to Title III cases and COFINA-GO dispute

0.200 75.00

01-22-2018 NN Draft Memorandum summarizing Governor's message 0.300 112.50

01-23-2018 NN Study analysis as to possible impact of PREPA's privatization on 

Title III cases

0.300 112.50

01-25-2018 NN Review of PR new Fiscal Plan sent by B. Whyte and assess 

implications to GO-COFINA dispute

0.800 300.00

01-25-2018 NN Read various updates re new developments re Fiscal Plan 

relevant to the COFINA - GO dispute and mediation

0.300 112.50

01-26-2018 NN Read various news reports and updates sent by B. Whyte re 

debt negotiation relevant to COFINA Agent and mediation

0.600 225.00

01-29-2018 NN Revise draft of Motion expanding mediation scope and immunity 0.300 112.50

01-29-2018 NN Correspond with co-counsel and B. Whyte re Motion expanding 

mediation scope and immunity

0.300 112.50

01-30-2018 NN Read various updates and reports re Bondholders' claims and 

other developments in PR relevant to mediation and the COFINA 

Agent sent by B. Whyte

0.400 150.00

01-31-2018 NN Read reports re SUT and TSA sent by WF&G relevant to 

mediation

0.200 75.00

01-31-2018 NN Weekly conference call with B. Whyte and co-counsel re strategy 

for mediation

0.500 187.50

Total Fees 4,200.00

Time Summary

Timekeeper Hours Rate Amount

NN 11.200 375.00 4,200.00

NNC 0.200 0.00 0.00

Total Fees 4,200.00

00005 - Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

01-02-2018 RR Work on December Fee Statement 1.300 162.50

01-02-2018 NN Work on December Fee Statement 0.900 337.50

01-03-2018 NN Read and analyze Memorandum from Fee Examiner on status 

report and evaluation of Interim Fee Applications

0.200 75.00

01-11-2018 RR Work on December Fee Statement and update list of previous 

statements and payments

0.500 62.50

01-11-2018 NN Final revision to December Fee Statement 0.300 112.50

01-29-2018 NN Correspond with co-counsel and B. Whyte re draft of Stipulated 

Disclosure Agreement and Protective Order sent by Fee 

Examiner

0.300 112.50

01-31-2018 NN Execute Stipulate Disclosure Agreement sent by Fee Examiner 

and correspond with Fee Examiner re same

0.200 75.00

Total Fees 937.50

Time Summary

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Timekeeper Hours Rate Amount

NN 1.900 375.00 712.50

RR 1.800 125.00 225.00

Total Fees 937.50

00006 - Fee Application Retention and Objections

Professional Services

Date Timekeeper Description Hours Amount

01-18-2018 NN Correspond with A. Lopez (local counsel to AAFAF) re no 

Objection Statement

0.200 75.00

Total Fees 75.00

Time Summary

Timekeeper Hours Rate Amount

NN 0.200 375.00 75.00

Total Fees 75.00

00007 - Budget

Professional Services

Date Timekeeper Description Hours Amount

01-03-2018 NN Correspond with B. Whyte re January 2018 budget 0.100 37.50

01-03-2018 RR Obtain required information to prepare budget for January 2018 

and assist with calculations and estimates

1.200 150.00

01-03-2018 NN Prepare budget and staffing plan for January 2018 0.900 337.50

01-25-2018 RR Gather information for preparing February 2018 budget and work 

with budget

1.800 225.00

01-25-2018 NN Work on February 2018 budget 0.800 300.00

Total Fees 1,050.00

Time Summary

Timekeeper Hours Rate Amount

NN 1.800 375.00 675.00

RR 3.000 125.00 375.00

Total Fees 1,050.00

00008 - Discovery/Facts Analysis

Professional Services

Date Timekeeper Description Hours Amount

01-03-2018 NN Correspond with S. Hussein re draft of COFINA Agent's 

responses to Interrogatories

0.200 75.00

01-03-2018 NN Revise draft of COFINA Agent's responses to Interrogatories 0.200 75.00

01-05-2018 NN Read various motions in support of discovery of Fiscal Plan 

development materials

0.300 112.50

01-06-2018 NN Read Joint Report filed by Ambac, the FOMB and other parties 

as to Rule 2004 discovery

0.100 37.50

01-10-2018 NN Correspond with S. Hussein re deposition Subpoenas to J. 

Pagan and J. Irizarry

0.500 187.50

01-10-2018 NN Correspond with A Gouzoules re deposition Subpoenas 0.200 75.00

01-10-2018 NN Review draft of Rule 30b6 deposition notices 0.300 112.50

01-10-2018 NN Correspond with S. Hussein re drafts of Rule 30b6 deposition 

notices

0.200 75.00

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Date Timekeeper Description Hours Amount

01-10-2018 NN Reivse deposition notices to Jose Pagan and to J. Irizarry and 

corresponding deposition Subpoenas

0.400 150.00

01-10-2018 NN Confer with R. Rivera (paralegal) to instruct as to deposition 

Subpoenas to be served in PR

0.200 75.00

01-10-2018 RR Confer with N. Navarro as to deposition Subpoenas to be served 

in PR

0.200 25.00

01-10-2018 RR Review, complete and prepare for service deposition Subpoenas 

to J. Pagan and J. Irizarry

0.500 62.50

01-10-2018 RR Internet search to obtain addresses for serving deposition 

Subpoenas to J. Pagan and J. Irizarry

0.600 75.00

01-10-2018 RR Confer with process server to instruct as to service of deposition 

Subpoenas to J. Pagan and J Irizarry

0.500 62.50

01-11-2018 RR Confer with Irizarry's assistant re serving deposition Subpoena to 

Irizarry

0.200 25.00

01-11-2018 RR Confer with process server re status of service of deposition 

Subpoena to Irizarry

0.200 25.00

01-11-2018 RR Various inquiries and emails to find out where process server 

can serve deposition Subpoenas upon Irizarry and Pagan

1.300 162.50

01-11-2018 NN Confer with Pagan's representative to service of deposition 

Subpoena

0.200 75.00

01-11-2018 NN Correspond with S. Hussein (WF&G) re status of service of 

deposition Subpoenas and alternatives

0.300 112.50

01-11-2018 NN Review process server certificate of service to Pagan 0.100 37.50

01-11-2018 NN Correspond with J. Pagan re service of deposition Subpoena 0.200 75.00

01-11-2018 NN Confer with Irizarry's secretary to coordinate service of 

deposition Subpoena to Irizarry

0.100 37.50

01-11-2018 NN Correspond with Irizarry re service of deposition Subpoena 0.100 37.50

01-11-2018 NN Confer with process server to instruct as to service of deposition 

Subpoena to Irizarry

0.200 75.00

01-11-2018 NN Confer with Irizarry re deposition Subpoena 0.200 75.00

01-11-2018 NN Correspond with S. Hussein (WF&G) re Irizarry's deposition 0.100 37.50

01-12-2018 RR Review process server's certificate re service of deposition 

Subpoena to Irizarry

0.100 12.50

01-12-2018 NN Read process server's certificate re service of deposition 

Subpoena to Irizarry

0.100 37.50

01-12-2018 NN Correspond with S. Hussein (WF&G) re deposition Subpoena to 

Irizarry and pending issues with service of Pagan's Subpoena

0.200 75.00

01-14-2018 NN Correspond with S. Hussein (WF&G) re Pagan's and Irizarry's 

depositions

0.200 75.00

01-15-2018 NN Correspond with Irizarry-Herrans as to his availability for 

deposition

0.200 75.00

01-15-2018 NN Correspond with Casillas (local counsel to Commonwealth 

Agent) re pending depositions

0.200 75.00

01-15-2018 NN Correspond with S. Hussein (WF&G) re pending depositions 0.300 112.50

01-16-2018 NN Correspond with S. Hussein (WF&G) re Pagan's deposition 0.100 37.50

01-16-2018 NN Confer with J. Irizarry to coordinate his deposition 0.200 75.00

01-16-2018 NN Correspond with S. Hussein re Mr. Irizarry's deposition 0.500 187.50

01-16-2018 NN Correspond with J. Casillas (local counsel for Commonwealth 

Agent) to coordinate Irizarry's deposition

0.300 112.50

01-16-2018 NN Confer with J. Casillas to coordinate Irizarry's deposition 0.200 75.00

01-16-2018 NN Review of National Public Finance Guarantee Corp.'s Motion for 

R 2004 Order authorizing limited discovery issues relevant to 

COFINA Agent

0.200 75.00

01-17-2018 NN Correspond with Casillas (local counsel to Commonwealth 

Agent) re Irizarry's deposition

0.100 37.50

01-18-2018 NN Correspond with Casillas (local counsel to Commonwealth 0.100 37.50

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Date Timekeeper Description Hours Amount

Agent) re Irizarry's deposition

01-18-2018 NN Read Order authorizing discovery 0.100 37.50

01-18-2018 NN Read letter from counsel to RSM ROC re Subpoena for 

production of documents in AP against COFINA Agent, 

Subpoena and attachments to letter

0.400 150.00

01-18-2018 NN Correspond with S. Hussein re letter from counsel to RSM ROC 

re production of documents

0.100 37.50

01-19-2018 NN Confer with R. Widmann, counsel for Santander, re Santander's 

production of documents

0.100 37.50

01-19-2018 NN Correspond with R. Widmann, counsel for Santander re 

Santander's production of documents

0.200 75.00

01-19-2018 NN Correspond with S. Hussein (WF&G) re Santander's production 

of documents

0.200 75.00

01-19-2018 NN Correspond with S. Hussein re status of Irizarry's deposition 0.100 37.50

01-19-2018 NN Correspond with Irizarry re status of his deposition 0.100 37.50

01-19-2018 NN Read Non-party KPMG Emergency Motion to Quash deposition 

Subpoena served by Commonwealth Agent in AP against 

COFINA Agent and its exhibits

0.300 112.50

01-19-2018 NN Read Commonwealth Agent's Limited Objection to Non-party 

KPMG's Emergency Motion to Quash deposition Subpoena

0.100 37.50

01-19-2018 NN Read order re KPMG Emergency Motion to Quash in AP against 

COFINA Agent

0.100 37.50

01-19-2018 NN Read letter from Widmann, counsel for Santander, re 

Santander's production of documents

0.100 37.50

01-22-2018 NN Call from Calaf re Pagan's deposition Subpoena 0.200 75.00

01-23-2018 NN Read Commonwealth Agent's and KPMG's Joint Status Report 

re KPMG's Motion to Quash deposition Subpoena

0.100 37.50

01-23-2018 NN Read Brief filed by FOMB, Commonwealth and AAFAF in 

Opposition to demand for production and use of fiscal plan 

development materials

0.200 75.00

01-23-2018 NN Correspond with A. Gouzoules (WF&G) re new deposition 

Subpoenas to be served in PR

0.200 75.00

01-24-2018 NN Read Order re KPMG's Motion to Quash Subpoena in AP 

against COFINA Agent

0.100 37.50

01-25-2018 NN Read Notice of Subpoena Duces Tecum from Commonwealth 

Agent to Lehman Brothers Holdings for production of 

documents, Subpoena and list of documents requested in AP 

against COFINA Agent

0.300 112.50

01-25-2018 NN Read Notice of Subpoena Duces Tecum from Commonwealth 

Agent to Goldman Sachs for production of documents, 

Subpoena and list of documents requested in AP against 

COFINA Agent

0.200 75.00

01-25-2018 NN Read KPMG's Motion to Withdraw Emergency Motion to Quash 

Deposition Subpoena in AP against COFINA Agent

0.100 37.50

01-29-2018 NN Telephone call from A. Calaf re Pagan's deposition Subpoena 0.100 37.50

01-30-2018 NN Correspond with A. Gouzoules re expert's deposition Subpoena 0.100 37.50

01-30-2018 NN Revise draft of expert's deposition Subpoena 0.200 75.00

01-30-2018 NN Read Ambac's Notices of depositions of A. Wolfe and D. Mondell 0.200 75.00

01-30-2018 NN Read Joint Motion to Hold in abeyance Motion for entry of order 

rule 2004 order authorizing limited discovery

0.100 37.50

01-30-2018 NN Read Order holding in abeyance Motion for entry rule 2004 

authorizing limited discovery

0.100 37.50

01-30-2018 NN Read GDB's Opposition to FGIC's Joinder ot National's Rule 

2004 Motion

0.100 37.50

01-30-2018 NN Correspond with S. Hussein (WF&G) re Pagan's and Irizarry's 

depositions

0.200 75.00

01-31-2018 NN Read Order re GDB's Opposition to FGIC's Joinder to National's 0.100 37.50

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Date Timekeeper Description Hours Amount

Rule 2004

Total Fees 4,762.50

Time Summary

Timekeeper Hours Rate Amount

NN 11.500 375.00 4,312.50

RR 3.600 125.00 450.00

Total Fees 4,762.50

Total for this Invoice 28,129.52

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(Itemized expenses for the period of January 1, 2018 through January 31, 2018) 

Date Expense Amount Description

1/10/18 Deposition fees and 

mileage for deponent

$45.00 Deposition fees and mileage for deponent

1/10/18 Copies $13.70 In house copies

1/12/18 Process server fees $50.00 Process server fees for deposition Subpoena

1/29/18 Messenger $8.32 Messenger service to the Offices of Reichard & 

Calaf

1/30/18 Pro hac vice fees $300.00 Application for admission pro hac vice for R. 

Pfister

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EXHIBIT 5

COMPARABLE COMPENSATION DISCLOSURES

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Category of Timekeeper

(Using categories already 

maintained by the Firm)

Blended Hourly Rate

Billed*

Firm for Preceding Year

Billed 

In this Application

Partners $275.00 $375.00

Counsel/Associates $240.00 $250.00

Paralegal $125.00 $125.00

Aggregated $265.00 $337.36

*The stated blended rate reflects actual rates charged by Navarro-Cabrer during 2017 on matters that are 

not comparable to the Title III cases in terms of their demands, complexity and importance. The hourly 

rates of Navarro-Cabrer in the Title III Cases are commensurate with the complexity, importance, and 

nature of the problems, issues, and tasks addressed in these cases, and with the demands imposed by the 

expedited nature and extraordinary environment—legal and practical—of these proceedings. NavarroCabrer’s hourly rates in this matter are comparable to the hourly rates charged in the Title III Cases by 

comparably-skilled local counsel and substantially lower than those fees charged in the competitive 

national legal market. In addition, the small size of Navarro-Cabrer Law Offices guarantees efficiency 

and precludes duplication of effort or overlapping billing by multiple attorneys. 

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EXHIBIT 6

BUDGET AND STAFFING PLAN

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from October 1, 2017 through October 31, 2017

Budget 

For this period we estimate a total of 64.00 hours at an average hourly rate (attorneys and 

paralegals) of $ 335.00, for a total of $ 21,440.00 mainly concentrated in litigation, 

mediation and discovery. This is just an estimate, which may vary according to the work 

delegated to me by the lead counsel (WF&G) and the special municipal bankruptcy counsel 

(KTB&S).

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

TOTAL 2

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from November 1, 2017 through and including November 30, 2017

Budget 

For this period we estimate a total of 95.00 hours at an average hourly rate of $361.85, for a 

total of $ 34,375.75, mainly concentrated in litigation and discovery.

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

TOTAL 2

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from December 1, 2017 through December 31, 2017

Budget 

For this period we estimate a total of 100.00 hours at an average hourly rate of $ 330.00, for 

a total of $ 33,000.00 mainly concentrated in litigation, mediation, discovery and the 

preparation of the Interim Fee Application. This is just an estimate, which may vary 

according to the work delegated to me by the lead counsel (WF&G) and the special 

municipal bankruptcy counsel (KTB&S).

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

TOTAL 2

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Nilda M. Navarro-Cabrer

d/b/a Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from January 1, 2018 through and including January 31, 2018

This Budget and Staffing Plan is an estimate based on currently available information. The amount of 

Navarro-Cabrer’s actual fees may vary materially from the Budget based on future developments and 

tasks delegated to Navarro-Cabrer by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent

Budget 

Project Category Budgeted Hours Budgeted Fees

0001 – Litigation/Adversary Proceedings 60.00 $20,000.00

0002 – Case Administration 0 -

0003 – Meetings/Creditor Communications 5.00 $1,875.00

0004 – Mediation/Negotiations 15.00 $5,625.00

0005 – Fee Application and Retention 4.00 $750.00

0006 – Fee Application and Retention Objections 3.00 $625.00

0007 – Budget 3.00 $625.00

0008 – Discovery/Fact Analysis 25.00 $8,125.00

0009 – Non-Working Travel 0.00 -

Total: 116 $37,625.00

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

Total: 2

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