1

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

----------------------------------------------------------------------- x

In re: :

:

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III

:

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

:

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

: 

Debtors.

2

:

----------------------------------------------------------------------- x

THIRD INTERIM APPLICATION OF CASILLAS, SANTIAGO & TORRES, LLC, 

LOCAL COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED CREDITORS, 

FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES 

FOR THE PERIOD FROM FEBRUARY 1, 2018 THROUGH MAY 31, 2018

COVER SHEET3

Name of Applicant: Casillas, Santiago & Torres, LLC

Authorized to Provide Professional Services to: Official Committee of Unsecured Creditors of all 

Title III Debtors (other than COFINA) (the “Committee”)

Date of retention: July 20, 2017

Period for which compensation and reimbursement is sought: February 1, 2018 through May 31, 

2018

Amount of interim compensation sought as actual, reasonable, and necessary: $294,120.50

 

2 The Debtors in these title III cases, along with each Debtor’s respective title III case number listed as a 

bankruptcy case number due to software limitations 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) 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), (iii) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567 

(LTS)) (Last Four Digits of Federal Tax ID: 3808), (iv) Puerto Rico Sales Tax Financing Corporation (“COFINA”)

(Bankruptcy Case No. 17-BK-3284 (LTS)) (Last Four Digits of Federal Tax ID: 8474); and (v) Puerto Rico

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780) (Last Four Digits of Federal Tax ID:

3747).

3 This form has been designed to incorporate many of the requirements of PROMESA §316 and ¶C2.1 and Exhibit E 

to the Appendix B Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed 

under United States Code by Attorneys in Larger Chapter 11 Cases (“US Trustee Guidelines”).

Hearing Date: November 7, 2018 at 8:30 a.m. (EST) / 9:30 a.m. (AST)

Objection Deadline: August 6, 2018 at 4:00 p.m. (EST) / 4:00 p.m.(AST)

(AST)

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Amount of interim expense reimbursement sought as actual, reasonable, and necessary: 

$12,052.09

Are your fee or expense totals different from the sum of previously-served monthly statements?

_ Yes X No

If there is any discrepancy, please explain it in the text of the attached fee application or in a 

footnote to this cover sheet. 

Blended rate in this application for all attorneys: $196.10/hour4

Blended rate in this application for all timekeepers: $195.82/hour

This is an interim application.

The total time expended for fee application preparation for the Interim Fee Period is 

approximately 13 hours, and the corresponding compensation requested is approximately 

$2,510.00.

MONTHLY FEE REQUESTS TO DATE

Date 

Submitted

Monthly 

Period 

Covered

Fees Requested 

Fees (90%)

Requested 

Expenses 

(100%)

Fees Paid Expenses 

Paid

10% Fee 

Holdback

First Interim Fee Period (July 20, 2017 through August 31, 2017)

12/15/2017

07/20/2017 

-

08/31/2017

$169,523.00 $152,570.70 $6,320.62 $173,440.00 $6,320.62 $0.00 

Total $169,523.00 $152,570.70 $6,320.62 $173,440.00 $6,320.62 $0.00 

Second Interim Fee Period (September 1, 2017 through January 31, 2018)

03/19/2018

09/01/2017 

-

01/31/2018

$444,593.50 $400,134.15 $21,160.13 $400,122.00 $21,160.13 $44,474.20 

Total $444,593.50 $400,134.15 $21,160.13 $400,122.00 $21,160.13 $44,474.20 

Third Interim Fee Period (February 1, 2018 through May 31, 2018)

 

4 Please note that the average hourly rate is significantly lower due to CST Law’s agreement to review documents on 

a fixed hourly rate of $100.00 per hour. The usual rate for Junior Partners and Counsel is $240.00, for Senior 

Associates is $200.00 and for Associates is $170.00.

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06/13/2018

02/01/2018 

-

02/28/2018

$93,937.50 $84,543.75 $1,172.10 $0.00 $0.00 $9,393.75 

06/14/2018

03/01/2018 

-

03/31/2018

$75,088.00 $67,579.20 $4,782.51 $0.00 $0.00 $7,508.80 

07/12/2018

04/01/2018 

-

05/31/2018

$125,095.00 $112,585.50 $6,097.48 $0.00 $0.00 $12,509.50 

Total $294,120.50 $264,708.45 $12,052.09 $0.00 $0.00 $29,412.05 

Prior Interim Fee Applications & Adjustments:

Period Requested Approved

Date 

[Docket 

No.]

Interim Fee 

Period (“IFP”) 

Covered

Fees Expenses Fees Expenses

12/15/2017 

[Docket No. 

2079]

07/21/2017 -

08/31/2017 $169,523.00 $6,320.62 $173,440.00 $6,320.62 

03/19/2018 

[Docket No. 

2757]

09/01/2017 -

01/31/2018 $444,593.50 $21,160.13 $444,596.20 $21,160.13 

Total fees and expenses approved by interim orders to date: $618,036.20 $27,480.75 

Prior Interim or Monthly Fee PAYMENTS to date:

Period Requested Paid

Payment 

Received 

Date

Paid Interim 

Fee 

Application 

[Docket No.] 

or Monthy Fee 

Statement

Fees Expenses Fees Expenses

05/09/2018

12/15/2017 

[Docket No. 

2079]

$169,523.00 $6,320.62 $173,440.00 $6,320.62 

06/07/2018

03/19/2018 

[Docket No. 

2757]

$444,593.50 $21,160.13 $400,122.00 $21,160.13 

Total fees and expenses PAID to date: $573,562.00 $27,480.75 

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Number of professionals with time included in this application: 13

If applicable, number of professionals in this application not included in a staffing plan approved 

by the client: N/A

If applicable, difference between fees budgeted and compensation sought for this period: N/A

Are any timekeeper’s hourly rates higher than those charged and approved upon retention:5 No

 

5

If any timekeeper’s hourly rate has changed since the firm’s retention, the narrative portion of the fee application 

shall identify each timekeeper with an adjusted rate, the date and amount of the rate change, the reason for the change, 

and a statement that the client was notified and approved the rate change. 

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

----------------------------------------------------------------------- x

In re: :

:

THE FINANCIAL OVERSIGHT AND : PROMESA 

MANAGEMENT BOARD FOR PUERTO RICO, : Title III

:

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

:

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

: 

Debtors. :

----------------------------------------------------------------------- x

THIRD INTERIM APPLICATION OF CASILLAS, SANTIAGO & TORRES, LLC, 

LOCAL COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED CREDITORS, 

FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM FEBRUARY 1, 2018 THROUGH MAY 31, 2018

TABLE OF CONTENTS

Preliminary Statement......................................................................................................................3

Background......................................................................................................................................5

Compensation and Reimbursement Request ...................................................................................8

Summary of Services.....................................................................................................................10

General (Matter ID: 396-00002)............................................................................12

COFINA Dispute Analysis (Matter ID: 396-00003) .............................................13

Communications with Creditors / Website (other than Committee Members) 

(Matter ID: 396-00004)..........................................................................................17

PREPA (Matter ID: 396-00006)............................................................................18

ERS (Matter ID: 396-00008) .................................................................................19

Other Adversary Proceedings (Matter ID: 396-00009) .........................................19

Mediation (Matter ID: 396-00010)........................................................................20

Document Review (Matter ID: 396-00012)...........................................................20

GDB (Matter ID: 396-00013)................................................................................21

PBAPR (Matter ID: 396-00014)............................................................................21

Fee Application (Matter ID: 396-00015)...............................................................22

Actual and Necessary Disbursements............................................................................................22

Requested Compensation Should be Allowed...............................................................................23

Conclusion .....................................................................................................................................25

Hearing Date: November 7, 2018 at 9:30 a.m. (ET) / 8:30 a.m. (AST)

Objection Deadline: August 6, 2018 at 4:00 p.m. (ET) / 4:00 p.m. (AST)

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SUPPORTING DECLARATION, EXHIBITS AND SCHEDULE

Supporting Declaration of Juan J. Casillas-Ayala, Esq.

Exhibits

A. Customary and Comparable Compensation Disclosures with Fee Applications

B. Summary of Timekeepers Included in this Application for Fee Period

C. Budgets and Staffing Plans for Application Period

C-1. Budgets

C-2. Staffing Plans

D. Summary of Compensation Requested by Project Category as Compared to Budget

D-1. Summary of Compensation Requested by Project Category as Compared to 

Budget

Further Breakdown of Compensation Requested by Project Category and by 

Matter

D-2. Summary of Expenses by Category

E. Breakdown of Compensation and Expense Requested by Debtor

F. List of Professionals by Matter

G. Monthly Statements Covered in Application

Schedule

Proposed Order

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

Casillas, Santiago & Torres, LLC (“CST Law”), Local Counsel to the Official Committee 

of Unsecured Creditors of all title III Debtors (other than COFINA) (the “Committee”), for its

third application (the “Application”), pursuant to sections 316 and 317 of the Puerto Rico

Oversight, Management and Economic Stability Act of 2016 (“PROMESA”)6, section 503(b) of

title 11, United States Code (the “Bankruptcy Code”) as made applicable to these cases by

section 301(a) of PROMESA, Rule 2016 of the Federal Rules of Bankruptcy Procedure (the

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

Bankruptcy Court for the District of Puerto Rico (the “Local Rules”), for the interim allowance

of compensation for professional services performed by CST Law for the period from February

1, 2018 through and including May 31, 2018 (the “Interim Fee Period”), and for reimbursement 

of its actual and necessary expenses incurred during the Interim Fee Period, respectfully 

represents:

PRELIMINARY STATEMENT

1. CST Law has continued to perform these services in an economic, effective, and efficient 

manner commensurate with the complexity and importance of the issues involved. For example, 

the work performed by CST Law was carefully assigned to appropriate professionals or 

paraprofessionals according to the experience and level of expertise required for each particular 

task. Moreover, whenever possible, CST Law sought to minimize the costs of Paul Hastings’ 

services to the Committee by utilizing talented junior attorneys to handle the more routine aspects 

of the assignments. In addition, a small group of the same Paul Hastings attorneys was utilized 

for the vast majority of the work in these title III cases, to minimize the costs of intra-CST Law

 

6 References to PROMESA are references to 48 U.S.C. §§2101 et. seq.

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communication and education about the cases. Notably, as a general matter, no more than two 

CST Law attorneys (and often only one attorney) attended the various hearings and mediation 

sessions held during the Application Period, thereby minimizing not only the time billed on these 

hearings/sessions but also the cost of travel and lodging. 

2. CST Law respectfully submits that the services for which it seeks compensation in this

Application were necessary for and beneficial to the Committee, the Debtors, and their 

stakeholders, and were rendered to protect, preserve, and maximize the value for unsecured 

creditors during the pendency of these Title III cases. The results obtained to date have benefited 

not only the Committee but also the Debtors and their creditors. Accordingly, considering the 

nature and complexity of the Title III Cases, CST Law’s charges for professional services 

performed and expenses incurred are reasonable under applicable standards. For all these reasons,

CST Law respectfully requests that the Court grant the Application and allow interim 

compensation for professional services performed and reimbursement for expenses as requested.

3. This Application is consistent with the Interim Compensation Order (as defined below),

Local Rule 2016-1, and Appendix B of 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 Larger Chapter 11 Cases (the “U.S. Trustee Guidelines”). To the extent necessary,

CST Law requests a waiver for cause shown of any such requirement not met by this Application.

7

4. In accordance with the U.S. Trustee Guidelines, at the end of this Application are the 

following Exhibits:

• Exhibit A contains disclosures regarding “customary and comparable compensation.”

• Exhibit B contains a summary of CST Law’s timekeepers included in this Application.

 

7 The Committee and CST Law reserve all rights as to the relevance and substantive legal effect of the U.S. 

Trustee Guidelines with respect to any application for compensation in these cases.

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• Exhibit C-1 contains the budgets for CST Law’s services during the application period

• Exhibit C-2 contains the staffing plans for CST Law’s services during the 

application period

• Exhibit D-1 contains (a) a summary of the compensation requested as compared to 

the compensation budgeted for the firm’s services during the application period, 

and (b) a further breakdown of the compensation requested by project category 

and matter number.

• Exhibit D-2 contains a summary of the expenses requested by project. An itemized

schedule of all such expenses is included in CST Law’s monthly statements.

• Exhibit E contains a breakdown of compensation and expenses requested by Debtor.

• Exhibit F contains a list of the professionals providing services during the application 

period by matter.

• Exhibit G includes the monthly fee statements covered in this application. Attached is 

copy of the monthly statements for CST Law’s services during the Interim Fee Period,

which include detailed time records and narrative descriptions of the services rendered

by each timekeeper.

• Schedule 1 includes the proposed order approving this application.

BACKGROUND

5. On May 3, 2017, the Oversight Board commenced a title III case for the Commonwealth

of Puerto Rico by filing a voluntary petition for relief pursuant to section 304 (a) of PROMESA

(the “Commonwealth Title III Case”). Thereafter, the Oversight Board commenced a title III

case for each of COFINA, the Employees Retirement System of the Government of the

Commonwealth of Puerto Rico (“ERS Title III Case”), the Puerto Rico Highways and

Transportation Authority (“HTA Title III Case”), and the Puerto Rico Electric Power Authority

(“PREPA Title III Case”) (and together with the Commonwealth Title III Case, the “Title III

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Cases”).

8 By orders dated June 29, 2017 [Docket No. 537] and October 6, 2017 [Docket No. 

1417], the Court approved the joint administration of the Title III Cases.

6. On June 15, 2017, the Office of the United States Trustee for the District of Puerto

Rico (the “U.S. Trustee”) filed a Notice Appointing Creditors Committee for Unsecured

Creditors [Docket No. 338]. On July 21, 2017, the Committee selected CST Law as counsel to 

the Committee.

7. On August 4, 2017, the Committee filed an application to retain and employ CST Law,

effective July 21, 2017 [Docket No. 884] (the “Retention Application”). By order of this Court

entered October 6, 2017 [Docket No. 1414] (the “Retention Order”), incorporated herein by

this reference, CST Law’s retention as Local Counsel to the Committee was approved effective as 

of July 21, 2017.

8. On August 23, 2017, the Court entered the Order Setting Procedures for Interim

Compensation and Reimbursement of Expenses of Professionals (as amended, the Interim

Compensation Order”).

9

9. On August 25, 2017, the U.S. Trustee filed an Amended Notice of Appointment of Official

Committee of Unsecured Creditors [Docket No. 1171], which expanded the role of the Committee

to be the official committee for the HTA Title III Case, the ERS Title III Case, and the PREPA 

Title III Case.

10. The Retention Order authorized CST Law to be compensated on an hourly basis and

reimbursed for actual and necessary out-of-pocket expenses pursuant to Sections 316 and 317 of

PROMESA, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

 

8 Unless otherwise indicated, references to docket numbers shall be to the docket of the Commonwealth Title III 

Case.

9 The Interim Compensation Order was amended on November 8, 2017, to reflect certain changes requested by the 

Fee Examiner.

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The Retention Order further provides that “pursuant to Bankruptcy Code section 503(b)(1), made

applicable by PROMESA Section 301(a), the fees and expenses of CST Law under this Order

shall be an administrative expense.” In addition, as provided in the Retention Order, the

Oversight Board has consented to the Debtors’ payment of CST Law allowed fees and 

expenses.

11. On October 6, 2017, the Court entered the Order Pursuant to PROMESA Sections 316 and 

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

(the “Fee Examiner Order”) [Docket No. 1416]. The Court appointed Brady Williamson as 

the Fee Examiner in the Title III Cases.

12. On December 15, 2017, CST Law filed its first interim fee application with respect to the 

period from July 21, 2017 through August 31, 2017 [Docket No. 2079] (the “First Interim Fee 

Application”). In accordance with the Interim Compensation Order, CST Law received a 

preliminary report from the Fee Examiner with respect to the First Interim Fee Application. On 

March 7, 2018, the court approved the First Interim Fee Application, with the agreed-upon 

adjustments.

13. On March 19, 2018, CST Law filed its second interim fee application with respect to the 

period from September 1, 2017 through January 31, 2018 [Docket No. 2757] (the “Second Interim 

Fee Application”). In accordance with the Interim Compensation Order, CST Law received a 

preliminary report from the Fee Examiner with respect to the Second Interim Fee Application. On 

March 7, 2018, the court approved the Second Interim Fee Application.

14. On June 6, 2018, the Court enter the Second Amended Order Setting Procedures for

Interim Compensation and Reimbursement of Expenses of Professionals (as amended, the Second 

Interim Compensation Order”).

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15. This is CST Law’s third interim fee application, covering the period from February 1, 

2018 through May 31, 2018. All services for which compensation is requested were performed

for or on behalf of the Committee.

COMPENSATION AND REIMBURSEMENT REQUEST

16. By this Application, CST Law seeks from the Debtors (a) compensation for professional

services rendered to the Committee during the Interim Fee Period in the aggregate amount of 

$294,120.50; and (b) expense reimbursements in the aggregate amount of $12,052.09. These

amounts are allocated among the Commonwealth Title III Case, the HTA Title III Case, the ERS 

Title III Case, and the PREPA Title III Case, as follows:

Application Period Fees Expenses Total

Commonwealth Title III Case $252,854.00 $12,051.99 $264,905.99 

PREPA Title III Case $20,500.50 $0.10 $20,500.60 

HTA Title III Case $1,449.00 $0.00 $1,449.00 

ERS Title III Case $19,317.00 $0.00 $19,317.00 

Total $294,120.50 $12,052.09 $306,172.59 

16. The Committee has approved the amounts requested by CST Law for services performed and

expenses incurred in each of the monthly statements submitted that were or are hereby being 

submitted concurrently to, among others, the Oversight Board, AAFAF, the Fee Examiner, and

the U.S. Trustee, during the Interim Fee Period.10

17. As of today, CST Law has not been paid any amounts for which it requests payment 

pursuant to this Fee Application.

 

10 CST Law began submitting budgets in the month of January 2018. Further, due to the passing of Hurricane María 

and its impact to CST Law’s operation, CST Law was unable to submit its billing for the Interim Fee until this date. 

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18. By this Application, CST Law requests payment of all outstanding fees and expenses 

for services rendered during the Interim Fee Period.

19. There is no agreement or understanding between CST Law and any other person other

than the attorneys, employees, and staff of CST Law, for the sharing of compensation to be 

received for services rendered in these cases.

20. CST Law maintains computerized records, in the form of monthly statements, of the time

spent by all of CST Law’s attorneys and paraprofessionals in connection with its 

representation of the Committee. The monthly statements are in the same form regularly used by 

CST Law to bill its clients for services rendered, and include the date that the services were 

rendered, a detailed, contemporaneous narrative description of the services provided, the amount 

of time spent for each service, and the designation of the professional who performed the service.

21. The fees charged by CST Law in the Title III Cases are billed in accordance with its

existing billing rates and procedures in effect during the Interim Fee Period. The rates CST

Law charges for the services rendered by its professionals and paraprofessionals in the Title III 

Cases are comparable to the rates CST Law charges for professional and paraprofessional services

rendered in comparable non-bankruptcy related matters. Moreover, when CST Law’s 

professionals and paraprofessionals work on non-bankruptcy matters, the firm generally charges 

their standard rate. Such fees are reasonable based on the customary compensation charged by 

comparably skilled practitioners in comparable non-bankruptcy cases in the Puerto Rico legal 

market.

22. CST Law’s rates are set at a level designed to fairly compensate CST Law for the work

of its attorneys and paraprofessionals to cover fixed and routine overhead expense. CST Law

operates in the Puerto Rico legal services market in which rates are driven by multiple factors

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relating to the individual lawyer, their area of specialization, the firm’s expertise, performance and

reputation, the nature of the work involved, and other factors. Accordingly, CST Law set its

rates for attorneys and paraprofessionals within the firm by reference to market information and

market adjustments by firms considered to be industry peers. Based on this and the reviews of 

contemporaneous time records and fee applications filed in other cases, CST Law endeavors to set

the hourly rates for its attorneys and paraprofessionals at levels comparable to those of its principal 

competitor firms.

23. CST Law’s professional services during the Interim Fee Period required an aggregate

expenditure of 1,502.00 recorded hours by CST Law’s attorneys and paraprofessionals, broken

down as follows: partners (551.30 hours), junior partners (37.60 hours), counsel (32.60 hours), 

senior associates (197.60 hours), associates (678.80 hours), and paraprofessionals (4.10 hours).

During the Interim Fee Period, CST Law’s billing rates for attorneys rendering services in this 

matter ranged from $170.00 to $270.00 per hour. However, it should be noted that almost 15% of 

the mentioned time represents time incurred in the First Level Review of documents produced in 

connection with Commonwealth-COFINA Dispute, for which CST Law agreed to charge a 

significantly reduced blended rate of $100.00.

24. To the extent that time or disbursement charges for services rendered or disbursements

incurred relate to the Interim Fee Period but were not processed before the preparation of

this Application, or CST Law has for any other reason not sought compensation or reimbursement

with respect to such services or expenses, CST Law reserves the right to request additional

compensation for such services, and reimbursement of such expenses, in a supplemental or future

application.

SUMMARY OF SERVICES

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25. During the Interim Fee Period, CST Law assisted and advised the Committee on a regular

basis regarding legal matters relating to the restructuring of the Debtors, including related 

adversary proceedings, and all other matters arising in the performance of the Committee’s 

duties. In addition, CST Law has prepared various motions, applications, proposed orders, and 

other pleadings submitted to the Court for consideration, and has performed the necessary 

professional services that are described below and in the monthly statements attached hereto as

Exhibit F.

11 For ease of reference and transparency purposes, CST Law created several matter

numbers for its representation of the Committee. The matter numbers are divided by Debtor

and/or large tasks the Committee undertook, as follows:

Matter ID Matter Name

396-00002 General

396-00003 COFINA Dispute Analysis 

396-00004 Communications w/ Creditors/ Website 

(other than Committee Members)

396-00005 Plan Fiscal Analysis

396-00006 PREPA

396-00007 HTA

396-00008 ERS

396-00009 Other Adversary Proceedings

396-00010 Mediation

396-00011 GO Bond Debt Issues

396-00012 Document Review

 

11 The description of services in this Application is limited to those matters in which CST Law provided 5 or more 

hours of service during the Application Period.

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396-00013 GDB

396-00014 PBAPR

396-00015 Fee Application

I. General (Matter ID: 396-00002)

(a) Case Administration (Task Code 110)

Fees: $1,189.00 Total Hours: 6.70

26. During the Application Period, CST Law, along Paul Hastings, continued to advise the

Committee on general case administration. To efficiently track deadlines, organize documents, 

and manage workstreams, CST Law also prepared a task list per requests from Paul Hastings 

LLP attorneys and maintained a case calendar. To minimize duplication of services, CST Law 

developed procedures for allocating responsibilities among various CST Law lawyers.

(b) Pleading Reviews (Task Code B113)

Fees: $17,260.00 Total Hours: 73.00

27. During the Application Period, CST Law has reviewed various pleadings to be 

adequately prepared to provide services to the Committee. This is compliance with the applicable 

Rules of Professional Conduct.

(c) Meeting of and Communications with Creditors (Task Code B150)

Fees: $10,044.00 Total Hours: 37.20

28. During the Application Period, CST Law prepared various documents to keep the 

Committee apprised of relevant developments in the Title III Cases, related adversary

proceedings, and the mediation process. Also, CST Law participated in various telephone 

conferences and communications with the Committee for the same purposes.

(d) Court Hearings (Task Code B155)

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Fees: $1,807.00 Total Hours: 7.60

29. During the Application Period, CST Law attended as local counsel to all hearings that 

Paul Hastings attended. To minimize costs, only one CST Law attorney appeared in the hearings 

accompanying Paul Hastings’ attorneys.

30. In preparation for these hearings, CST Law also reviewed relevant issues raised in the 

parties’ pleadings, prepared materials for the hearings, and filed the requisite informative motions 

to be heard.

(e) General Litigation (Task Code B191)

Fees: $3,558.50 Total Hours: 16.30

31. During the Application Period, CST Law aided Paul Hastings in various matters including 

filing of pro hac vice admissions, motions, conducted local law research, among others. 

II. COFINA Dispute Analysis (Matter ID: 396-000003)

32. Pursuant to the Stipulation and Order Approving Procedure to Resolve CommonwealthCOFINA Dispute, dated August 10, 2017 [Docket No. 996] (the “Commonwealth-COFINA

Stipulation”), the Committee was appointed as the Commonwealth representative to litigate

and/or settle the Commonwealth-COFINA Dispute (as defined in the Commonwealth-COFINA

Stipulation) on behalf of the Commonwealth (the “Commonwealth Agent”).

12 The

Commonwealth-COFINA Dispute is one of the most significant and complex disputes in these

Title III Cases.

33. During the Application Period, the Commonwealth Agent continued to litigate the 

Commonwealth-COFINA Action by filing, among other things: (i) its motion for summary 

 

12 The Commonwealth-COFINA Dispute concerns the question “[w]hether, after considering all procedural and 

substantive defenses and counterclaims, including constitutional issues, the sales and use taxes [the (“SUT”)] 

purportedly pledged by COFINA to secure debt . . . are property of the Commonwealth or COFINA under applicable

law.”

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judgment; (ii) an omnibus opposition to the COFINA Agent’s summary judgment motion, the 

COFINA Senior Bondholders’ Coalition’s summary judgment motion, and the Mutual Fund 

Group’s and Puerto Rico Funds’ summary judgment motion (collectively, the COFINA Summary 

Judgment Motions”); (iii) responses to all of the statements of undisputed facts associated with 

the COFINA Summary Judgment Motions; (iv) a reply in support of its motion for summary 

judgment; and (v) an omnibus objection to the COFINA Agent’s motion to certify questions under 

Puerto Rico law to the Supreme Court of Puerto Rico (the “Certification Motion”), the Mutual 

Fund Group’s and Puerto Rico Funds’ motion to certify questions under Puerto Rico law to the 

Supreme Court of Puerto Rico, Ambac Assurance Corporation’s and National Public Finance 

Corporation’s limited objection to the Certification Motion and cross-motion to certify alternative 

questions to the Supreme Court of Puerto Rico, and joinders and statements thereto (collectively, 

the “Litigation Pleadings”).

34. All the while, the Commonwealth Agent, COFINA Agent and other intervenors and 

interested parties in the Commonwealth-COFINA Dispute worked tirelessly to mediate not only 

the Commonwealth-COFINA Dispute, but all of the claims this court dismissed as being out of 

scope of the Commonwealth-COFINA Dispute pursuant to the order setting forth the scope of the 

Commonwealth-COFINA Action (the “Scope Order”) on December 21, 2017. In addition to the 

Litigation Pleadings, CST Law helped Paul Hastings draft and file the joint urgent motion for an 

order expanding, for mediation purposes only, the Commonwealth Agent’s and COFINA Agent’s 

authority and immunity protections in advance of the Commonwealth-COFINA mediation 

sessions. All of the time, energy and resources expended on the Commonwealth-COFINA Action 

and the Commonwealth-COFINA Dispute mediation sessions proved fruitful. The parties made 

great strides and announced a fair resolution of what has been one of the most critical pieces of 

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litigation in these Title III Cases on June 5, 2018, based primarily off of work performed during 

the Application Period. 

(a) Pleadings Review (Task Code B113)

Fees: $4,104.00 Total Hours: 15.20

35. During the Application Period, CST Law has reviewed various pleadings to be 

adequately prepared to provide services to the Committee and assist Paul Hastings in its 

representation of the Committee. Specifically, CST Law reviewed pleadings filed and orders 

entered in the Commonwealth-COFINA Action and the in the adversary proceeding styled Bank 

of New York Mellon, as Trustee v. COFINA, Adv. Proc. No. 17-133, for internal review and review 

by the Committee.

(b) Other Contested Matters (Excluding Assumptions/Rejections) (Task Code B190)

Fees: $19,936.00 Total Hours: 92.30

36. During the Application Period, CST Law provided assistance to Paul Hastings in the 

analysis and drafting of pleadingsfiled in connection with the COFINA Agent’s motion to confirm

the application of the liability protections in section 105 of PROMESA. For example, CST Law

conducted various research that were instrumental in developing a strategy.

(c) General Litigation (Task Code B191)

Fees: $79,285.00 Total Hours: 395.00

37. During the Application Period, CST Law continued to work with Paul Hastings to 

prosecute the Commonwealth-COFINA Action on behalf of the Committee, as the 

Commonwealth Agent. Among other things, CST Law: (i) researched and analyzed critical legal 

issues with respect to the COFINA structure and other similar structures in the context of 

constitutionality, claims allowance, and transfer issues; (ii) reviewed discovery from the parties 

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to the Commonwealth-COFINA Action; (iii) reviewed drafts of an amended complaint and 

answers and counterclaims; (iv)analyzed and provide advice on the prosecution and defense of 

motions to enforce the scope of the Commonwealth-COFINA Action; and (v) pursuant to Paul 

Hastings’ requests, researched and analyzed issues critical to the Commonwealth Agent’s motion 

for summary judgment, which was due on February 21, 2018, and prepared briefing and 

accompanying documents for this motion.

38. Furthermore, CST Law strategize with Paul Hastings as to a dispute concerning the scope 

of the Commonwealth-COFINA Dispute. In particular, CST Law conducted extensive research 

and strategize pertaining to whether various questions should be certified to the Supreme Court of 

Puerto Rico.

39. As the court is aware, the Commonwealth-COFINA Dispute is extremely complex, 

involving novel and interlocking issues of both law and fact. As such, it has required extensive 

legal analysis and discovery efforts on the part of CST Law as local counsel for the 

Commonwealth Agent. CST Law accomplished the following work streams in connection with 

its submission of the Commonwealth Agent’s summary judgment motion; (i) coordinated firstlevel review of documents produced; (iii) extensively researched Puerto Rico case law in order to

analyze novel issues related to property interests, municipal bonds, financing schemes, and 

constitutional law, among others; (iv) as well as engaged in discovery efforts with third-parties.

(d) Non-Working Travel (Task Code B195)

Fees: $2,778.50 Total Hours: 21.10

40. During the Application Period, certain CST Law attorneys traveled to and from Court 

Hearings and Meetings in New York. 

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41. In accordance with Local Rule 2016-2(d)(viii), CST Law billed for one-half the total time 

that CST Law professionals spent on non-working travel

III. Communications with Creditors / Website (other than Committee Members) 

(Matter ID: 396-00004)

(a) Pleadings Review (Task Code B113)

Fees: $1,050.00 Total Hours: 6.00

42. During the Application Period, CST Law has reviewed various pleadings to be 

adequately prepared to provide services to the Committee and assist Paul Hastings in its 

representation of the Committee. In particular, CST Law was engaged in developing and 

implementing the Creditors’ Information Session, along with Paul Hastings. 

(b) Meetings of and Communications with Creditors (Task Code B150)

Fees: $2,214.00 Total Hours: 8.20

43. During the Application Period, CST Law communicated with creditors of the 

Commonwealth to provide information about the information sessions that were ordered by the 

Court. 

(c) Other Contested Matters (Excluding Assumptions/Rejections) (Task Code B190)

Fees: $5,185.00 Total Hours: 24.50

44. During the Fee Application, CST Law attorneys conducted extensive research pertaining 

to potential claims relating to PBA. CST Attorneys communication with Paul Hastings to 

strategize pertaining to the foregoing. 

(d) General Litigation (Task Code B191)

Fees: $32,028.00 Total Hours: 160.80

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45. During the Application Period, CST Law worked with Paul Hastings attorneys to analyze 

pleadings filed in various local cases being monitored adversary proceedings and to develop 

strategies for such cases.

(e) Non-Working Travel (Task Code B195)

Fees: $3,609.00 Total Hours: 36.40

46. During the Application Period, certain CST Law attorneys traveled to and from the various 

locations were the Informative Sessions were held. One attorney traveled to Orlando, FL and other 

two attorneys traveled within Puerto Rico to attend and participate in such sessions.

47. In accordance with Local Rule 2016-2(d)(viii), CST Law billed for one-half the total time 

that CST Law professionals spent on non-working travel.

IV. PREPA (Matter ID 396-00006)

(a) Pleadings Review (Task Code B113)

Fees: $13,907.00 Total Hours: 58.10

48. During the Application Period, CST Law has reviewed various pleadings to be 

adequately prepared to provide services to the Committee and assist Paul Hastings in its 

representation of the Committee. In particular, CST Law continued to review and prepare 

summaries of pleadings filed and orders entered in the PREPA Title III Case, related adversary 

proceedings, and other litigation including the briefs filed in the First Circuit appeal by the ad hoc 

group of PREPA bondholders regarding the appointment of a receiver for PREPA, No. 17-2079, 

and the adversary proceeding styled Puerto Rico Energy Commission (“PREC”) v. PREPA, et al., 

Adv. Proc. No. 18-021 (the “PREC Adversary Proceeding”).

(b) General Litigation (Task Code B191)

Fees: $5,146.00 Total Hours: 24.40

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49. During the Application Period, CST Law worked with Paul Hastings attorneys to analyze 

pleadings filed in various local cases being monitored adversary proceedings and to develop 

strategies for such cases. Further, CST Law review and provided comments to motion to 

intervene in the PREC Adversary Proceeding (in which case PREC had sought to enjoin the 

Oversight Board from taking certain actions with respect to PREPA). The Committee 

successfully intervened and joined in the Oversight Board’s opposition to the preliminary 

injunction motion. The court ultimately denied PREC’s preliminary injunction motion and 

PREC thereafter voluntarily dismissed the PREC Adversary Proceeding.

V. ERS (Matter ID: 396-00008)

(a) Other Contested Matters (Excluding Assumptions/Rejections) (Task Code B190)

Fees: $17,471.00 Total Hours: 72.30

50. During the Fee Application, CST Law attorneys conducted extensive research pertaining 

to potential claims relating to ERS. The results of the investigation provided were document in 

memorandums and shared with Paul Hastings’ attorneys. Further, CST Attorneys communication 

with Paul Hastings to strategize pertaining to the foregoing. 

(b) General Litigation (Task Code B191)

Fees: $1,846.00 Total Hours: 8.80

51. During the Application Period, CST Law worked with Paul Hastings attorneys to analyze 

pleadings filed in various local cases being monitored adversary proceedings and to develop 

strategies for such cases.

VI. Other Adversary Proceedings (Matter ID: 396-00009)

(a) Other Contested Matters (Excluding Assumptions/Rejections) (Task Code B190)

Fees: $6,579.00 Total Hours: 33.90

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52. During the Application Period, CST Law worked with Paul Hastings attorneys to analyze 

pleadings filed in various local cases being monitored adversary proceedings and to develop 

strategies for such cases.

VII. Mediation (Matter ID: 396-00010)

53. The Committee’s role in the mediation process during the Application Period focused on 

the efforts to settle the Commonwealth-COFINA Dispute (as expanded by the Scope Order), with 

respect to which the Committee is acting as the Commonwealth Agent.

(a) Meetings of and Communications with Creditors (Task Code B150)

Fees: $1,268.00 Total Hours: 5.40

54. During the Application Period, CST Law attorneys participated in various conference calls, 

as well as communicated electronically, pertaining to mediation efforts. This conference calls were 

with Committee Members, Paul Hastings’ attorneys, or other parties engaged in mediation.

(b) General Litigation (Task Code B191)

Fees: $12,064.00 Total Hours: 47.20

55. During the Application Period, CST Law attorneys reviewed and analyzed the 

developments of the mediation process, as well as strategize with Paul Hastings attorneys to obtain 

better results for the Committee in said process. 

VIII. Document Review (Matter ID: 396-00012)

(a) General Litigation (Task Code B191)

Fees: $20,650.00 Total Hours: 206.50

56. During the Application Period, CST Law conducted the first level review documents 

produced in connection with the Commonwealth-COFINA Dispute. For purposes of this matter, 

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CST Law agreed to reduce its rates to a blended rate of $100.00 per hour per timekeeper. This task 

alone represents almost 15% of the fees requested by CST Law in the Interim Period. 

IX.GDB (Matter ID: 396-00013)

(a) Other Contested Matters (Excluding Assumptions/Rejections) (Task Code B190)

Fees: $3,950.00 Total Hours: 17.00

57. During the Fee Application Period, CST Law attorneys conducted various research to assist 

Paul Hastings to analyze various developments in GDB’s Title VI proceeding. Further, CST Law 

attorneys communicated with Paul Hastings’ attorneys to provide the research results. 

X. PBAPR (Matter ID: 396-00014)

58. On February 14, 2018, the PBA Funds’ Rent Motion was filed, alleging not less than $289 

million in administrative “rent” claims. Upon that filing, the Committee began investigating the 

PBA structure, its bonds, its purpose, and the underlying “leases” to evaluate the merits of the PBA 

Funds’ Rent Motion.

(a) Pleadings Review (Task Code B113)

Fees: $2,034.00 Total Hours: 8.20

59. During the Application Period, CST Law has reviewed various pleadings to be 

adequately prepared to provide services to the Committee and assist Paul Hastings in its 

representation of the Committee.

(b) Other Contested Matters (Excluding Assumptions/Rejections) (Task Code B190)

Fees: $2,829.00 Total Hours: 14.60

60. During the Application Period, CST Law assisted Paul Hastings in obtaining various 

documents related to PBA that were necessary to properly analyze various issues regarding the 

mentioned public corporation. 

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(c) General Litigation (Task Code B191)

Fees: $9,441.00 Total Hours: 45.40

61. During the Application Period, CST Law assisted Paul Hastings in obtaining various 

documents related to PBA that were necessary to properly analyze various issues regarding the 

mentioned public corporation. This, to further explore challenges to the PBA structure.

XI. Fee Application (Matter ID: 396-00015)

(a) Case Administration (Task Code B110)

Fees: $2,306.00 Total Hours: 12.30

62. Pursuant to the Fee Examiner’s request, CST Law has established a matter to keep track of 

the time incurred in compliance with the Fee Examiner’s requests. The time spent in the Fee 

Application Period pertains to the time spent in compliance with the Fee Examiner’s requests 

including communications with the mentioned examiner. 

*****

63. The foregoing professional services were necessary and appropriate to the administration

of the Title III Cases and were incurred upon in the best interests of the Committee, the Debtors, 

the creditors, and other parties in interest.

ACTUAL AND NECESSARY DISBURSEMENTS

64. As set forth in Exhibit D hereto, CST Law disbursed $12,052.09 as expenses incurred in 

providing professional services during the Interim Fee Period.

65. Because CST Law believes that online legal research (e.g., LEXIS and WESTLAW) is far

more cost-efficient than manual research using hard-bound volumes, CST Law encourages 

computerized legal research even though it is not a profit center for CST Law.

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66. The time constraints imposed by the circumstances of the matters handled by CST Law

during the Interim Fee Period required its attorneys and other employees, at times, to devote 

substantial time during the evenings and on weekends to perform legal services on behalf of the 

Committee. These extraordinary services were essential to meet deadlines, timely respond to 

daily inquiries, and satisfy the Committee’s needs and demands. Attorneys and other CST Law 

employees who worked late in the evenings or on weekends were reimbursed for their reasonable 

meal and transportation costs in accordance with the Local Rules and firm policy. CST Law’s 

regular practice is not to include components for those charges in overhead when establishing 

billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements 

incurred during the regular course of the provision of legal services. 

67. CST Law believes the rates for charges incurred are the market rates that most law

firms charge clients for such services. In addition, CST Law believes that such charges are in

accordance with the American Bar Association’s (“ABA”) guidelines, as set forth in the ABA’s

Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other 

charges.

THE REQUESTED COMPENSATION SHOULD BE ALLOWED

68. Section 316 provides for the compensation of professionals. Specifically, the section

provides that a Court may award a professional employed by a committee under Section 1103

of the Bankruptcy Code “reasonable compensation for actual, necessary services rendered...

and reimbursement for actual, necessary expenses.” PROMESA §316(a). Section 316 of

PROMESA also sets forth the criteria for the award of such compensation and reimbursement:

(a) 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:

(i) the time spent on such services;

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(ii) the rates charged for such services;

(iii) whether the services were necessary to the administration of, or 

beneficial at the time at which the service was rendered toward the 

completion of, a case under this chapter;

(iv) 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;

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

certified or otherwise has demonstrated skill and experience in the 

restructuring field; and

(vi) 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, United States Code.

PROMESA §316(c). Further, section 317 of PROMESA provides that “a committee... may 

apply to the court not more than once every 120 days... for such compensation for services 

rendered...”

69. In the instant case, CST Law respectfully submits that the services for which it seeks

compensation in this Application were, at the time rendered, believed to be necessary for and

beneficial to the Committee, the Debtors, and their stakeholders and were rendered to 

protect, preserve, and maximize the value for unsecured creditors during the pendency of the 

Title III Cases. The services rendered to the Committee were performed in an economic, effective,

and efficient manner commensurate with the complexity and importance of the issues involved. 

Furthermore, almost 15% of the fees requested were performed at a significant reduced blended 

rate of $100.00 per hour per timekeeper. The results obtained to date have benefited not only

the Committee but also the Debtors and their stakeholders. Accordingly, the compensation 

requested herein is reasonable considering the nature, extent, and value of such services to the

Committee, the Debtors, and all parties in interest.

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70. The work conducted was carefully assigned to appropriate professionals or 

paraprofessionals according to the experience and level of expertise required for each particular 

task. Whenever possible, CST Law sought to minimize the costs of CST Law’s services to the 

Committee by utilizing talented junior attorneys and paraprofessionals to handle the more routine 

aspects of the assignments. A small group of the same CST Law attorneys was utilized for the 

vast majority of the work in this case, to minimize the costs of intra- CST Law communication 

and education about the Title III Cases. As demonstrated by this Application, CST Law spent its 

time economically and without unnecessary duplication. Accordingly, approval of the 

compensation sought herein is warranted.

CONCLUSION

WHEREFORE, CST Law respectfully requests entry of an order (i) allowing interim 

compensation for professional services rendered during the Interim Fee Period in the amount of

$294,120.50 and expense reimbursements in the amount of $12,052.09; (ii) directing the Debtors’ 

payment of the amounts allowed and; (iii) granting CST Law such other and further relief as is

just.

Date: July 16, 2018

In San Juan, Puerto Rico

/s/Juan J. Casillas-Ayala

Juan J. Casillas-Ayala, Esq.

CASILLAS, SANTIAGO & TORRES, LLC

Juan J. Casillas-Ayala, Esq., USDC-PR 218312

Diana M. Batlle-Barasorda, Esq., USDC-PR 213103

Alberto J. E. Añeses-Negrón, Esq., USDC-PR 302710

Ericka C. Montull-Novoa, Esq., USDC-PR 230601

El Caribe Office Building 

53 Palmeras Street, Ste. 1601 

San Juan, PR 00901-2419 

Telephone: (787) 523-3434 

jcasillas@cstlawpr.com 

dbatlle@cstlawpr.com 

aaneses@cstlawpr.com 

emontull@cstlawpr.com

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