EXHIBIT C 

BUDGET AND STAFFING PLAN 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 1 of 13
EXHIBIT C-1 

BUDGET (FEBRUARY 2023) 

Period Covered: February 1, 2023 through February 28, 20231

U.S. Trustee Task Code and Project Category Estimated Hours for 

Period February 1, 

2023 through 

February 28, 2023 

B110 Case Administration 30 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 15 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 20 

B155 Court Hearings 40 

B160 Employment / Fee Applications 50 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 15 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 20 

B191 General Litigation 50 

B195 Non-Working Travel2 0 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 2 of 13
2 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 40 

B320 Plan and Disclosure Statement 400 

B420 Restructurings 200 

TOTAL HOURS 908 

TOTAL ESTIMATED FEES $1,094,140.003

MINUS 20% REDUCTION4 ($218,828.00) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $875,312.00 

 

2

 The firm charges one-half a timekeeper’s normal billing rate for any time incurred on account of non-working 

travel. 

3 The Total Estimated Fees are calculated based on a $1,205 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from February 1, 2023 through February 28, 2023. 

The impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-ofthe-case reduction, would be approximately $964. 

4 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 3 of 13
BUDGET (MARCH 2023) 

Period Covered: March 1, 2023 through March 31, 20231

U.S. Trustee Task Code and Project Category Estimated Hours for 

Period March 1, 

2023 through 

March 31, 2023 

B110 Case Administration 30 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 15 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 20 

B155 Court Hearings 40 

B160 Employment / Fee Applications 50 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 15 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 20 

B191 General Litigation 50 

B195 Non-Working Travel2 0 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2

 The firm charges one-half a timekeeper’s normal billing rate for any time incurred on account of non-working 

travel. 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 4 of 13
2 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 40 

B320 Plan and Disclosure Statement 500 

B420 Restructurings 100 

TOTAL HOURS 908 

TOTAL ESTIMATED FEES $1,094,140.003

MINUS 20% REDUCTION4 ($218,828.00) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $875,312.00 

 

 

3 The Total Estimated Fees are calculated based on a $1,205 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from March 1, 2023 through March 31, 2023. The 

impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at this 

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-of-thecase reduction, would be approximately $964. 

4 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 5 of 13
BUDGET (APRIL 2023) 

 

Period Covered: April 1, 2023 through April 30, 20231

U.S. Trustee Task Code and Project Category Estimated Hours for 

Period April 1, 2023 

through April 30, 

2023 

B110 Case Administration 30 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 15 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 20 

B155 Court Hearings 40 

B160 Employment / Fee Applications 50 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 15 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 20 

B191 General Litigation 50 

B195 Non-Working Travel2 0 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2

 The firm charges one-half a timekeeper’s normal billing rate for any time incurred on account of non-working 

travel. 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 6 of 13
2 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 40 

B320 Plan and Disclosure Statement 500 

B420 Restructurings 100 

TOTAL HOURS 908 

TOTAL ESTIMATED FEES $1,094,140.003

MINUS 20% REDUCTION4 ($218,828.00) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $875,312.00 

 

 

3 The Total Estimated Fees are calculated based on a $1,205 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from April 1, 2023 through April 30, 2023. The 

impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at this 

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-of-thecase reduction, would be approximately $964. 

4 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 7 of 13
BUDGET (MAY 2023) 

Period Covered: May 1, 2023 through May 31, 20231

U.S. Trustee Task Code and Project Category Estimated Hours for 

Period May 1, 2023 

through May 31, 

2023 

B110 Case Administration 30 

B112 General Creditor Inquiries 5 

B113 Pleadings Review 15 

B120 Asset Analysis and Recovery 0 

B130 Asset Disposition 0 

B140 Relief from Stay / Adequate Protection Proceedings 5 

B150 Meetings of Creditors’ Committee and Communications 

with Creditors 20 

B155 Court Hearings 40 

B160 Employment / Fee Applications 50 

B161 Budgeting (Case) 1 

B165 Fee and Employment Applications of Other Professionals 15 

B170 Fee and Employment Objections 2 

B180 Avoidance Action Analysis 0 

B185 Assumption / Rejection of Leases and Contracts 0 

B190 Other Contested Matters 20 

B191 General Litigation 200 

B195 Non-Working Travel2 0 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2

 The firm charges one-half a timekeeper’s normal billing rate for any time incurred on account of non-working 

travel. 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 8 of 13
2 

B210 Debtors’ Financial Information and Operations/Fiscal 

Plan 5 

B220 Employee Benefits/Pensions 5 

B230 Financing / Cash Collections 0 

B231 Security Document Analysis 0 

B260 Meetings of and Communications with Debtors/Oversight 

Board 5 

B261 Investigations 0 

B310 Claims Administration and Objections 40 

B320 Plan and Disclosure Statement 500 

B420 Restructurings 100 

TOTAL HOURS 1058 

TOTAL ESTIMATED FEES $1,274,890.003

MINUS 20% REDUCTION4 ($254,978.00) 

TOTAL ESTIMATED FEES (NET OF REDUCTION) $1,019,912.00 

 

3 The Total Estimated Fees are calculated based on a $1,205 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from May 1, 2023 through May 31, 2023. The 

impact of the agreed-upon 20% end of the case write-off on the blended hourly rate cannot be calculated at this 

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% end-of-thecase reduction, would be approximately $964. 

4 For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of Paul 

Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to attain the 20% 

overall reduction in total fees in connection with the final fee application process. In other words, Paul Hastings 

could designate its entire final fee application as the source of this reduction (which it does not intend to do) or 

a combination of reductions across other fee applications (which is one more likely scenario). 

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 9 of 13
EXHIBIT C-2 

STAFFING PLAN (FEBRUARY 2023) 

Period Covered: February 1, 2023 to February 28, 20231

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period 

February 1, 2023 

through 

February 28, 2023 

Average hourly rate 

for period February 1, 

2023 through 

February 28, 2023 (net 

of 20% reduction)2

Partner 7 $1,737 $1,390 

Counsel 6 $1,437 $1,150 

Associate 8 $1,064 $851 

Paraprofessionals 5 $350 $280 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 10 of 13
STAFFING PLAN (MARCH 2023) 

Period Covered: March 1, 2023 to March 31, 20231

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period March 1, 

2023 through 

March 31, 2023 

Average hourly rate 

for period March 1, 

2023 through 

March 31, 2023 (net of 

20% reduction)2

Partner 7 $1,737 $1,390 

Counsel 6 $1,437 $1,150 

Associate 8 $1,064 $851 

Paraprofessionals 5 $350 $280 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 11 of 13
STAFFING PLAN (APRIL 2023) 

Period Covered: April 1, 2023 to April 30, 20231

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period April 1, 

2023 through 

April 30, 2023 

Average hourly rate 

for period April 1, 

2023 through April 30, 

2023 (net of 20% 

reduction)2

Partner 7 $1,737 $1,390 

Counsel 6 $1,437 $1,150 

Associate 8 $1,064 $851 

Paraprofessionals 5 $350 $280 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 12 of 13
STAFFING PLAN (MAY 2023) 

Period Covered: May 1, 2023 to May 31, 20231

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period May 1, 

2023 through 

May 31, 2023 

Average hourly rate 

for period May 1, 2023 

through May 31, 2023 

(net of 20% reduction)2

Partner 8 $1,737 $1,390 

Counsel 7 $1,437 $1,150 

Associate 8 $1,064 $851 

Paraprofessionals 6 $350 $280 

 

1

 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed 

during the budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all 

adversary proceedings in which the Committee has intervened and/or sought to intervene will only involve 

briefing and hearings on motions to dismiss. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the 

Committee may need to respond to motions that are not and cannot be anticipated. At this time, the proposed 

budget is speculative. 

2 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be calculated at 

this time. However, for illustrative purposes only, we have provided the average hourly rate, after accounting 

for the 20% end-of-the-case reduction.

Case:17-03283-LTS Doc#:24747-3 Filed:07/14/23 Entered:07/14/23 19:01:20 Desc:

Exhibit C Page 13 of 13