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EXHIBIT C-1

BUDGET

Period Covered: February 1, 2018 through February 28, 201815

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

Period February 1,

2018 through

February 28, 2018

B110 Case Administration 40

B112 General Creditor Inquiries 5

B113 Pleadings Review 75

B120 Asset Analysis and Recovery 5

B140 Relief from Stay / Adequate Protection Proceedings 5

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 50

B155 Court Hearings 60

B160 Employment / Fee Applications 40

B161 Budgeting (Case) 5

B180 Avoidance Action Analysis 20

B185 Assumption / Rejection of Leases and Contracts 5

B190 Other Contested Matters 75

B191 General Litigation 700

B195 Non-Working Travel16 15

B210 Debtors’ Financial Information and Operations/Fiscal Plan 35

B220 Employee Benefits / Pensions 5

B230 Financing / Cash Collections 5

 

15 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; (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.

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

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B231 Security Document Analysis 30

B260 Meetings of and Communications with Debtors/Oversight 

Board 20

B261 Investigations 115

B310 Claims Administration and Objections 25

B320 Plan and Disclosure Statement 50

TOTAL HOURS 1,385

TOTAL ESTIMATED FEE $302,567.1017

 

17 The Total Estimated Fees are calculated based on a $218.46 blended hourly rate for the attorneys who are expected 

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

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Period Covered: March 1, 2018 through March 31, 201818

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

Period March 1,

2018 through

March 31, 2018

B110 Case Administration 40

B112 General Creditor Inquiries 5

B113 Pleadings Review 75

B120 Asset Analysis and Recovery 5

B140 Relief from Stay / Adequate Protection Proceedings 5

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 150

B155 Court Hearings 40

B160 Employment / Fee Applications 40

B161 Budgeting (Case) 5

B180 Avoidance Action Analysis 20

B185 Assumption / Rejection of Leases and Contracts 5

B190 Other Contested Matters 75

B191 General Litigation 500

B195 Non-Working Travel19 15

B210 Debtors’ Financial Information and Operations/Fiscal Plan 35

B220 Employee Benefits / Pensions 5

B230 Financing / Cash Collections 5

B231 Security Document Analysis 20

B260 Meetings of and Communications with Debtors/Oversight 

Board 20

B261 Investigations 80

 

18 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 isthe only adversaryproceeding 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 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.

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

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B310 Claims Administration and Objections 25

B320 Plan and Disclosure Statement 40

TOTAL HOURS 1,210

TOTAL ESTIMATED FEE $264,336.6020

 

20 The Total Estimated Fees are calculated based on a $218.46 blended hourly rate for the attorneys who are expected

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

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Period Covered: April 1, 2018 through April 30, 201821

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

Period April 1,

2018 through

April 30, 2018

B110 Case Administration 50

B112 General Creditor Inquiries 5

B113 Pleadings Review 75

B120 Asset Analysis and Recovery 5

B140 Relief from Stay / Adequate Protection Proceedings 5

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 200

B155 Court Hearings 50

B160 Employment / Fee Applications 40

B161 Budgeting (Case) 5

B180 Avoidance Action Analysis 20

B185 Assumption / Rejection of Leases and Contracts 5

B190 Other Contested Matters 75

B191 General Litigation 500

B195 Non-Working Travel22 15

B210 Debtors’ Financial Information and Operations/Fiscal Plan 35

B220 Employee Benefits / Pensions 5

B230 Financing / Cash Collections 5

B231 Security Document Analysis 20

B260 Meetings of and Communications with Debtors/Oversight 

Board 20

B261 Investigations 80

 

21 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; (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.

22

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

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B310 Claims Administration and Objections 175

B320 Plan and Disclosure Statement 40

TOTAL HOURS 1,430

TOTAL ESTIMATED FEE $306,020.0023

 

23 The Total Estimated Fees are calculated based on a $214.00 blended hourly rate for the attorneys who are expected 

to work on this matter during the period from April 1, 2018 through April 30, 2018.

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Period Covered: May 1, 2018 through May 31, 201824

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

for Period May 1, 

2018 through May

31, 2018

B110 Case Administration 40

B112 General Creditor Inquiries 10

B113 Pleadings Review 40

B120 Asset Analysis and Recovery 5

B130 Asset Disposition 5

B140 Relief from Stay / Adequate Protection Proceedings 5

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 40

B155 Court Hearings 20

B160 Employment / Fee Applications 20

B161 Budgeting (Case) 5

B165 Fee and Employment Applications of Other Professionals 5

B180 Avoidance Action Analysis 5

B185 Assumption / Rejection of Leases and Contracts 10

B190 Other Contested Matters (including GDB restructuring) 75

B191 General Litigation (including Commonwealth-COFINA litigation, 

mediation process, and handling of adversary proceedings).

250

B195 Non-Working Travel25

15

 

24 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; (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 thistime.

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

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B210 Debtors’ Financial Information and Operations/Fiscal Plan 5

B230 Financing / Cash Collections 35

B231 Security Document Analysis. 5

B260 Meetings of and Communications with Debtors/Oversight 

Board 20

B261 Investigations (including Whitefish Contract and PBA 

Structure). 25

B310 Claims Administration and Objections

40

B312 Objections to Claims

40

B320 Plan and Disclosure Statement 15

TOTAL HOURS 735

TOTAL ESTIMATED FEE $150,583.3326

 

26 The Total Estimated Fees are calculated based on a $216 blended hourly rate for the CST Law attorneys who are 

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

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EXHIBIT C-2

STAFFING PLAN

Period Covered: February 1, 2018 through February 28, 201827

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

Partner 3 $270.00

Junior Partner 2 $240.00

Counsel 1 $240.00

Senior Associate 4 $200.00

Associate 3 $170.00

Paraprofessionals 3 $95.00

 

27 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.

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Period Covered: March 1, 2018 through March 31, 201828

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 March 1, 2018

through March 28, 2018

Partner 3 $270.00

Junior Partner 2 $240.00

Counsel 1 $240.00

Senior Associate 4 $200.00

Associate 3 $170.00

Paraprofessionals 3 $95.00

 

28 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 isthe 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 thistime.

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Period Covered: April 1, 2018 through April 30, 201829

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 April 1, 2018

through April 30, 2018

Partner 3 $270.00

Junior Partner 2 $240.00

Counsel 1 $240.00

Senior Associate 5 $200.00

Associate 4 $170.00

Paraprofessionals 1 $95.00

 

29 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.

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Period Covered: May 1, 2018 through May 31, 201830

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 May 1, 2018

through May 31, 2018

Partner 3 $270

Junior Partner & Counsel 2 $240

Senior Associate 4 $200

Associate 3 $170

Paraprofessionals 1 $95

 

30 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; (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 thistime.

Case:17-03283-LTS Doc#:3562-5 Filed:07/16/18 Entered:07/16/18 20:07:39 Desc:

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