Exhibit D 

Budget Plan

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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 0 - 10 $0 - $7,300 1.90 $1,387.00 

Legal Research 202 80 - 105 $58,400 -

$76,650 96.40 $63,124.00 

Hearings and other nonfiled communications 

with the Court 

203 5 - 15 $3,650 - 

$10,950 4.60 $2,686.00 

Communications with 

Claimholders 204 5 - 15 $3,650 - $10,950 9.60 $6,912.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 10 - 25 $7,300 - 

$18,250 10.30 $7,279.00 

Documents Filed on 

Behalf of the Board 206 600 - 655 $438,000 - $478,150 605.50 $426,319.00 

Non-Board Court Filings 

207 20 - 45 $14,600 - 

$32,850 34.40 $24,248.00 

Stay Matters 208 0 - 10 $0 - $7,300 0.90 $657.00 

Adversary Proceeding 209 10 - 25 $7,300 - 

$18,250 12.40 $9,052.00 

Analysis and Strategy 210 120 - 145 $87,600 - 

$105,850 121.10 $82,451.00 

Non-Working Travel 

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

General Administration 212 20 - 45 $14,600 - 

$32,850 25.90 $7,483.00 

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

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,300 0.10 $73.00 

Plan of Adjustment and 

Disclosure Statement 215 0 - 10 $0 - $7,300 0.00 $0.00 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 3 of 15
3 

PROJECT 

CATEGORY 

TASK 

CODE OCTOBER OCTOBER 

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

Appeal 219 5 - 15 $3,650 - 

$10,950 10.00 $7,300.00 

TOTALS 875 – 1,180 $638,750 - 

$861,400 933.10 $638,971.00 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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 0 - 10 $0 - $7,300 0.40 $292.00 

Legal Research 202 40 - 65 $29,200 -

$47,450 38.20 $27,214.00 

Hearings and other nonfiled communications 

with the Court 

203 140 - 165 $102,200 -

$120,450 148.30 $108,259.00 

Communications with 

Claimholders 204 5 - 15 $3,650 - $10,950 9.50 $6,935.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 0 - 10 $0 - $7,300 2.80 $2,044.00 

Documents Filed on 

Behalf of the Board 206 250 - 305 $182,500 - $222,650 265.70 $193,961.00 

Non-Board Court Filings 

207 20 - 45 $14,600 - 

$32,850 24.10 $17,065.00 

Stay Matters 208 0 - 10 $0 - $7,300 0.00 $0.00 

Adversary Proceeding 209 0 - 10 $0 - $7,300 0.90 $657.00 

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

$47,450 43.70 $31,517.00 

Non-Working Travel 

Time 211 0 - 10 $0 - $7,300 1.20 $876.00 

General Administration 212 40 - 65 $29,200 - 

$47,450 55.70 $14,117.00 

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

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,300 0.70 $511.00 

Plan of Adjustment and 

Disclosure Statement 215 0 - 10 $0 - $7,300 0.00 $0.00 

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

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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 2.60 $650.00 

Appeal 219 0 - 10 $0 - $7,300 2.00 $1,460.00 

TOTALS 535 – 845 $390,550 - 

$616,850 595.80 $405,558.00 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 7 of 15
7 

Exhibit D-3 

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

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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 0 - 10 $0 - $7,300 2.90 $2,117.00 

Legal Research 202 0 - 10 $0 - $7,300 4.90 $3,577.00 

Hearings and other nonfiled communications 

with the Court 

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

Communications with 

Claimholders 204 10 - 25 $7,300 -$18,250 10.20 $7,446.00 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 0 - 10 $0 - $7,300 4.70 $3,431.00 

Documents Filed on 

Behalf of the Board 206 20 - 45 $14,600 - $32,850 29.40 $21,462.00 

Non-Board Court Filings 

207 5 - 15 $3,650 - 

$10,950 6.10 $4,453.00 

Stay Matters 208 0 - 10 $0 - $7,300 0.00 $0.00 

Adversary Proceeding 209 0 - 10 $0 - $7,300 1.00 $730.00 

Analysis and Strategy 210 5 - 15 $3,650 - 

$10,950 7.00 $5,110.00 

Non-Working Travel 

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

General Administration 212 0 - 10 $0 - $7,300 0.30 $75.00 

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

Legal/ Regulatory 

Matters 214 0 - 10 $0 - $7,300 0.00 $0.00 

Plan of Adjustment and 

Disclosure Statement 215 0 - 10 $0 - $7,300 0.00 $0.00 

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

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

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 9 of 15
9 

PROJECT 

CATEGORY 

TASK 

CODE DECEMBER DECEMBER 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

Employment and Fee 

Applications 218 10 - 25 $7,300 - $18,250 15.50 $4,211.00 

Appeal 219 20 - 45 $14,600 - 

$32,850 29.20 $21,316.00 

TOTALS 70 – 300 $51,100 - 

$219,000 111.20 $73,928.00 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 10 of 15
10 

Exhibit D-4 

Budget Plan for the Period of January 1, 2018 through January 31, 2018 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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 80 - 100 $60,800 - 

$76,000 0.70 $531.30 

Legal Research 202 100 - 150 2.00 2.00 $1,518.00 

Hearings and other nonfiled communications 

with the Court 

203 20 - 40 $15,200 - 

$30,400 0.00 $0.00 

Communications with 

Claimholders 204 30 - 60 $22,800 - $45,600 124.40 $94,419.60 

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities 

205 80 - 160 $60,800 - 

$121,600 5.10 $3,870.90 

Documents Filed on 

Behalf of the Board 206 200 - 350 $152,000 - $266,000 8.60 $6,527.40 

Non-Board Court Filings 

207 100 - 140 $76,000 - 

$106,400 20.00 $15,180.00 

Stay Matters 208 10 - 25 $7,600 - 

$19,000 0.20 $52.00 

Adversary Proceeding 209 100 - 150 $76,000 - 

$114,000 0.10 $75.90 

Analysis and Strategy 210 80 - 180 $60,800 - 

$136,800 3.30 $2,504.70 

Non-Working Travel 

Time 211 10 - 30 $7,600 - $22,800 3.20 $2,428.80 

General Administration 212 30 - 50 $22,800 - 

$38,000 1.90 $494.00 

Labor, Pension Matters 213 0 - 5 $0 - $3,800 0.00 $0.00 

Legal/ Regulatory 

Matters 214 0 - 5 $0 - $3,800 0.00 $0.00 

Plan of Adjustment and 

Disclosure Statement 215 50 - 200 $38,000 - $152,000 0.00 $0.00 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 12 of 15
12 

PROJECT 

CATEGORY 

TASK 

CODE JANUARY 2018 JANUARY 2018 

 EST. 

HOURS 

EST. 

FEES 

HOURS 

BILLED 

FEES 

SOUGHT 

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

Tax 217 10 - 20 $7,600 - 

$15,200 1.30 $338.00 

Employment and Fee 

Applications 218 65 - 80 $49,400 - $60,800 0.60 $156.00 

Appeal 219 0 - 20 $0 - $15,200 13.00 $9,867.00 

TOTALS 965 – 

1,770 

$733,400 – 

$1,345,200 184.40 $137,963.60 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 13 of 15
13 

Exhibit D-5 

Staffing Plan for the Compensation Period 

Case:17-03283-LTS Doc#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 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 18 $730/ $759 

Senior Counsel 1 $730/ $759 

Associates 22 $730/ $759 

Law Clerks 2 $250/ $260 

Paraprofessionals 14 $250/ $260 

 

1

 Attorney Practice Groups: Bankruptcy (12); Litigation (25); Corporate (4). 

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”); 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#:2874-4 Filed:04/09/18 Entered:04/09/18 20:20:56 Desc:

Exhibit D Page 15 of 15