Hearing Date: June 7, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) 

 Objection Deadline: March 30, 2023 at 3:00 p.m. (ET) / 4:00 p.m. (AST) 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.1

_____________________________________________/ 

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

SUMMARY COVER SHEET FOR THE FINAL FEE APPLICATION OF GENOVESE 

JOBLOVE & BATTISTA, P.A., AS SPECIAL LITIGATION COUNSEL TO OFFICIAL 

COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES RENDERED AND 

REIMBURSEMENT OF EXPENSES FOR THE PERIOD OF 

AUGUST 1, 2022 THROUGH DECEMBER 31, 2022 

All Fees and Services included in this Final Application were performed outside of Puerto Rico 

SUMMARY COVER SHEET

Name of applicant: Genovese Joblove & Battista, P.A. (“GJB”) 

Authorized to provide professional 

services to: 

Special Litigation Counsel for the Official 

Committee of Unsecured Creditors (the 

“Committee”)2

1

 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); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5523 (LTS)) (Last Four Digits of Federal Tax ID: 3801). (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

2

 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and 

COFINA. 

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2

Name of Client: Official Committee of Unsecured Creditors of all 

Title III Debtors (other than COFINA and PBA) 

Petition Date: May 3, 20173

 Date of retention: May 31, 2019, effective as of April 16, 2019 

 [Docket No. 7181] 

 Period for which compensation 

and reimbursement are sought:

 August 1, 2022 – December 31, 2022 (the “Application 

Period”) 

 Amount of final compensation 

 sought as actual, reasonable, and 

 necessary: 

$21,574.00 4

 Amount of interim expense 

 reimbursement sought as actual, 

 reasonable, and necessary: 

$2,069.08

Are your fee or expense totals 

different from the sum of 

previously-served monthly 

statements for the Application 

Period? 

N/A 

Total compensation approved by 

interim order to date: 

$657,907.05 (First Interim Fee Order ECF No. 9046) 

$1,339,434.84 (Second Interim Fee Order ECF No. 13296) 

$1,171,906.40 (Third Interim Fee Order ECF No. 13824) 

$887,215.20 (Fourth Interim Fee Order ECF No. 15971) 

$499,302.23 (Fifth Interim Fee Order DE 17646) 

$327,033.50 (Sixth Interim Fee Order DE 18371) 

$163,364.88 (Seventh Interim Fee Order DE 20412) 

$278,543.20 (Eighth Interim Fee Order DE 22727) 

$117,740.40 (Ninth Interim Fee Order DE 23408) 

3

 The Petition Date for the Commonwealth under Title III was May 3, 2017. The petition date for COFINA under 

Title III was May 5, 2017. The petition date for ERS and HTA under Title III was May 21, 2017. The Petition Date 

for PREPA under Title III was July 2, 2017. 

4 The full amount of fees incurred by GJB during the Application Period total $21,574.00. GJB agreed taking a 

voluntary fee reduction equal to 20% in the amount of $4,314.80 and, thereby, seeks allowance and payment of fees 

in the amount of $17,259.20. By the time of the hearing on this Application, a portion of this amount should have 

been paid by the Debtors pursuant to the Interim Compensation Order, and GJB reserves its rights to seek relief from 

the Court to the extent any outstanding fees and expenses that are due and payable are not paid on the terms set forth 

in the Interim Compensation Order. 

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Total expenses approved by 

interim order to date: 

$3,848.56 (First Interim Fee Order ECF No. 9046) 

$43,602.27(Second Interim Fee Order ECF No. 13296)

$33,296.95 (Third Interim Fee Order ECF 13824) 

$54,671.58 (Fourth Interim Fee Order ECF No. 15971) 

$31,381.55 (Fifth Interim Fee Order DE 17646) 

$37,092.49 (Sixth Interim Fee Order DE 18371) 

$30,614.97 (Seventh Interim Fee Order DE 20412) 

$19,344.38 (Eighth Interim Fee Order DE 22727) 

$11,383.83 (Ninth Interim Fee Order DE 23408) 

Total allowed compensation paid 

to date: 

$5,442,447.70 

Total allowed expenses paid to 

date: 

$265,236.58 

Blended rate in this Application 

for all attorneys: 

$591.09/hour5

 Blended rate in this Application 

for all timekeepers: $383.88/hour

Total compensation sought in this 

Application already paid pursuant 

to a monthly compensation order 

but not yet allowed: 

$0.00 

Total expenses sought in this 

Application already paid pursuant 

to a monthly compensation order 

but not yet allowed. 

$0.00 

Total time expended for fee 

application preparation 

during the Application 

Period: 

50.00 hrs6

Total compensation requested 

for fee application preparation 

during the Application Period: 

$18,009.00 

Number of professionals included 

in this Application: 

5 

5

 The calculation of the blended hourly rates reflected in this Application Period does not take into account GJB’s 

agreement to reduce its fees by an amount equal to 20% of its hourly rates. 

6

 The hours allocated for preparation of fee application include 6.60 hours which were inadvertently entered under the 

incorrect task code B191 – General Litigation. See paragraph 64. 

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 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 the 

Application Period: 

N/A 

Number of professionals billing 

fewer than 15 hours to the case 

during the Application Period: 

3 

Are any timekeeper’s hourly rates 

higher than those approved or 

disclosed at retention? If yes, 

calculate and disclose the total 

compensation sought in this 

Application using the rates originally 

disclosed in the retention application: 

None. 

 SUMMARY OF PRIOR MONTHLY FEE STATEMENTS FOR THE COMPENSATION 

PERIOD AUGUST 1, 2022 THROUGH DECEMBER 31, 2022

N/A 

Summary of Amounts Requested to be Paid 

Total Unpaid Fees: $21,574.00

Total Unpaid Expenses: $2,069.08

Total 10% Holdback on Fees: $2,157.40

Reimbursement for 29% Tax Withholding: N/A

Reimbursement for 1.5% Government Contribution: N/A 

Less expenses voluntarily reduced herein: N/A

Total Amount Requested to be Paid in Fees and Expenses for this period: $19,328.28. 

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PRIOR INTERIM FEE APPLICATIONS 

First Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees Requested 

(90%) 

Holdback 

(10%) 

Expenses 

Requested 

7/15/19 7994 April 19, 2019- 

May 31, 2019 

$691,742.25 $553,393.80 $498,054.42 $55,339.38 $10,373.05 

Second Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

11/15/19 9213 June 1, 2019- 

September 30, 

2019 

$1,728,948.00 $1,383,158.40 $1,244.842.56 $138,315.84 $43,602.27 

Third Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

3/15/20 12409 October 1, 2019- 

January 31,2020

$1,494,787.75 $1,195,830.20 $1,076,247.18 $119,583.02 $33,296.95 

Fourth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

11/16/20 15142 February 1,2020 

-August 31,2020

$1,124,542.00 $899,633.60 $809,670.24 $89,963.36 $56,687.18 

Fifth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

03/15/21 16068 September 1 

2020 - January 

31, 2021

$499,302.23 $399,441.78 $359,497.62 $39,944.16 $31,381.55 

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Sixth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

07/15/21 17365 February 1, 

2021-April 30, 

2021

$327,033.50 $261,626.80 $235,464.12 $26,162.68 $37,092.49 

Seventh Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

11/15/21 19219 June 1, 2021 – 

September 30, 

2021

$204,609.00 $163,687.20 $147,318.48 $16,368.72 $33,089.07 

Eighth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

08/31/22 21992 October 1, 2021 

– December 31, 

2021

$349,725.50 $279,780.40_

_____ $251,802.36_

___ $25,180.24

____ $19,344.38 

Ninth Interim Fee Application 

Date 

Filed 

DE# Period 

Covered 

Total Fees 20% 

Discount 

Fees 

Requested (90%) 

Holdback 

(10%) Expenses Requested 

11/15/2022 22880 January 1, 

2022 – July 31, 

2022 

$147,175.50 $117,740.40 $105,966.36 $11,740.04 $11,922.93 

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SUPPORTING CERTIFICATION, EXHIBITS, AND SCHEDULES

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

following Exhibits and Schedules: 

EXHIBIT A CERTIFICATION OF MARIAELENA GAYO-GUITIAN IN SUPPORT 

OF APPLICATION 

EXHIBIT B CUSTOMARY AND COMPARABLE COMPENSATION 

DISCLOSURES 

EXHIBIT C SUMMARY OF TIMEKEEPERS INCLUDED IN THIS APPLICATION 

EXHIBIT D BUDGETS AND STAFFING PLANS FOR APPLICATION PERIOD 

EXHIBIT E SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

 CATEGORY 

EXHIBIT E-1 SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

 CATEGORY AS COMPARED TO BUDGET 

EXHIBIT E-2 SUMMARY OF EXPENSE REIMBURSEMENT REQUESTED BY 

CATEGORY 

EXHIBIT F BREAKDOWN OF COMPENSATION AND EXPENSE 

REIMBURSEMENT REQUESTED AND BY WHETHER SERVICES 

WERE RENDERED IN PUERTO RICO OR OUTSIDE PUERTO RICO 

SCHEDULE 1 LIST OF PROFESSIONALS BY MATTER 

SCHEDULE 2 MONTHLY STATEMENTS COVERED IN APPLICATION 

SCHEDULE 3 PROPOSED ORDER 

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 Hearing Date: June 7, 2023 at 8:30 a.m. (ET) / 9:30 a.m. (AST) 

 Objection Deadline: March 30, 2023 at 3:00 p.m. (ET) / 4:00 p.m. (AST) 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.7

_____________________________________________/ 

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

FINAL APPLICATION OF GENOVESE JOBLOVE & BATTISTA, P.A, SPECIAL 

LITIGATION COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR ALLOWANCE OF COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR PERIOD FROM 

AUGUST 1, 2022 THROUGH DECEMBER 31, 2022

To The Honorable United States District Judge Laura Taylor Swain: 

Genovese Joblove & Battista, P.A. (“GJB”), special litigation counsel to the Official 

Committee of Unsecured Creditors (the “Committee”), in the above-captioned Title III cases (the 

“Title III Cases”)8 hereby submits its Final Fee Application (the “Application”) for allowance of 

compensation for professional services rendered, and reimbursement for actual and necessary 

7 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); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5523 (LTS)) (Last Four Digits of Federal Tax ID: 3801). (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

8 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and 

COFINA.

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expenses incurred in connection with such services, for the period from August 1, 2022 through 

December 31, 2022 (the “Application Period”). 

On February 15, 2022, former GJB attorneys John Arrastia (“J. Arrastia”), Jesus Suarez 

(“J. Suarez”) and Angelo Castaldi (“A. Castaldi”) formed the law firm, Continental, PLLC 

(“Continental”) and took over representation of the Committee as special litigation counsel for the 

Committee. In connection with the foregoing, Arrastia, Suarez and Castaldi filed Notices of 

Appearance and Request for Notices and Papers [D.E. 20136]. On February 28, 2022, Continental 

filed their Informative Motion Regarding Change of Firm and Address, and Proposed Substitution 

of Counsel [Docket No. 20225]. As a result of the foregoing, GJB no longer is representing any 

party in these proceedings and thereby submits its Final Fee Application. GJB submits this 

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

Economic Stability Act of 2016 (“PROMESA”),9 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”), Rule 2016-1 of the 

Local Bankruptcy Rules for the United States Bankruptcy Court for the District of Puerto Rico (the 

“Local Rules”), Appendix B of the United States Trustee Guidelines for Reviewing Applications 

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

Larger Chapter 11 Cases issued by the Executive Office for the United States Trustee, 28 CFR 

Part 58, Appendix B (the “Guidelines”), and in accordance with this Court’s the First Amended 

Order Setting Procedures for Interim Compensation and Reimbursement of Expenses of 

Professionals (“Interim Compensation Order”) [Docket No. 1715]; the Second Amended Order 

Setting Procedures for Interim Compensation and Reimbursement of Expenses of Professionals 

(“Second Interim Compensation Order”) [Docket No. 3269]; the Fee Examiner’s November 10, 

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

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2017 Memorandum (the “Fee Examiner Memorandum”); the Court’s Order on Fee Examiner’s 

Motion to Impose Presumptive Standards and Timeliness requirements for Professional Fee 

Applications (the “Presumptive Order”) [Docket No. 3932]; the Court’s Order Imposing 

Additional Presumptive Standards: Rate Increases and the Retention of Expert Witnesses or Other 

Sub-retained Professionals (the “Revised Presumptive Order”) [Docket No. 7678] and the Third 

Amended Order Setting Procedures for Interim and Final Compensation and Reimbursement of 

Expenses of Professionals [Docket No. 20546] (“Third Interim Compensation Order”). In support 

of the Application, GJB submits the Certification of Mariaelena Gayo-Guitian (the “Gayo-Guitian 

Certification”), attached as Exhibit A, and respectfully represents as follows: 

JURISDICTION AND VENUE 

1. The Court has subject matter jurisdiction to consider and determine this Tenth and 

Final Application pursuant to PROMESA section 306(a). Venue is proper before this Court 

pursuant to PROMESA section 307(a). The statutory predicates for the relief requested herein are 

PROMESA sections 316 and 317, Bankruptcy Rule 2016 and Local Rule 2016-1. 

2. This Application has been prepared in accordance with the Guidelines and the Third 

Interim Compensation Order. Attached as Exhibit A is a certification regarding compliance with 

the Local Guidelines. 

3. This Application is consistent with the Third 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, GJB requests a waiver for cause shown of any requirements not met by this 

Application.10

10 The Committee and GJB reserve all rights as to the relevance and substantive legal effect of the U.S. Trustee 

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BACKGROUND 

 A. Case Background

4. 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 (the “ERS Title III Case”), the Puerto Rico Highways and 

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

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

Cases”).11 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.

5. 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]. Thereafter, the U.S. Trustee modified the composition of the Committee 

membership [Docket Nos. 1171, 3058, and 3947], such that, currently, the members of the 

Committee are the American Federation of Teachers, Baxter Sales and Distribution Puerto Rico

Corp., Doral Financial Corporation, Genesis Security Services, Inc., Service Employees 

International Union, Tradewinds Energy Barceloneta, LLC, and Unitech Engineering Group, S.E. 

(the “Committee Members”) [Docket No. 3947]. 

6. 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 

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

11 Unless otherwise indicated, references to docket numbers shall be to the docket of the Commonwealth Title III Case. 

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PREPA Title III Case. 

B. Retention of Genovese Joblove & Battista, P.A. 

7. On April 16, 2019, the Committee selected GJB as proposed special litigation 

counsel to the Committee in connection with the evaluation and analysis of potential causes of 

action and representation as co-plaintiff in the filing and prosecution of certain claims and causes 

of action to be asserted against certain parties involved in the offering of (a) the Commonwealth’s 

General Obligation bonds (“GO Bonds”), (b) bonds issued by the Public Buildings Authority 

(“PBA”), and (c) bonds issued by ERS (“ERS”), including bond counsel, disclosure counsel, 

underwriters, underwriters’ counsel, swap counterparties, or auditors (collectively, the “Financial 

Party Targets”). 

8. The retention of GJB as special litigation counsel was necessary and appropriate 

because the Committee’s primary counsel, Paul Hastings, LLP (“Paul Hastings”) represents certain 

of the Financial Party Targets (or their affiliates) in matters unrelated to the Title III Cases. 

9. On April 26, 2019, the Court approved the Stipulation and Agreed Order By and 

Among Financial Oversight and Management Board, Its Special Claims Committee, and Official 

Committee of Unsecured Creditors to Joint Prosecution of Debtor Causes of Action [Doc No. 6524 

] (the “Joint Prosecution Stipulation”). In connection with the prosecution of such claims or causes 

of action, the Oversight Board agreed to the appointment of the members of the Special Claims 

Committee of the Oversight Board (“Special Claims Committee”), on the one hand, and the 

Committee, on the other hand, as co-trustees and co-plaintiffs with respect to the Co-Plaintiff 

Adversary Proceedings. 

10. As set forth in the Engagement Agreement dated April 30, 2019, GJB was retained 

by and authorized to represent the Committee as special litigation counsel and conflicts counsel in 

connection with, among other matters, the evaluation and analysis of potential causes of action 

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and representation as co-plaintiff in the filing and prosecution of certain claims and causes of 

action to be asserted against certain parties involved in the involved in the offering of (a) the 

Commonwealth’s General Obligation bonds, (b) bond issued by the Public Buildings Authority, 

and (c) bonds issued by ERS, including underwriters, underwriters’ counsel, swap counterparties, 

disclosure counsel, and auditors (collectively, the “Financial Party Targets”). 

11. On April 30, 2019, the Committee filed the Application for Order Pursuant to 

Bankruptcy Code Section 1103(a) and Local Bankruptcy Rule 2014-1(e) Authorizing Employment 

and Retention of Genovese Joblove & Battista, P.A. as Special Litigation Counsel to Official 

Committee of Unsecured Creditors, Effective as of April 16, 2019 [Docket No. 6661] (the “GJB 

Employment Application”). 

12. On May 31, 2019, the Court entered the Order Authorizing Employment and 

Retention of Genovese, Joblove & Battista, P.A. as Special Litigation Counsel to Official 

Committee of Unsecured Creditors, Pursuant to Bankruptcy Code Section 1103(A) and Local Rule 

2014-1(e), Effective as of April 16, 2019 [Docket No. 7181] (the “Retention Order”). 

13. GJB’s retention extends to the representation of the Committee as the official 

committee for the HTA Title III Case, the ERS Title III Case, and the PREPA Title III Case. In 

particular, the Retention Order provided that “[t]he retention of GJB, as counsel to the Committee, 

shall be deemed to apply to the representation of the Committee if ever enlarged to include 

unsecured creditors of other debtors, without the need to obtain a modification of this Order.”

14. The Retention Order authorized GJB 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. The 

Retention Order further provides that “[p]ursuant to Bankruptcy Code section 503(b)(1), made 

applicable by PROMESA section 301(a), the fees and expenses of GJB shall be an administrative 

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expense.” In addition, as provided in the Retention Order, the Committee has consented to the 

Debtors’ payment of GJB’s allowed fees and expenses. 

15. On February 15, 2022, former GJB attorneys J. Arrastia, J. Suarez and A. Castaldi 

formed the law firm, Continental and took over representation of the Committee as special 

litigation counsel for the Committee. As a result of the foregoing, GJB no longer is representing 

any party in these proceedings and thereby submits its Final Fee Application. 

C. Interim Compensation and Fee Examiner Orders 

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

Compensation and Reimbursement of Expenses of Professionals (the “Interim Compensation 

Order”) [Docket No. 1150]. 

17. On October 6, 2017, the Court appointed a Fee Examiner in these Title III Cases 

(the “Fee Examiner”) pursuant to the Order Pursuant to PROMESA Sections 316 and 317 and 

Bankruptcy Code Section 105(a) Appointing a Fee Examiner and Related Relief [Docket No. 

1416] (the “Fee Examiner Order”). The Court appointed Brady Williamson as the Fee Examiner 

in the Title III Cases. 

18. On October 31, 2017, the Fee Examiner filed the Urgent Motion of the Fee 

Examiner to Amend the Interim Compensation Order, Including the Due Date and Hearing Date 

for Interim Compensation [Docket No. 1594]. 

19. On November 8, 2017, the Court entered the First Amended Order Setting 

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket 

No. 1715]. 

20. On November 10, 2017, the Fee Examiner issued a memorandum, and on January 

3, 2018, the Fee Examiner issued a supplemental memorandum (together, the “Fee Examiner 

Guidelines”) to all retained professionals in these Title III Cases providing additional guidelines 

in connection with the Interim Compensation Order. 

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21. On May 8, 2018, the Fee Examiner filed the Motion of the Fee Examiner to Amend 

the Fee Examiner Order with Respect to the Scope of the Fee Examiner’s Authority in the Interest 

of Administrative Efficiency [Docket No. 3032] (the “Motion to Amend the Fee Examiner Order”). 

22. On May 23, 2018, the Oversight Board and the Puerto Rico Fiscal Agency and 

Financial Authority (“AAFAF”) filed a Joint Motion for Entry of an Order Further Amending the 

Interim Compensation Order [Docket No. 3133]. 

23. On June 6, 2018, the Court entered the Second Amended Order Setting Procedures 

for Interim Compensation and Reimbursement of Expenses of Professionals (“Second Interim 

Compensation Order”) [Docket No. 3269]. 

24. On June 20, 2018, the Court entered the First Amended Order Pursuant to 

PROMESA Sections 316 and 317 and Bankruptcy Code Section 105(A) Appointing a Fee 

Examiner and Related Relief [Docket No. 3324] (the “Amended Fee Examiner Order”). 

25. On June 26, 2019, the Court entered the Order Imposing Additional Standards: 

Rate Increases and the Retention of Expert Witnesses or Other Sub-Retained Professionals 

[Docket No. 7678]. 

26. On April 12, 2022, the Court entered the Third Amended Order Setting Procedures 

for Interim Compensation and Reimbursement of Expenses of Professionals (the “Third Interim 

Compensation Order”) [Doc. No. 20546], and in accordance therewith, GJB and other 

professionals retained in these Title III Cases were authorized to serve upon the parties identified 

therein (the “Notice Parties”) monthly fee statements (the “Monthly Fee Statements”). 

27. Pursuant to the Third Amended Interim Compensation Order, the Notice Parties 

have ten (10) days from the date of service of the Monthly Fee Statement to object to the amounts 

requested. If no objection is filed prior to expiration of the objection period, the Commonwealth 

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is authorized to pay the respective professionals 90% of the fees and 100% of the expenses sought 

in each Monthly Fee Statement. 

D. Applications for Interim Compensation 

28. In addition to the Monthly Fee Statements, the Third Interim Compensation Order 

directed professionals to seek interim allowance and payment of compensation (including the 10% 

held back from Monthly Fee Statements) and expense reimbursement at 120-day intervals (each 

an “Interim Fee Period”) by filing with the Court and serving on the Notice Parties an application 

for approval and allowance of all compensation and reimbursement of expenses relating to services 

rendered and expenses incurred during the preceding Interim Fee Period (see Interim 

Compensation Order at ¶2(d)). 

29. On July 15, 2019, GJB filed its First Interim Fee Application for the period from 

April 16, 2019 through May 31, 2019 [ECF No. 7994] (the “First Interim Fee Application”). The 

hearing on the First Interim Fee Application was held on October 30, 2019 at 9:30 a.m. 

30. On October 29, 2019, the Court entered the Omnibus Order Awarding Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Sixth Compensation Period from February 1, 2019 through May 31, 2019 [ECF No. 9046] 

(the “First Interim Fee Order”). Pursuant to the First Interim Fee Order, GJB was awarded 

$657,907.05 in fees and reimbursement of expenses in the amount of $3,848.56. 

31. On November 15, 2019, GJB filed its Second Interim Fee Application for the period 

from June 1, 2019 through September 30, 2019 [ECF No. 9213] (the “Second Interim Fee 

Application”). The hearing on the Second Interim Fee Application was held on March 4, 2020 at 

9:30 a.m. and was continued to April 22, 2020 at 9:30 a.m. 

32. On June 1, 2020, the Court entered the Second Supplemental Omnibus Order 

Awarding Interim Allowance of Compensation for Professional Services Rendered and 

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Reimbursement of Expenses for the Seventh Interim (June 1- September 30, 2019) and Prior 

Compensation Periods [ECF No. 13296] (the “Second Interim Fee Order”). Pursuant to the 

Second Interim Fee Order, GJB was awarded $1,339,434.84 in fees and reimbursement of 

expenses in the amount of $43,602.27. 

33. On March 16, 2020, GJB filed its Third Interim Fee Application for the period from 

October 1, 2019 through January 31, 2020 [ECF No. 12409] (the “Third Interim Fee Application”). 

The hearing on the Third Interim Fee Application was held on July 29, 2020 at 9:30 a.m. [ECF 

No. 12410]. 

34. On July 24, 2020, the Court entered the Omnibus Order Awarding (I). Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Eighth Interim (October 1, 2019-January 31, 2020) and Prior Compensation Periods; (II) 

Final Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Final Fee Period [ECF No. 13824] (the “Third Interim Fee Order”). Pursuant to 

the Third Interim Fee Order, GJB was awarded $1,171,906.40 in fees and reimbursement of 

expenses in the amount of $33,296.95. 

35. On November 16, 2020, GJB filed its Fourth Interim Fee Application for the period 

from February 1, 2020 through August 31, 2020 [ECF No. 15142] (the “Fourth Interim Fee 

Application”). 

36. On March 8, 2021, the Court entered the Omnibus Order Awarding (I). Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Eighth Interim (June 1, 2020-September 30, 2020) and Prior Compensation Periods; (II) 

Final Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Final Fee Period [ECF No. 15971] (the “Fourth Interim Fee Order”). Pursuant 

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to the Fourth Interim Fee Order, GJB was awarded $887,215.80 in fees and reimbursement of 

expenses in the amount of $54,671.58. 

37. On April 15, 2021, GJB filed its Fifth Interim Fee Application for the period from 

September 1, 2020 through January 31, 2021 [ECF No. 16068] (the “Fifth Interim Fee 

Application”). 

38. On August 3, 2021, the Court entered the Omnibus Order Awarding (I). Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Eleventh Interim (October 1, 2020-January 31, 2021) and Prior Compensation Periods; 

[ECF No. 17646] (the “Fifth Interim Fee Order”). Pursuant to the Fifth Interim Fee Order, GJB 

was awarded $393,780.03 in fees and reimbursement of expenses in the amount of $28,860.55. 

39. On April 15, 2021, GJB filed its Sixth Interim Fee Application for the period from 

February 1, 2021-May 1, 2021 [ECF No. 17365] (the “Sixth Interim Fee Application”). 

40. On October 4, 2021, the Court entered the Omnibus Order Awarding (I). Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Twelfth Interim (February 1, 2021-May 31, 2021) and Prior Compensation Periods [ECF 

No. 18371] (the “Sixth Interim Fee Order”). Pursuant to the Sixth Interim Fee Order, GJB was 

awarded $260,272.72 in fees and reimbursement of expenses in the amount of $35,727.69. 

41. On November 15, 2021, GJB filed its Seventh Interim Fee Application for the 

period from June 1, 2021 through September 30, 2021 [ECF No. 19219] (the “Seventh Interim Fee 

Application”). 

42. On March 18, 2022, the Court entered the Omnibus Order Awarding: Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Thirteenth Interim (June 1, 2021 – September 30, 2021) and Prior Compensation Periods

[ECF No. 20412] (the “Seventh Interim Fee Order”). Pursuant to the Seventh Interim Fee Order, 

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GJB was awarded $163,364.88 in fees and reimbursement of expenses in the amount of 

$30,614.97. 

43. On August 31, 2022, GJB filed its Eighth Interim Fee application for the period 

from October 1, 2021 – December 31, 2021 [ECF No. 21992] (the “Eighth Interim Fee 

Application”). 

44. On October 28, 2022, the Court entered the Supplemental Omnibus Order 

Awarding: Interim Allowance of Compensation for Professional Services Rendered and 

Reimbursement of Expenses for the Fifteenth Interim (February 1, 2022 – May 31, 2022) and Prior 

Compensation Periods [ECF No. 22727] (the “Eighth Interim Fee Order”). Pursuant to the Eighth 

Interim Fee Order, GJB was awarded $278,543.20 in fees and reimbursement of expenses in the 

amount of $19,344.38. 

45. On November 15, 2022, GJB filed its Ninth Interim Fee application for the period 

from January 1, 2022 – July 31, 2022 [ECF No. 22880] (the “Ninth Interim Fee Application”). 

46. On January27, 2023, the Court entered the Omnibus Order Awarding: Interim 

Allowance of Compensation for Professional Services Rendered and Reimbursement of Expenses 

for the Sixteenth Interim (June 1, 2022 – September 30, 2022) and Prior Compensation Periods; 

(II) Final Allowance of Compensation for Professional Services Rendered and Reimbursement of 

Expenses for the Final Fee Period for Certain Professionals [ECF No. 23408] (the “Eighth Interim 

Fee Order”). Pursuant to the Eighth Interim Fee Order, GJB was awarded $117,740.40 in fees and 

reimbursement of expenses in the amount of $11,383.83. 

COMPENSATION AND REIMBURSEMENT REQUEST

47. By this Application, GJB seeks an order authorizing (a) allowance of final 

compensation for professional services rendered to the Committee during the Application Period 

in the aggregate amount of $21,574.00 and (b) allowance of reimbursement of actual and necessary 

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expenses incurred by GJB in the aggregate amount of $2,069.08. These amounts were for legal 

services provided to the Committee in connection with the Commonwealth Title III case. 

48. During the Application Period, GJB attorneys and paraprofessionals expended a 

total of 56.20 hours for which compensation is requested. All services rendered and expenses 

incurred for which compensation or reimbursement is requested were performed or incurred for or 

on behalf of the Committee. 

49. As a courtesy to the Committee and based on circumstances unique to the Title III 

Case, during the Application Period GJB voluntarily applied a 20% discount of its hourly rates 

totaling $4,314.80. For details regarding the waived fees, please see the Certification of 

Mariaelena Gayo-Guitian filed concurrently. 

50. As noted herein, by this Final Fee Application, GJB seeks final approval, and final 

allowance and payment of all fees and expenses incurred for services rendered during the 

Application Period and of all previously requested compensation (including all paid amounts and 

holdbacks). 

51. There is no agreement or understanding between GJB and any other person other 

than the attorneys, employees, and staff of GJB, for the sharing of compensation to be received 

for services rendered in these cases. 

52. GJB maintains computerized records, in the form of monthly statements, of the time 

spent by all GJB’s attorneys and paraprofessionals in connection with its representation of the 

Committee. The monthly statements are in the same form regularly used by GJB to bill its clients 

for services rendered and include the date that the services were rendered, a detailed, and 

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. 

53. The fees charged by GJB in the Title III Case are billed in accordance with its 

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existing billing rates and procedures in effect during the Application Period. The rates GJB 

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

are comparable to the rates GJB charges for professional and paraprofessional services rendered 

in comparable non-bankruptcy related matters. 

54. GJB’s rates are set at a level designed to fairly compensate GJB for the work of its 

attorneys and paraprofessionals to cover fixed and routine overhead expenses. GJB operates in a 

national marketplace for legal services in which rates are driven by multiple factors relating to the 

individual lawyer, his or her area of specialization, the firm’s expertise, performance and 

reputation, the nature of the work involved, and other factors. Accordingly, GJB set its rates for 

attorneys and paraprofessionals both in the restructuring group and related litigation groups within 

the firm by reference to market information and market adjustments by firms considered to be 

industry peers. Based on this and reviews of contemporaneous time records and fee applications 

filed in other cases, GJB’s endeavors to set the hourly rates for its attorneys and paraprofessionals 

at levels comparable to those of its principal competitor firms. 

55. As is customary, and as permitted pursuant to paragraph 2 of the Retention Order, 

every year GJB reviews its rate structure and, when appropriate, adjusts its hourly rates based 

upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market 

for legal services, (iii) the rates charged for comparable non-bankruptcy services, and (iv) the 

firm’s analysis of the hourly rates being charged by professionals in other law firms. 

56. GJB’s professional services during the Application Period required an aggregate 

expenditure of 56.20 recorded hours by GJB’s attorneys and paraprofessionals broken down as 

follows: partners (30.70) and paraprofessionals (25.50). During the Application Period, GJB’s 

billing rates for attorneys rendering services in this matter ranged from $305.00 to $765.00 per 

hour. As a courtesy to the Committee, no rate increases were made in January 2022 for the 

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incoming year. 

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

disbursements incurred relate to the Application Period, but were not processed before the 

preparation of this Application, or GJB has for any other reason not sought compensation or 

reimbursement with respect to such services or expenses, GJB reserves the right to request 

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

or future application. 

58. Pursuant to, and consistent with, the relevant requirements of the Guidelines, as 

applicable, the following exhibits are attached hereto and incorporated by reference: 

 Exhibit A- Certification of Mariaelena Gayo-Guitian 

 Exhibit B- contains disclosures regarding “customary and 

comparable compensation.” 

 Exhibit C contains a summary of GJB’s timekeepers included in 

this Application. 

 Exhibit D contains the budgets for GJB’s services during the 

Application Period. 

 Exhibit E 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 E-1 contains summary of compensation requested by 

project category as compared to budget. 

 Exhibit E-2 contains a summary of the expense reimbursements 

requested by category. An itemized schedule of all such expenses 

is included in GJB’s monthly statements. 

 Exhibit F contains a breakdown of compensation and expense 

reimbursement requested by Debtors and by whether the services 

were rendered in Puerto Rico or outside Puerto Rico. 

 Schedule 1 contains a list of the professionals providing Services 

during the Application Period by matter. 

 Schedule 2 includes the monthly fee statements covered in this 

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Application. 

 Schedule 3 includes the proposed order approving this Application. 

SUMMARY OF SERVICES PERFORMED BY GJB DURING 

THE APPLICATION PERIOD 

 

 59. Set forth below is a description of the professional services rendered by GJB during 

the Application Period broken down by project category. The following services described are not 

intended to be a comprehensive summary of the work performed by GJB. Detailed descriptions of 

all services rendered by GJB can be found in the detailed time records reflecting the services 

performed by GJB’s professionals, the time expended by each professional, and the hourly rate of 

each professional, annexed to the Monthly Fee Statements attached as Schedule 2 and such 

descriptions are incorporated herein by reference. 

60. GJB respectfully submits that the services for which it seeks compensation in this 

Application were necessary for and beneficial to the Committee, and were rendered to protect, 

preserve, and maximize the value for unsecured creditors during the pendency of these Title III 

cases. Accordingly, in light of the nature and complexity of these Title III cases, GJB’s charges 

for professional services performed and expenses incurred are reasonable under applicable 

standards. For all these reasons, GJB respectfully requests that the Court grant the Application 

and allow final compensation for professional services performed and reimbursement for expenses 

as requested. 

61. For ease of reference and transparency purposes, GJB created several matter 

numbers for its representation of the Committee. The matter numbers are divided as follows: 

Matter ID Matter Name

001 Official Committee of Unsecured Creditors 

002 PREPA Adversary Litigation 

003 ERS Adversary Litigation 

004 HTA Adversary Litigation 

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005 Kobre & Kim Investigation Report Database 

Review 

I. Official Committee of Unsecured Creditors of Commonwealth of Puerto Rico 

 (Matter ID 001) 

(a) Fee/Employment Applications (GJB) (Task Code B160) 

 Fees: $16,617.00 Total Hours: 43.40 

62. During the Application Period, GJB prepared and filed its Ninth Interim Fee 

Application and related exhibits [Doc No. 22880]. GJB also responded to inquiries from the Fee 

Examiner. 

(b) Fee/Employment Objections (Task Code B170) 

 Fees: $3,565.00 Total Hours: 6.20 

63. During the Application Period, GJB, among other things, had communications with 

Mr. Nicholas Hahn related to PRRADA Disclosures. Additionally, GJB had communications with 

the Fee Examiner related to resolution of comments and objections to GJB’s Eighth Interim Fee 

Application. 

 (c) General Litigation (Task Code B191)

 Fees: $1,392.00 Total Hours: 6.60 

64. The hours allocated in the General Litigation category were inadvertently entered 

under the incorrect task code and pertain to Fee/Employment Applications (Task Code B160). 

 II. PREPA (Matter ID 002) 

65. During the Application Period there was no time billed in this matter. 

III. ERS (Matter ID 003) – N/A 

66. During the Application Period there was no time billed in this matter. 

 IV. HTA (Matter ID 004) – N/A 

67. During the Application Period there was no time billed in this matter. 

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V. Kobre & Kim Investigation Report Database Review (Matter ID 005)- N/A 

68. During the Application Period there was no time billed in this matter. 

ATTENDANCE AT HEARINGS

69. In accordance with the presumptions set forth in the Order on Fee Examiner’s

Motion to Impose Presumptive Standards and Timeliness Requirements for Professional Fee

Applications [Docket No. 3932] (the “Presumptive Standards Order”), GJB provides the following 

summary regarding the attendance of GJB’s professionals at Court hearings: 

 GJB did not attend Court hearings during the Application Period. 

ACTUAL AND NECESSARY DISBURSEMENTS

70. As set forth in Exhibit D-2, GJB disbursed $2,069.08 as expenses incurred in 

providing professional services during the Application Period. 

71. The time constraints imposed by the circumstances of the matters handled by GJB 

during the Application 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 

inquiries on a daily basis, and satisfy the Committee’s needs and demands. Attorneys and other 

GJB 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. 

GJB’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. 

72. GJB believes the rates for charges incurred are the market rates that the majority of 

law firms charge clients for such services. In addition, GJB believes that such charges are in 

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

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

charges. 

REQUESTED COMPENSATION SHOULD BE ALLOWED

73. Section 316 of PROMESA provides for the compensation of professionals. 

Specifically, section 316 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 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; 

(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. 

74. In the instant case, GJB respectfully submits that the services for which it seeks 

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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 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. The results 

obtained to date have benefited not only the Committee but also the Debtors, their stakeholders, 

and other interested parties. Accordingly, the compensation requested is reasonable in light of the 

nature, extent, and value of such services to the Committee, the Debtors, and all parties in interest. 

75. 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, GJB sought to minimize the costs of GJB’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 GJB attorneys was utilized for the vast majority of 

the work in order to minimize the costs of intra-GJB communication and education about the Title 

III Cases. As demonstrated by this Application, GJB spent its time economically and without 

unnecessary duplication. Accordingly, approval of the compensation sought herein is warranted. 

NOTICE

76. In accordance with the Interim Compensation Order, GJB will provide notice of 

this Application to (i) the attorneys for the Oversight Board, Proskauer Rose LLP and O’Neill & 

Borges LLC; (ii) the attorneys for the Puerto Rico Fiscal Agency and Financial Advisory 

Authority, O’Melveny & Myers LLP and Marini Pietrantoni Muñiz LLC; (iii) the Office of the 

United States Trustee for the District of Puerto Rico; (iv) the attorneys for the Official Committee 

of Retired Employees, Jenner & Block LLP and Bennazar, García & Milián, C.S.P.; (v) the Puerto 

Rico Department of Treasury; (vi) the Fee Examiner, Brady Williamson; and (vii) counsel to the 

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Fee Examiner, Godfrey & Kahn, S.C. and EDGE Legal Strategies, PSC. In addition, the notice of 

hearing with respect to this Application will be served on all parties that have filed a notice of 

appearance in the Title III Cases. 

CONCLUSION 

WHEREFORE, GJB respectfully requests entry of an order, substantially in the form 

attached hereto as Schedule 3, (i) allowing final compensation for professional services rendered 

during the Application Period in the amount of $21,574.00, representing 100% of the fees billed 

during the Application Period plus 10% holdbacks in the amount $1,725.92 (not including GJB”s 

voluntary fee reduction equal to 20% in the amount of $4,314.80) and reimbursement of $2,069.08, 

representing 100% of the actual and necessary expenses incurred during the Application Period 

(ii) authorizing and directing the Debtors’ payment of the fees allowed (net of credits for fee 

reductions) plus 100% of the expenses allowed and any amounts paid by the Debtors pursuant to 

the Third Interim Compensation Order, (iii) allowing such compensation and payment for 

professional services rendered and reimbursement of actual and necessary expenses incurred be 

without prejudice to GJB’s right to seek such further compensation and/or payment for the full 

value of services performed and expenses incurred, and (iv) granting GJB such other and further 

relief as is just. 

Dated: March 13, 2023.

 /s/ Mariaelena Gayo-Guitian 

GENOVESE JOBLOVE & BATTISTA, P.A. 

John H. Genovese, Esq. (Pro Hac Vice) 

Mariaelena Gayo-Guitian, Esq. (Pro Hac Vice)

100 SE 2nd Street, Suite 4400 

Miami, FL 33131 

Telephone: (305) 349-2300 

jgenovese@gjb-law.com

mguitian@gjb-law.com

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.1 

_____________________________________________/

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

CERTIFICATION OF MARIAELENA GAYO-GUITIAN, ESQ. IN SUPPORT OF FINAL 

FEE APPLICATION OF GENOVESE JOBLOVE & BATTISTA, P.A., AS SPECIAL 

LITIGATION COUNSEL TO OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS, FOR SERVICES RENDEREDAND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM AUGUST 1, 2022 – DECEMBER 31, 2022 

I, Mariaelena Gayo-Guitian certify that the following is true to the best of my knowledge 

information, and belief: 

1. I was an attorney and partner at Genovese Joblove & Battista, P.A. (“GJB”) through 

December 31, 2022, with four offices in Florida located at 100 SE 2nd Street, Suite 4400, Miami, 

FL 33131 (“Miami”); 200 East Broward Blvd, Suite 1110, Fort Lauderdale, FL 33301 (“Ft. 

Lauderdale”), and 100 N. Tampa Street, Suite 2600, Tampa, FL (“Tampa”). GJB also had an 

affiliate office in Caracas Venezuela located at Av. Francisco de Miranda, Torre Provincial "A" 

piso 8 oficina 81 y 82 1060 Caracas, Venezuela. 

2. I am admitted to practice law in the state of Florida. By order dated April 16, 2019, 

1 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); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5523 (LTS)) (Last Four Digits of Federal Tax ID: 3801). (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

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I was admitted to appear Pro Hac Vice in the Debtors Title III Cases [Docket No. 6330]. 

3. I am duly authorized to make this Certification on behalf of GJB. The facts set forth 

in this Certification are based upon my personal knowledge, my discussions with other GJB 

attorneys, and the review of GJB’s client/matter records by me or other GJB attorneys acting under 

my supervision and direction. 

4. In accordance with (a) Local Bankruptcy Rule 2016-1 (the “Local Guidelines”), (b) 

Appendix B of the United States Trustee Guidelines for Reviewing Applications for Compensation 

and Reimbursement of Expenses Filed Under 11 U.S.C. § 330, effective as of November 1, 2013 

(the “U.S. Trustee Guidelines”), and (c) the Third Amended Order Setting Procedures for Interim 

Compensation and Reimbursement of Expenses of Professionals entered April 12, 2022 (the “Third 

Interim Compensation Order”), this Certification is made with respect to the Tenth & Final 

Application of Genovese Joblove & Battista, P.A., as Special Litigation Counsel to Official 

Committee of Unsecured Creditors, for Services Rendered and Reimbursement of Expenses for 

the Period from August 1, 2022 – December 31, 2022 (the “Application”).2

 

5. Pursuant to section (a)(4) of the Local Guidelines, I hereby certify that I have read 

the Application and, to the best of my knowledge, information, and belief, formed after reasonable 

inquiry, (a) the compensation and reimbursement of expenses sought in the Application conforms 

with the Bankruptcy Code, the Bankruptcy Rules, the U.S. Trustee Guidelines, and the Local 

Rules, (b) the compensation and reimbursement of expenses are billed at rates no less favorable to 

the Debtors than those customarily employed by GJB generally (taking into consideration that GJB 

employs a variety of fee arrangements with its clients, including hourly fees, contingency fees and 

hybrid fees involving reduced hourly rates and reduced contingency fee percentages) and billed in 

accordance with the Engagement Letter and Retention Order; and (c) in providing a reimbursable 

2 Capitalized terms used herein shall have the same meanings given to them in the Application.

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31

services, GJB does not make a profit on that service, whether the service is performed by GJB inhouse or through a third party. 

6. In accordance with the Engagement Letter and Retention Order, GJB agreed to a 

voluntary fee reduction equal to 20%, which results in a reduction in fees in the amount of 

$4,314.80 in the Application. GJB seeks allowance of all of its fees incurred during the Application 

Period in the net amount of $21,574.00, to the extent such amount has not been paid before the 

hearing scheduled on this Application. 

7. GJB provides the following response to the request for information set forth 

in the U.S. Trustee 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: Yes. As a courtesy to the Committee and based on circumstances 

unique to the Title III Case, during the Application Period, GJB 

agreed to a voluntary reduction of its fees by an amount equal to 20% 

of the total fees sought to be paid, which reduction totals $4,314.80. 

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

budgeted for the Application Period are higher by 10% or more, did 

you discuss the reasons for the variation with the client? 

Response: The fees were below the budgeted amount, therefore the request is 

not applicable. 

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

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

Response: No.

Question: Does the 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 billing 

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. 

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32

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

to redact any privileged or other confidential information? If so, 

please quantify by hours and fees. 

Response: No. 

Question: If the application includes any rate increases since retention: (i) Did 

your client review and approve those rate increases in advance? (ii) 

Did your client agree when retaining the law firm to accept all future 

rate increases? If not, did you inform your client that they need not 

agree to modified rates or terms in order to have you continue the 

representation consistent with ABA Formal Ethics Opinion 11-458? 

Response: No rate increases have occurred since the retention date. 

8. I declare under penalty of perjury that, to the best of my knowledge and after 

reasonable inquiry, the foregoing is true and correct. 

Executed this 13th day of March, 2023. 

 

/s/ Mariaelena Gayo-Guitian

 Mariaelena Gayo-Guitian, Esq.

 GENOVESE JOBLOVE & BATTISTA, P.A. 

Mariaelena Gayo-Guitian, Esq. (Pro Hac Vice) 

 100 SE 2nd Street, Suite 4400 

 Miami, FL 33131 

 Telephone: (305) 349-2300 

 mguitian@gjb-law.com

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Document Page 32 of 56
EXHIBIT B

CUSTOMARY AND COMPARABLE COMPENSATION DISCLOSURES

(See Guidelines ¶ C.3. for definitions of terms used in this Exhibit.) 

CATEGORY 

OF 

TIMEKEEPER

(using categories 

already maintained 

by the firm)

BLENDED HOURLY RATE

NONBANKRUPTCY 

BLENDED 

HOURLY RATE

GJB BLENDED 

HOURLY RATE1

GJB BLENDED 

HOURLY RATE 

(AFTER 20%

REDUCTION)2

Partner N/A $591.09 $472.87 

Counsel N/A N/A N/A 

Associate N/A N/A N/A 

All timekeepers 

aggregated N/A $383.88 $307.10 

 

1 The calculation of GJB’s Blended Hourly Rate does not take into account GJB’s agreement to reduce its fees by an 

amount equal to 20% of its total hourly fees. 

2

 For illustrative purposes only. 

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EXHIBIT C

SUMMARY OF TIMEKEEPERS INCLUDED IN THIS 

APPLICATION

Name 

Title 

or 

Position

Department, 

Group, or 

Section 

Date of 

First 

Admission

Fees Billed 

in this 

Application

Hours Billed 

in this 

Application 

 Hourly Rate Bil In this Application

In E

Int

Appl

Genovese, John H. Partner Bankruptcy 1979 $1,989.00 2.60 $765.00 $76Gayo-Guitian, Mariaelena Partner Bankruptcy 1989 $16,157.50 28.10 $575.00 $57

Total Partner: $18,146.50 30.70 

Sardina, Jessey Paralegal $397.50 5.30 $75.00 $7Scavone, Carolyn Paralegal $2,580.00 17.20 $150.00 $15Lambdin, Vonda Paralegal $450.00 3.00 $150.00 $15

 Total Paraprofessional: $3,427.50 

Total: $21,574.00 56.20 Blended Rate: $383.88 Blended Rate Excluding Paraprofessionals:

$591.09 

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EXHIBIT D

BUDGET AND STAFFING PLAN 

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EXHIBIT D-1

BUDGETS 

N/A

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EXHIBIT D-2

STAFFING PLAN 

Period Covered: August 1, 2022 – December 31, 2022

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 08/01/22 

through 12/31/22

Average hourly rate 

for period 08/01/22 

through 12/31/22 

(net of 20% 

reduction)

Partner 

(20+ Years) 2 $591.09 $472.87 

Partner 

(10+ Years) n/a n/a n/a 

Associate n/a n/a n/a 

Paraprofessionals 3 $134.41 $107.53 

 

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EXHIBIT E 

SUMMARY OF COMPENSATION REQUESTED BY PROJECT CATEGORY

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EXHIBIT E-1 

SUMMARY OF COMPENSATION REQUESTED BY PROJECT 

CATEGORY

U.S. TRUSTEE 

TASK CODE 

AND PROJECT 

CATEGORY 

August 

2022 

September 

2022 

October 

2022 

November 

2022 

December 

2022 TOTAL 

B160 

Employment / Fee 

Applications (GJB) 

4.40 1.00 0.30 37.10 0.60 43.40 

B170 Fee and 

Employment 

Objections 

0.50 3.00 2.70 0.00 0.00 6.20 

B191 General 

Litigation 1.80 4.50 0.30 0.00 0.00 6.60 

TOTAL 

HOURS: 6.70 8.50 3.30 37.10 0.60 56.20 

TOTAL FEES: $1,337.50 $3,534.50 $1,747.50 $14,609.50 $345.00 $21,574.00 

MINUS 20% 

REDUCTION: $267.50 $706.90 $349.50 $2,921.90 $69.00 $4,314.80 

TOTAL 

FEES: 

(NET OF 

REDUCTION) 

$1,070.00 $2,827.60 $1,398.00 $11,687.60 $276.00 $17,259.20 

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FURTHER BREAKDOWN OF COMPENSATION REQUESTED 

 BY PROJECT CATEGORY AND BY MATTER 

Official Committee of Unsecured Creditors of Commonwealth of PR (Matter ID 001) 

U.S. Trustee Task Code and Project Category Hours Billed Fees Sought

B160 Fee/Employment Applications 43.40 $16,617.00 

B170 Fee/Employment Objections 6.20 $3,565.00 

B191 General Litigation 6.60 $1,392.00 

TOTAL $21,574.00 

PREPA (Matter ID 002) 

N/A

ERS (Matter ID 003) – 

N/A

HTA (Matter ID 004) – 

N/A

Kobre & Kim Report (Matter ID 005) - N/A 

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EXHIBIT E-2

SUMMARY OF EXPENSE REIMBURSEMENTS REQUESTED BY CATEGORY

Category Amount

Travel Expenses – Airfare $0.00 

Travel Expenses – Lodging $0.00 

Travel Expenses - Taxi / Ground Transportation $0.00 

Travel Expenses – Parking $0.00 

Meals (while working on Committee matters) $0.00 

Court call $0.00 

Long Distance Phone Calls $0.00 

Process Service Fee $0.00 

Messenger $0.00 

Computer Search $205.60 

Articles and Publications $0.00 

Court Reporting Services $0.00 

In-house Black and White Reproduction Charges $1,377.00

Outside Photocopies $0.00 

Outside Professional Services $0.00 

Postage/Express Mail $486.48 

Data Management/Web Hosting $0.00 

Miscellaneous- Website Domain and Maintenance $0.00 

TOTAL $2,069.08 

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EXHIBIT F 

BREAKDOWN OF COMPENSATION AND EXPENSE REIMBURSEMENT AND BY 

WHETHER SERVICES WERE RENDERED IN PUERTO RICO OR OUTSIDE 

PUERTO RICO

Fee Statement 

N/A 

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SCHEDULE 1

LIST OF PROFESSIONALS BY 

MATTER

Official Comm. of Unsecured Creditors of Commonwealth of PR (Matter ID 001)

Name Title or Position Department, Group, or

Section

Genovese, John H. Partner Bankruptcy 

Gayo-Guitian, Mariaelena Partner Bankruptcy 

Sardina, Jessey Paralegal Bankruptcy 

Lambdin, Vonda Paralegal Bankruptcy 

Scavone, Carolyn Paralegal Bankruptcy 

PREPA (Matter ID 002) 

– N/A

ERS (Matter ID 003) 

– N/A

HTA (Matter ID 004) 

-N/A

Kobra & Kim Report (Matter ID 005) 

 – N/A 

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SCHEDULE 2

 MONTHLY STATEMENTS COVERED IN APPLICATION

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Document Page 44 of 56
February 21, 2023

Invoice Number:108523

PROMESA - Official Committee of Unsecured Creditors

,

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

For fees for professional services

$21,574.00

Costs incurred and advanced $2,069.08

Current Fees and Costs Due $23,643.08

for the period endingDecember 31, 2022

Client/Matter # 012272 000001

PROMESA - Official Committee of Unsecured Creditors

PROMESA: Official Committee of Unsecured Creditors /

(Services rendered outside of Puerto Rico)

-

Miami, Florida 33131

GJB Tax I.D. No.: 65-0518134

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Genovese Joblove & Battista, P.A.

Employer ID# 65-0518134

Please Refer to

SUMMARY / REMITTANCE COPY

We encourage our lcients to pay via ACH, however, in the event that you pay by check, please send payment to the 

remittance address below:

Remittance Address

Genovese Joblove & Battista, P.A.

Attn.: Accounts Receivable

100 Southeast Second Street, 44th FL

066004367

Wire and ACH/Wire Instructions:

ABA Routing Number: 

Beneficiary Bank: 

Miami, FL 33131

City National Bank of Florida

100 SE 2nd Street

Miami, FL 33131

Swift Code (Optional): CNBFUS3M

Account Number: 30000160777

Account Name: Genovese Joblove & Battista, P.A.

For payment, please reference the invoice, client and matter number(s) being paid.

Please refer all questions to Ken Forrest @ 305-349-2312 or via email @ kforrest@gjb-law.com

TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We sttrongly encourage clients

to confirm any change in wiring instructions by contacting Ken Forrest @ 305-349-2312 or via email @

kforrest @ gjb-law.com and requesting written and verbal confirmation.

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February 21, 2023

Please Refer to

108523

For Professional Services Rendered

December 31, 2022

Invoice Number:

PROMESA - Official Committee of Unsecured Creditors

,

Miami, Florida 33131

Telephone: (305) 349-2300Facsimile: (305) 349-2310

100 Southeast Second Street, 44th Floor

Employer ID# 65-0518134

RE: PROMESA: Official Committee of Unsecured Creditors /

Special Conflict Counsel

GJB Tax I.D. No.: 65-0518134

for the period ending

Genovese Joblove & Battista, P.A.

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

8/12/2022 CAS Preparation of Monthly Fee Objection letter for

January. Finalize and serve. Calendar objection

deadline. [B160]

0.80 $150.00 $120.00

8/23/2022 VLL Review of Eight Interim Fee Application and

e-mail from M. Guitian regarding preparation for

filing with Court. [B160]

0.30 $150.00 $45.00

8/24/2022 VLL Review e-mail from M. Guitian regarding filing

Eighth Interim Fee Application, review and

correct dates on Fee application (.4); Review of

Court of Puerto Rico's Order Further Amended

Case Management Procedures, email same to

M. Guitian (.3); Telephone call and e-mail

correspondence with J. Sardina regarding

co-counsel, filing fee application and possible

hearing date (.3). [B160]

1.00 $150.00 $150.00

8/24/2022 VLL Review of docket for Promesa, review and

download several fee applications, e-mail same

to M. Guitian. [B160]

0.40 $150.00 $60.00

8/30/2022 VLL E-mail correspondence with M. Guitian and J.

Sardina regarding filing 8th interim fee

application. [B160]

0.20 $150.00 $30.00

8/30/2022 VLL Review and revise Eighth Interim Fee Application

of Genovese Joblove and Battista to correct

hearing date and deadline to object (.4); E-mail

final version to M. Guitian (.1). [B160]

0.50 $150.00 $75.00

8/31/2022 MGG Review Eighth Interim Fee Application for filing. 

Review Notice and COS. [B160]

0.60 $575.00 $345.00

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PROMESA - Official Committee of Unsecured Creditors Page: 2

012272 000001

Invoice No.108523

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

8/31/2022 VLL Review, finalize and file Eighth Interim Fee

Application of Genovese Joblove & Battista, P.A.

for period of October 1, 2021 - December 31,

2021 (.3); Revise and file Notice of Filing of

Eighth Interim Fee Application of Genovese

Joblove & Battista (.2); E-mail filed copies to M.

Guitian (.1). [B160]

0.60 $150.00 $90.00

9/1/2022 MGG Coordinate with Jessey Sardina re: service of

Eighth Interim Fee Application. [B160]

1.00 $575.00 $575.00

10/27/2022 MGG Receipt and review Informative Motion of the Fee

Examiner Pursuant to Order Regarding

Procedures for November 2-3 Omnibus Hearing.

[B160]

0.30 $575.00 $172.50

11/1/2022 MGG Communications with paralegals re: hearing on

GJB's 8th Interim Fee Application. Review Order

on Omnibus Hearing and Fee Examiner's Report

and recommendation re: GJB's fees. [B160]

1.00 $575.00 $575.00

11/10/2022 MGG Review docket and interim fee guidelines (1.0). 

Review pending open invoices (.5). [B160]

1.50 $575.00 $862.50

11/14/2022 MGG Review Third Amended Order Setting

Procedures for Interim and Final Compensation

and reimbursement of Expenses (. 5). Work on

background for 9th and Final Fee Application

(4.0). Communications with J. Sardinia and C.

Scavone re: submission of invoices approved

and holdback amounts (1.0). Communications

with Lillian Rice re: Prebills (.40). [B160]

5.90 $575.00 $3,392.50

11/14/2022 CAS Preparation of Summary Cover Sheet for the

Ninth & Final Fee Application. [B160]

0.50 $150.00 $75.00

11/14/2022 CAS Preparation of draft Ninth & Final Fee

Application. [B160]

1.00 $150.00 $150.00

11/14/2022 CAS Pull and review case docket. Pull and review

Third Interim Fee Order and Procedures for

Compensation and prior fee application. [B160]

0.50 $150.00 $75.00

11/14/2022 CAS Interoffice meeting with L. Rice re: January and

February invoices in preparation for Final Fee

Application. [B160]

0.40 $150.00 $60.00

11/14/2022 CAS Preparation of Certification of Mariaelena

Gayo-Guitian in Support of Ninth & Final Fee

Application. [B160]

0.50 $150.00 $75.00

11/14/2022 CAS Preparation of draft Exhibits to Final Fee

Application. Organization of January fee letter

and invoices. [B160]

0.60 $150.00 $90.00

11/14/2022 CAS E-mail correspondence with M. Guitian and J.

Sardina re: deadline for filing fee application and

strategy. [B160]

0.40 $150.00 $60.00

11/15/2022 MGG Review and approve open pre-bills (.6). Work on

9th and Final Fee Application. Various

communications with Carolyn Scavone (6.5).

[B160]

7.10 $575.00 $4,082.50

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PROMESA - Official Committee of Unsecured Creditors Page: 3

012272 000001

Invoice No.108523

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

11/15/2022 CAS Continue revisions and drafting of Ninth and

Final Fee Application and Summary Cover

Sheet. [B160]

1.50 $150.00 $225.00

11/15/2022 CAS Preparation of exhibit Prior Interim Fee

Applications. [B160]

0.50 $150.00 $75.00

11/15/2022 CAS Revise and finalize Certification of Mariaelena

Gayo-Guitian, Esq. in Support of the Ninth and

Final Fee Application for GJB. [B160]

0.80 $150.00 $120.00

11/15/2022 CAS Preparation of Exhibit B - Customary and

Comparable Compensation Disclosures.

Conference with K. Forrest re: same. [B160]

0.50 $150.00 $75.00

11/15/2022 CAS Preparation of Exhibit C - Summary of

Timekeepers Included in this Application.

Conference with K. Forrest re: same. [B160]

1.00 $150.00 $150.00

11/15/2022 CAS Compile Exhibit D-1 Budget for February 2022.

[B160]

0.30 $150.00 $45.00

11/15/2022 CAS Prepare Exhibit D-2 - Staffing Plan. [B160] 0.40 $150.00 $60.00

11/15/2022 CAS Preparation of Exhibit E-1 Summary of

Compensation Required by Project Category.

Conference with K. Forrest re: same. [B160]

1.50 $150.00 $225.00

11/15/2022 CAS Preparation of Further Breakdown of

Compensation Requested by Project Category

and by Matter. [B160]

1.20 $150.00 $180.00

11/15/2022 CAS Preparation of Exhibit E-2 Summary of Expense

Reimbursements Required by Category. [B160]

0.40 $150.00 $60.00

11/15/2022 CAS Preparation of Exhibit F - Breakdown of

Compensation and Expense Reimbursement

and by Whether Services were rendered in

Puerto Rico or outside Puerto Rico. [B160]

0.50 $150.00 $75.00

11/15/2022 CAS Preparation of Schedule 1 - List of Professionals

by Matter. [B160]

0.60 $150.00 $90.00

11/15/2022 CAS Preparation of Schedule 2 - Monthly Statements

Covered in Application. [B160]

0.30 $150.00 $45.00

11/15/2022 CAS Preparation of Proposed Order Granting Ninth &

Final Fee Application of GJB. [B160]

0.70 $150.00 $105.00

11/15/2022 CAS Receipt and review invoices and billing reports

from L. Rice for the months January 1, 2022

through July 31, 2022 in preparation for the Ninth

and Final Fee Application. [B160]

0.50 $150.00 $75.00

11/15/2022 CAS Finalize and file Ninth and Final Fee Application

of GJB, as Special Counsel to Official

Committee of Unsecured Creditors. [B160]

0.60 $150.00 $90.00

11/15/2022 CAS Finalize and file Notice of Filing Ninth and Final

Fee Application of GJB for the period January 1,

2022 - July 31, 2022. [B160]

0.40 $150.00 $60.00

11/15/2022 CAS Multiple meetings with K. Forrest and M. Guitian

re: filing of the Ninth and Final Fee Application.

[B160]

0.50 $150.00 $75.00

11/18/2022 MGG Review Fee Order on service of Fee Application

and communications with Carolyn Scavone

regarding same. [B160]

1.00 $575.00 $575.00

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PROMESA - Official Committee of Unsecured Creditors Page: 4

012272 000001

Invoice No.108523

-

Date Initials Description Hours Rate Amount

B160 Fee/Employment Applications

11/18/2022 CAS Calendar Fee Application Objection deadline and

Hearing date. [B160]

0.30 $150.00 $45.00

11/21/2022 MGG Review form Notice of Hearing for Interim Fee

Application (.30). Communications with C.

Scavone regarding same (.30). [B160]

0.60 $575.00 $345.00

11/28/2022 JHG Review final fee application and notice of filing.

[B160]

1.30 $765.00 $994.50

11/28/2022 MGG Communications with Ignacio Labarca re:

payment of holdbacks and clarification of

examiner's recommendations. (.5). Review 8th

Interim Fee Application and Fee Examiner's

comments for response. (1.50). 

Communications with Jessey Sardinia re: service

of Ninth and Final Fee Application (.3). [B160]

2.30 $575.00 $1,322.50

12/15/2022 MGG Communications with Nicholas Hahn re: request

for LEDES data in support of Final Fee

Application. [B160]

0.60 $575.00 $345.00

B170 Fee/Employment Objections

8/15/2022 MGG Receipt and review email from Monsita Arribas,

Office of U.S. Trustee with PRRADA Status

Report and filing attachment. [B170]

0.50 $575.00 $287.50

9/9/2022 MGG Review and response to detailed letter from

Nicholas Hahn Fee Examiner re: Eighth Interim

Fee Application. [B170]

1.00 $575.00 $575.00

9/14/2022 MGG Review open invoices and deadlines for filing fee

applications. [B170]

1.00 $575.00 $575.00

9/15/2022 MGG Review correspondence from Nicholas Hahn

counsel to Fee Examiner with comments to GJB

Eighth Interim Fee Application (.30). Response

to Mr. Hahn (.30). Memo to Accounting re: next

interim fee application (.2). [B170]

0.80 $575.00 $460.00

9/16/2022 MGG Review email from Nicholas Hahn counsel to

Fee Examiner. [B170]

0.20 $575.00 $115.00

10/24/2022 MGG Review status of Promesa deadlines and Fee

Application (.6). Review prebills (1.7). Review 

Sixteenth Amended Notice, Case Management

and Administrative Procedures Order (.4). [B170]

2.70 $575.00 $1,552.50

B191 General Litigation

8/24/2022 JNS Confer call with Vonda regarding e-filing of GJB's

Eighth Fee Application. Assist Vonda Lambdin

and Marielena Guitian making some revisions to

GJB's Eight Fee Application. [B191]

0.40 $75.00 $30.00

8/30/2022 JNS Communications between Marielena Guitian,

Vonda Lambdin and me regarding the e-filing of

the GJB Eigth Fee Application. Phone call with

Joelie Perez at the office of Juan Casillas in

Puerto Rico. [B191]

0.60 $75.00 $45.00

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PROMESA - Official Committee of Unsecured Creditors Page: 5

012272 000001

Invoice No.108523

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Date Initials Description Hours Rate Amount

B191 General Litigation

8/31/2022 JNS Research the Promesa procedures for service of

documents, draft a Certificate of Service for GJB

Eighth Fee Application and Notice of Hearing.

Circulate to the GJB Promesa Team for approval

for e-filing. [B191]

0.80 $75.00 $60.00

9/1/2022 JNS Prepare label from the Master Service List to

serve, via U.S. mail, Genovese joblove and

Battista, P.A.'s Eighth Interim Fee Application for

Compensations for Services and

Reimbursement of Expenses from October 1,

2021 through December 31, 2021 [DE 21992],

and the Notice of Hearing [DE 21993].

Coordinate the service of same (.5).

Review Master Service list, create a list of all

email addresses for all parties to be serve by

email, prepare and serve emails on all parties

listed on the Master Service List the Eighth

Interim Fee Application for Compensations for

Services and Reimbursement of Expenses from

October 1, 2021 through December 31, 2021

[DE 21992], and the Notice of Hearing [DE

21993]. Attention to returned confirmation

request emails and submit confirmation email to

all those (1.8)

Emails with Mariaelena and Vonda Lambdin

regarding same. [B191]

3.20 $75.00 $240.00

9/19/2022 JHG Review status of payment and holdbacks. [B191] 1.30 $765.00 $994.50

10/25/2022 JNS Review calendar, review promesa court page,

review Docket and CMO. Email to Carolyn

Scavone regarding deadline to file GJB's Last

Fee Application. [B191]

0.30 $75.00 $22.50

Total 56.20 $21,574.00

Timekeeper Summary

ID Timekeeper Name Title BillHours BillRate BillAmount

JHG John H. Genovese Senior Partner 2.60 $765.00 $1,989.00

MGG Mariaelena Gayo-Guitian Partner 28.10 $575.00 $16,157.50

VLL Vonda L. Lambdin Paralegal 3.00 $150.00 $450.00

JNS Jessey N. Sardina Paralegal 5.30 $75.00 $397.50

CAS Carolyn A. Scavone Paralegal 17.20 $150.00 $2,580.00

Total $56.20 $21,574.00

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PROMESA - Official Committee of Unsecured Creditors Page: 6

012272 000001

Invoice No.108523

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Costs incurrent and advanced

Date Description Amount

09/01/2022 Photocopies -- Photocopies (Color) 7820 @ 0.00 [E100 - E101](7820 @

$0.10)

$782.00

09/30/2022 PACER Service Center- Online Research- Pacer 12272-001 [E100 -

E106]

$113.60

11/28/2022 Photocopies -- Photocopies (Color) 5950 @ 0.00 [E100 - E101](5950 @

$0.10)

$595.00

11/28/2022 Postage [E100 - E108] $486.48

12/31/2022 PACER Service Center- Online Research- 4th Qtr 12272-001 [E100 -

E106]

$92.00

Total Costs incurrent and advanced $2,069.08

Current Fees and Costs $23,643.08

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PROMESA - Official Committee of Unsecured Creditors Page: 7

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Invoice No.108523

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TASK RECAP

Services

Category Hours Amount Category

Disbursements

Amount

B160 43.40 $16,617.00 E100 - E101 $1,377.00

B170 6.20 $3,565.00 E100 - E106 $205.60

B191 6.60 $1,392.00 E100 - E108 $486.48

56.20 $21,574.00 $2,069.08

BREAKDOWN BY PERSON

Person Category Hours Amount

JHG John H. Genovese B160 1.30 $994.50

JHG John H. Genovese B191 1.30 $994.50

MGG Mariaelena Gayo-Guitian B160 21.90 $12,592.50

MGG Mariaelena Gayo-Guitian B170 6.20 $3,565.00

VLL Vonda L. Lambdin B160 3.00 $450.00

JNS Jessey N. Sardina B191 5.30 $397.50

CAS Carolyn A. Scavone B160 17.20 $2,580.00

56.20 $21,574.00

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SCHEDULE 3

PROPOSED ORDER

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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, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.1

_____________________________________________/ 

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

ORDER GRANTING FINAL FEE APPLICATION OF GENOVESE JOBLOVE & 

BATTISTA, P.A. AS SPECIAL LITIGATION COUNSEL TO 

OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR SERVICES 

RENDERED AND REIMBURSEMENT OF EXPENSES 

FOR PERIOD FROM AUGUST 1, 2022 – DECEMBER 31, 2022

Upon consideration of the Final Fee Application (the “Application”)2 of Genovese Joblove 

& Battista, P.A. (“GJB”), as special litigation counsel to the Official Committee of Unsecured 

Creditors of all Title III Debtors (the “Committee”)3

, for an order pursuant to sections 316 and 317 

of PROMESA, section 503(b) of the Bankruptcy Code made applicable to these cases by section 

301(a) of PROMESA, Bankruptcy Rule 2016, and Local Rule 2016-1, for allowance of 

1

 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); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17-BK-4780) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings 

Authority (“PBA”) (Bankruptcy Case No. 19-BK-5523 (LTS)) (Last Four Digits of Federal Tax ID: 3801). (Title III 

case numbers are listed as Bankruptcy Case numbers due to software limitations). 

2

 Capitalized terms not defined herein shall have the meanings ascribed to them in the Application. 

3

 The Committee is the official committee of unsecured creditors for all Title III Debtors, other than PBA and COFINA. 

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compensation and reimbursement of expenses for the period from August 1, 2022 through 

December 31, 2022, the Court hereby FINDS AND DETERMINES that (i) the Court has 

jurisdiction to consider the Application and the relief requested therein pursuant to section 306(a) 

of PROMESA; (ii) venue is proper before this Court pursuant to section 307(a) of PROMESA; (iii) 

due and proper notice of the Application has been provided under the particular circumstances and 

no other or further notice need be provided; (iv) any objections to the Application having been 

resolved; (v) all persons with standing having been afforded the opportunity to be heard on the 

Application; and after due deliberation and sufficient cause appearing therefor, it is hereby 

ORDERED THAT:

1. The Application is granted on a final basis. 

2. GJB’s claim for fees and expenses for services rendered during the Application 

Period and reimbursement for actual and necessary expenses incurred during the Application 

Period are hereby allowed in the amounts of $21,574.00 and $2,069.08 respectively. 

3. To the extent the amounts described in paragraph 2 hereof have not already been 

paid pursuant to the Interim Compensation Order, (a) the Debtors are directed to pay GJB the 

outstanding fees in the amount of $21,574.00 which represents 100% of the fees requested within 

fourteen days of the date of this Order, and any such payment shall be made net of any payments 

made by the Debtors pursuant to the Interim Compensation Order, withholding or other applicable 

taxes, and (b) the Debtors are directed to reimburse GJB for its outstanding expenses in the amount 

of $2,069.08, which represents 100% of the expenses requested within fourteen days of the date of 

this Order. 

4. This Court shall retain jurisdiction to hear and determine all matters arising from 

the implementation of this Order. 

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5. GJB is authorized and empowered to take all necessary actions to implement the 

relief granted in this Order. 

6. Notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 

9014, or otherwise, the terms and conditions of this Order shall be immediately effective and 

enforceable upon its entry. 

7. All time periods set forth in this Order shall be calculated in accordance with 

Bankruptcy Rule 9006(a).

Dated:_____________, 2023. ___________________________________________ 

HON. LAURA TAYLOR SWAIN 

UNITED STATES DISTRICT JUDGE

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