Exhibit D 

Budget Plan

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 1 of 15
Exhibit D-1 

Budget Plan for the Period of October 1, 2017 through October 31, 2017 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 2 of 15
2 

PROJECT 

CATEGORY 

TASK 

CODE OCTOBER OCTOBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 10 - 25 $7,300 - 

$18,250 9.80 $5,762.00 

Legal Research 202 20 - 45 $14,600 - 

$32,850 33.20 $21,644.00 

Hearings and other nonfiled communications 

with the Court 

203 0 - 10 $0 - $7,300 0.00 $0.00 

Communications with 

Claimholders 204 20 - 45 $14,600 - $32,850 40.50 $29,565.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 10 - 25 $7,300 - 

$18,250 17.10 $12,483.00 

Documents Filed on 

Behalf of the Board 206 350 - 405 $255,500 - $295,650 357.40 $248,470.00 

Non-Board Court Filings 

207 20 - 45 $14,600 - 

$32,850 28.10 $17,297.00 

Stay Matters 208 20 - 45 $14,600 - 

$32,850 40.80 $21,720.00 

Adversary Proceeding 209 20 - 45 $14,600 - 

$32,850 25.30 $18,469.00 

Analysis and Strategy 210 20 - 45 $14,600 - 

$32,850 32.20 $20,914.00 

Non-Working Travel 

Time 211 0 - 10 $0 - $7,300 0.00 $0.00 

General Administration 212 40 - 65 $29,200 - 

$47,450 45.70 $13,297.00 

Labor, Pension Matters 213 0 - 10 $0 - $7,300 0.00 $0.00 

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,300 0.30 $219.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 3 of 15
3 

PROJECT 

CATEGORY 

TASK 

CODE OCTOBER OCTOBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Plan of Adjustment and 

Disclosure Statement 215 20 - 45 $14,600 - $32,850 20.00 $10,088.00 

Confirmation 216 0 - 10 $0 - $7,300 0.00 $0.00 

Tax 217 0 - 10 $0 - $7,300 0.00 $0.00 

Employment and Fee 

Applications 218 10 - 25 $7,300 - $18,250 9.00 $2,250.00 

Appeal 219 0 - 10 $0 - $7,300 1.60 $1,168.00 

TOTALS 560 – 930 $408,800 - 

$678,900 661.00 $423,346.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 4 of 15
4 

Exhibit D-2 

Budget Plan for the Period of November 1, 2017 through November 30, 2017 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 5 of 15
5 

PROJECT 

CATEGORY 

TASK 

CODE NOVEMBER NOVEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 20 - 45 $14,600 - 

$32,850 16.90 $12,337.00 

Legal Research 202 20 - 45 $14,600 - 

$32,850 23.90 $16,295.00 

Hearings and other nonfiled communications 

with the Court 

203 40 - 65 $29,200 - 

$47,450 49.00 $35,770.00 

Communications with 

Claimholders 204 20 - 45 $14,600 - $32,850 13.90 $10,147.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 20 - 45 $14,600 - 

$32,850 39.20 $28,616.00 

Documents Filed on 

Behalf of the Board 206 300 - 355 $219,000 - $259,150 344.90 $235,265.00 

Non-Board Court Filings 

207 60 - 85 $43,800 - 

$62,050 77.30 $54,989.00 

Stay Matters 208 0 - 10 $0 - $7,300 0.40 $292.00 

Adversary Proceeding 209 0 - 10 $0 - $7,300 2.80 $2,044.00 

Analysis and Strategy 210 40 - 65 $29,200 - 

$47,450 47.50 $33,907.00 

Non-Working Travel 

Time 211 0 - 10 $0 - $7,300 0.00 $0.00 

General Administration 212 40 - 65 $29,200 - 

$47,450 41.90 $10,475.00 

Labor, Pension Matters 213 0 - 10 $0 - $7,300 0.00 $0.00 

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,300 2.70 $1,971.00 

Plan of Adjustment and 

Disclosure Statement 215 0 - 10 $0 - $7,300 2.90 $2,117.00 

Confirmation 216 0 - 10 $0 - $7,300 0.00 $0.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 6 of 15
6 

PROJECT 

CATEGORY 

TASK 

CODE NOVEMBER NOVEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tax 217 0 - 10 $0 - $7,300 0.00 $0.00 

Employment and Fee 

Applications 218 0 - 10 $0 - $7,300 1.10 $803.00 

Appeal 219 120 - 175 $87,600 - 

$127,750 152.70 $105,711.00 

TOTALS 680 – 

1,080 

$496,400 - 

$788,400 817.10 $550,739.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 7 of 15
7 

Exhibit D-3 

Budget Plan for the Period of December 1, 2017 through December 31, 2017 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 8 of 15
8 

PROJECT 

CATEGORY 

TASK 

CODE DECEMBER DECEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 40 - 65 $29,200 - 

$47,450 44.60 $32,558.00 

Legal Research 202 40 - 65 $29,200 - 

$47,450 58.10 $31,901.00 

Hearings and other nonfiled communications 

with the Court 

203 0 - 10 $0 - $7,300 0.00 $0.00 

Communications with 

Claimholders 204 20 - 45 $14,600 - $32,850 18.90 $11,589.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 20 - 45 $14,600 - 

$32,850 29.20 $21,316.00 

Documents Filed on 

Behalf of the Board 206 200 - 255 $146,000 - $186,150 208.50 $152,205.00 

Non-Board Court Filings 

207 20 - 45 $14,600 - 

$32,850 26.60 $18,554.00 

Stay Matters 208 10 - 25 $7,300 - 

$18,250 12.70 $9,271.00 

Adversary Proceeding 209 0 - 10 $0 - $7,300 0.20 $146.00 

Analysis and Strategy 210 10 - 25 $7,300 - 

$18,250 19.20 $14,016.00 

Non-Working Travel 

Time 211 5 - 15 $3,650 - $10,950 7.40 $5,402.00 

General Administration 212 10 - 25 $7,300 - 

$18,250 14.80 $3,892.00 

Labor, Pension Matters 213 0 - 10 $0 - $7,300 0.00 $0.00 

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,300 0.30 $219.00 

Plan of Adjustment and 

Disclosure Statement 215 0 - 10 $0 - $7,300 0.80 $584.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 9 of 15
9 

PROJECT 

CATEGORY 

TASK 

CODE DECEMBER DECEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Confirmation 216 0 - 10 $0 - $7,300 0.00 $0.00 

Tax 217 0 - 10 $0 - $7,300 0.00 $0.00 

Employment and Fee 

Applications 218 10 - 25 $7,300 - $18,250 14.70 $4,059.00 

Appeal 219 0 - 10 $0 - $7,300 0.00 $0.00 

TOTALS 385 - 715 $281,050- 

$521,950 456.00 $305,712.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 10 of 15
10 

Exhibit D-4 

Budget Plan for the Period of January 1, 2017 through January 31, 2017 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 11 of 15
11 

PROJECT 

CATEGORY 

TASK 

CODE JANUARY 2018 JANUARY 2018 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants 

201 100 - 150 $76,000 - 

$114,000 40.00 $28,563.60 

Legal Research 202 30 - 50 $22,800 - 

$38,000 43.80 $25,609.50 

Hearings and other nonfiled communications 

with the Court 

203 10 - 30 $7,600 - 

$22,800 55.60 $42,200.40 

Communications with 

Claimholders 204 40 - 80 $30,400 - $60,800 42.70 $32,409.30 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 200 - 250 $152,000 - 

$190,000 241.70 $181,803.60 

Documents Filed on 

Behalf of the Board 206 20 - 40 $15,200 - $30,400 418.10 $309,603.40 

Non-Board Court Filings 

207 10 - 20 $7,600 - 

$15,200 20.20 $13,984.50 

Stay Matters 208 0 - 30 $0 - $22,800 15.30 $11,612.70 

Adversary Proceeding 209 0 - 5 $0 - $3,800 32.20 $24,439.80 

Analysis and Strategy 210 20 - 40 $15,200 - 

$30,400 108.10 $82,047.90 

Non-Working Travel 

Time 211 0 - 5 $0 - $3,800 1.60 $1,214.40 

General Administration 212 10 - 20 $7,600 - 

$15,200 36.00 $9,360.00 

Labor, Pension Matters 213 0 - 5 $0 - $3,800 5.70 $4,326.30 

Legal/ Regulatory 

Matters 214 0 - 15 $0 - $11,400 0.50 $379.50 

Plan of Adjustment and 

Disclosure Statement 215 50 - 100 $38,000 - $76,000 0.00 $0.00 

Confirmation 216 0 - 5 $0 - $3,800 0.00 $0.00 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 12 of 15
12 

PROJECT 

CATEGORY 

TASK 

CODE JANUARY 2018 JANUARY 2018 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Tax 217 0 - 5 $0 - $3,800 0.00 $0.00 

Employment and Fee 

Applications 218 65 - 80 $49,400 - $60,800 0.00 $0.00 

Appeal 219 0 - 40 $0 - $30,400 19.70 $14,952.30 

TOTALS 555 - 970 $421,800 - 

$737,200 1081.20 $782,507.20 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 13 of 15
13 

Exhibit D-5 

Staffing Plan for the Compensation Period 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 14 of 15
14 

Staffing Plan for the Compensation Period 

Category of Timekeeper1 Number of 

Timekeepers Expected 

to Work on The Matter 

During the Budget Period2

Average Hourly Rate3

Partners 22 $730/ $759 

Senior Counsel 1 $730/ $759 

Associates 26 $730/ $759 

Law Clerks 2 $250/ $260 

Paraprofessionals 19 $250/ $260 

 

1

 Attorney Practice Groups: Bankruptcy (14); Labor & Employment (5); Litigation (27); Corporate (3). 

2

 The chart reflects Proskauer’s staffing plan for the designated period based on currently foreseeable activities. 

Actual staffing needs, including additional attorneys, may vary materially based on actual facts and circumstances 

arising in the designated period, including as a result of currently unanticipated disputes. The staffing plan 

currently includes attorneys from the Business Solutions, Governance, Restructuring & Bankruptcy Group 

(BSGR&B); Labor & Employment; Litigation; and Corporate practice groups. The expertise of attorneys from 

other specialized areas is likely to be required during the course of these PROMESA cases. 

3

 In the ordinary course of business, the standard hourly billing rates for Proskauer professionals and 

paraprofessionals are adjusted annually as of the commencement of the firm’s fiscal year on November 1 to 

reflect economic and other conditions and apply to matters in and out of bankruptcy cases. Pursuant to the 

Appendix B Guidelines, “rate increases” “exclude annual ‘step increases’ historically awarded by the firm in the 

ordinary course to attorneys throughout the firm due to advancing seniority and promotion.” Appendix B 

Guidelines ¶ B.2.d, n.2. Annual step increases are awarded by Proskauer in the ordinary course throughout the 

firm on May 1. Proskauer’s November 25, 2016 engagement letter with the Oversight Board (a copy of which is 

available on the Oversight Board’s website at https://juntasupervision.pr.gov/wp-content/uploads/wpfd/50/ 

58b6126be2546.pdf) (the “Engagement Letter”) provides that Proskauer’s rates will be increased on January 1 

(rather than on November 1) by the lower of the percentage rate increase announced as of November 1 and four 

percent. Because Proskauer’s fees under the Engagement Letter are a blended rate (currently $759) for all 

attorneys and (currently $260) for all other professionals, no annual step increases will be applicable to the rates 

charged in this matter. 

Case:17-03283-LTS Doc#:2876-4 Filed:04/09/18 Entered:04/09/18 20:25:48 Desc:

Exhibit D Page 15 of 15