EXHIBIT C 

BUDGET AND STAFFING PLAN 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 1 of 13
EXHIBIT C-1 

BUDGET 

Period Covered: February 1, 2018 through February 28, 20181

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

Period 2/1/2018 

through 2/28/2018 

B110 Case Administration 250

B112 General Creditor Inquiries 5

B113 Pleadings Review 100

B120 Asset Analysis and Recovery 10

B140 Relief from Stay / Adequate Protection Proceedings 5

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 100

B155 Court Hearings (including Preparation for Court Hearings) 80

B160 Employment / Fee Applications (Paul Hastings and Other 

Professionals) 60

B161 Budgeting (Case) 5

B180 Avoidance Action Analysis 25

B185 Assumption / Rejection of Leases and Contracts 5

B190 Other Contested Matters 75

B191 General Litigation 1,300

B195 Non-Working Travel2 15

 

1

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed budget may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. At this time, the proposed budget is speculative, including, without 

limitation, because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases 

remains uncertain at this time. 

2

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

travel. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 2 of 13
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B210 Debtors’ Financial Information and Operations/Fiscal Plan 50

B220 Employee Benefits / Pensions 5

B230 Financing / Cash Collections 5

B231 Security Document Analysis 40

B260 Meetings of and Communications with Debtors/Oversight 

Board 35

B261 Investigations 150

B310 Claims Administration and Objections 75

B320 Plan and Disclosure Statement 75

TOTAL HOURS 2,462.5

TOTAL ESTIMATED FEES $2,203,938.503

MINUS 20% REDUCTION4 ($440,787.50)

TOTAL ESTIMATED FEES (NET OF REDUCTION) $1,763,150.00

 

3 The Total Estimated Fees are calculated based on a $895 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from February 1, 2018 through February 28, 2018. 

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

this time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% 

reduction, would be approximately $716. 

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

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

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

may designate its entire final fee application as the source of this reduction or a combination of reductions 

across other fee application. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 3 of 13
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Period Covered: March 1, 2018 through March 31, 20185

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

Period 3/1/2018 

through 3/31/2018 

B110 Case Administration 320

B112 General Creditor Inquiries 5

B113 Pleadings Review 100

B120 Asset Analysis and Recovery 10

B140 Relief from Stay / Adequate Protection Proceedings 10

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 350

B155 Court Hearings (including Preparation for Court Hearings) 60

B160 Employment / Fee Applications 120

B161 Budgeting (Case) 5

B180 Avoidance Action Analysis 25

B185 Assumption / Rejection of Leases and Contracts 5

B190 Other Contested Matters 75

B191 General Litigation 1,450

B195 Non-Working Travel6 15

B210 Debtors’ Financial Information and Operations/Fiscal Plan 50

B220 Employee Benefits / Pensions 5

B230 Financing / Cash Collections 25

B231 Security Document Analysis 5

 

5

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed budget may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. At this time, the proposed budget is speculative, including, without 

limitation, because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases 

remains uncertain at this time. 

6

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

travel. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 4 of 13
-4- 

B260 Meetings of and Communications with Debtors/Oversight 

Board 30

B261 Investigations 100

B310 Claims Administration and Objections 50

B320 Plan and Disclosure Statement 50

TOTAL HOURS 2,857.5

TOTAL ESTIMATED FEES $2,600,325.007

MINUS 20% REDUCTION8 ($520,065.00)

TOTAL ESTIMATED FEES (NET OF REDUCTION) $2,080,260.00

 

7 The Total Estimated Fees are calculated based on a $910 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from March 1, 2018 through March 31, 2018. The 

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

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% discount, 

would be approximately $728. 

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

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

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

may designate its entire final fee application as the source of this reduction or a combination of reductions 

across other fee application. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 5 of 13
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Period Covered: April 1, 2018 through April 30, 20189

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

Period 4/1/2018 

through 4/30/2018 

B110 Case Administration 300

B112 General Creditor Inquiries 10

B113 Pleadings Review 100

B120 Asset Analysis and Recovery 10

B130 Asset Disposition 10

B140 Relief from Stay / Adequate Protection Proceedings 10

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 150

B155 Court Hearings (including Preparation for Court Hearings) 100

B160 Employment / Fee Applications (Paul Hastings) 75

B161 Budgeting (Case) 5

B165 Fee and Employment Applications of Other Professionals 5

B180 Avoidance Action Analysis 25

B185 Assumption / Rejection of Leases and Contracts 20

B190 Other Contested Matters (including GDB restructuring) 100

B191 General Litigation 1,600

B195 Non-Working Travel10 20

B210 Debtors’ Financial Information and Operations/Fiscal Plan 20

 

9

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed budget may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. Similarly, the Committee may need to respond to motions that are not 

and cannot be anticipated. At this time, the proposed budget is speculative, including, without limitation, 

because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases remains uncertain 

at this time. 

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

travel. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 6 of 13
-6- 

B230 Financing / Cash Collections 75

B231 Security Document Analysis 5

B260 Meetings of and Communications with Debtors/Oversight 

Board 40

B261 Investigations 100

B310 Claims Administration and Objections 300

B320 Plan and Disclosure Statement 50

TOTAL HOURS 3,120

TOTAL ESTIMATED FEES $2,758,080.0011

MINUS 20% REDUCTION12 ($551,616.00)

TOTAL ESTIMATED FEES (NET OF REDUCTION) $2,206,464.00

 

11 The Total Estimated Fees are calculated based on a $884 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from April 1, 2018 through April 31, 2018. The 

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

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% reduction, 

would be approximately $707. 

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

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

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

may designate its entire final fee application as the source of this reduction or a combination of reductions 

across other fee application. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 7 of 13
-7- 

Period Covered: May 1, 2018 through May 31, 201813

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

Period 5/1/2018 

through 5/31/2018 

B110 Case Administration 300

B112 General Creditor Inquiries 10

B113 Pleadings Review 75

B120 Asset Analysis and Recovery 10

B130 Asset Disposition 10

B140 Relief from Stay / Adequate Protection Proceedings 10

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 150

B155 Court Hearings 50

B160 Employment / Fee Applications 75

B161 Budgeting (Case) 5

B165 Fee and Employment Applications of Other Professionals 10

B180 Avoidance Action Analysis 5

B185 Assumption / Rejection of Leases and Contracts 20

B190 Other Contested Matters 200

B191 General Litigation 1,500

B195 Non-Working Travel14 20

B210 Debtors’ Financial Information and Operations/Fiscal Plan 10

 

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed budget may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. Similarly, the Committee may need to respond to motions that are not 

and cannot be anticipated. At this time, the proposed budget is speculative, including, without limitation, 

because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases remains uncertain 

at this time. 

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

travel. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 8 of 13
-8- 

B230 Financing / Cash Collections 75

B231 Security Document Analysis 5

B260 Meetings of and Communications with Debtors/Oversight 

Board 40

B261 Investigations 25

B310 Claims Administration and Objections 150

B312 Objections to Claims 150

B320 Plan and Disclosure Statement 25

TOTAL HOURS 2,920

TOTAL ESTIMATED FEES $2,671,80015

MINUS 20% REDUCTION16 ($534,360.00)

TOTAL ESTIMATED FEES (NET OF REDUCTION) $2,137,440.00

 

15 The Total Estimated Fees are calculated based on a $915 blended hourly rate for the Paul Hastings attorneys 

who are expected to work on this matter during the period from May 1, 2018 through May 31, 2018. The 

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

time. However, for illustrative purposes only, the blended hourly rate, after accounting for the 20% reduction, 

would be approximately $732. 

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

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

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

may designate its entire final fee application as the source of this reduction or a combination of reductions 

across other fee application. 

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 9 of 13
EXHIBIT C-2 

STAFFING PLAN 

Period Covered: February 1, 2018 through February 28, 20181

Category of 

timekeeper 

(using categories 

maintained by 

the firm) 

Number of 

timekeepers expected 

to work on the matter 

during the budget 

period 

Average hourly rate 

for period February 

1, 2018 through 

February 28, 2018 

Average hourly rate 

for period February 1, 

2018 through February 

28, 2018 (net of 20% 

reduction)2

Partner 10 $1,143 $915 

Counsel 6 $1,083 $866 

Associate 18 $729 $583 

Paraprofessionals 10 $345 $276 

 

1

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; (iv) all adversary proceedings in which the Committee has intervened 

and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this proposed 

staffing plan may be materially different from the work actually performed. For instance, discovery disputes 

may lead to extensive litigation. At this time, the proposed staffing plan is speculative, including, without 

limitation, because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases 

remains uncertain at this time. 

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

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

for the 20% reduction.

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 10 of 13
-2- 

Period Covered: March 1, 2018 through March 31, 20183

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 3/1/2018 

through 3/31/2018 

Average hourly rate 

for period 3/1/2018 

through 3/31/2018 (net 

of 20% reduction)4

Partner 10 $1,172 $938 

Counsel 6 $1,109 $887 

Associate 18 $742 $594 

Paraprofessionals 10 $356 $285 

 

3

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed staffing plan may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. At this time, the proposed staffing plan is speculative, including, 

without limitation, because the full impact of Hurricane Maria on the Puerto Rico economy and the title III 

cases remains uncertain at this time. 

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

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

for the 20% reduction.

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 11 of 13
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Period Covered: April 1, 2018 through April 30, 20185

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 4/1/2018 

through 4/30/2018 

Average hourly rate 

for period 4/1/2018 

through 4/30/2018 (net 

of 20% reduction)6

Partner 10 $1,142 $913 

Counsel 6 $1,082 $865 

Associate 18 $718 $575 

Paraprofessionals 10 $346 $276 

 

5

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed budget may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. Similarly, the Committee may need to respond to motions that are not 

and cannot be anticipated. At this time, the proposed budget is speculative, including, without limitation, 

because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases remains uncertain 

at this time. 

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

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

for the 20% reduction.

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 12 of 13
-4- 

Period Covered: May 1, 2018 through May 31, 20187

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 5/1/2018 

through 5/31/2018 

Average hourly rate 

for period 5/1/2018 

through 5/31/2018 (net 

of 20% reduction)8

Partner 11 $1,177 $942 

Counsel 7 $1,126 $901 

Associate 18 $768 $614 

Paraprofessionals 15 $367 $294 

 

7

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

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

during the budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will 

require discovery and trial preparation; and (iv) all adversary proceedings in which the Committee has 

intervened and/or sought to intervene will only involve briefing and hearings on motions to dismiss. Thus, this 

proposed budget may be materially different from the work actually performed. For instance, discovery 

disputes may lead to extensive litigation. Similarly, the Committee may need to respond to motions that are not 

and cannot be anticipated. At this time, the proposed budget is speculative, including, without limitation, 

because the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases remains uncertain 

at this time. 

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

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

for the 20% reduction.

Case:17-03283-LTS Doc#:3568-3 Filed:07/16/18 Entered:07/16/18 20:51:10 Desc:

Exhibit C Page 13 of 13