Exhibit D

Budget Plan

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 1 of 45
Exhibit D-1

Budget Plan for the Period of February 1, 2018 through February 28, 2018

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 2 of 45
2

PROJECT 

CATEGORY

TASK 

CODE FEBRUARY FEBRUARY

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 $60,720 –

$72,000 84.60 $57,874.10

Legal Research 202 20 – 40 $15,180 –

$30,360 29.90 $17,803.90

Hearings and other nonfiled communications 

with the Court

203 20 – 40 $15,180 –

$30,360 25.20 $19,126.80

Communications with 

Claimholders 204 80 – 100 $60,720 –$72,000 58.90 $44,705.10

Communications with

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 60 – 80 $45,540 –

$60,720 75.60 $57,380.40

Documents Filed on 

Behalf of the Board 206 200 – 300 $151,800 –$227,700 206.00 $147,421.90

Non-Board Court 

Filings 207 80 – 100 $60,720 –

$75,900 105.20 $79,846.80

Stay Matters 208 20 – 40 $15,180 –

$30,360 23.80 $10,479.40

Adversary Proceeding 209 0 – 20 $0 – $15,180 12.30 $9,186.00

Analysis and Strategy 210 200 – 300 $151,800 –

$227,700 280.30 $208,156.90

Non-Working Travel 

Time 211 20 – 40 $15,180 –$30,360 22.70 $17,229.30

General Administration 212 500 – 600 $379,500 –

$455,400 573.90 $153,455.50

Labor, Pension Matters 213 60 – 80 $45,540 –

$60,720 67.40 $50,258.40

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 3 of 45
3

PROJECT 

CATEGORY

TASK 

CODE FEBRUARY FEBRUARY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Plan of Adjustment and 

Disclosure Statement 215 20 – 40 $15,180 –$30,360 35.50 $26,944.50

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 20 – 40 $15,180 –$30,360 30.70 $18,361.20

Appeal 219 40 – 60 $30,360 –

$45,540 42.90 $30,215.80

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 1,420 –

2,020

$1,077,780 –

$1,533,180 1,674.90 $948,446.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 4 of 45
4

Exhibit D-2

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

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 5 of 45
5

PROJECT 

CATEGORY

TASK 

CODE MARCH MARCH

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 100 – 200 $75,900 –

$151,800 123.70 $93,040.00

Legal Research 202 20 – 40 $15,180 –

$30,360 34.20 $21,816.10

Hearings and other nonfiled communications 

with the Court

203 20 – 40 $15,180 –

$30,360 48.00 $36,432.00

Communications with 

Claimholders 204 40 – 60 $30,360 –$45,540 44.50 $33,775.50

Communications with

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 40 – 60 $30,360 –

$45,540 39.60 $29,657.20

Documents Filed on 

Behalf of the Board 206 100 – 200 $75,900 –$151,800 121.20 $89,396.00

Non-Board Court 

Filings 207 100 – 200 $75,900 –

$151,800 116.00 $87,495.10

Stay Matters 208 10 – 20 $7,590 –

$15,180 21.00 $12,895.10

Adversary Proceeding 209 0 – 10 $0 – $7,590 5.00 $3,395.80

Analysis and Strategy 210 300 – 400 $227,700 –

$303,600 340.80 $246,940.70

Non-Working Travel 

Time 211 10 – 20 $7,590 –$15,180 19.40 $14,724.60

General Administration 212 400 – 500 $303,600 –

$379,500 486.20 $133,048.70

Labor, Pension Matters 213 20 – 40 $15,180 –

$30,360 13.10 $9,942.90

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 2.50 $1,897.50

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 6 of 45
6

PROJECT 

CATEGORY

TASK 

CODE MARCH MARCH

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Plan of Adjustment and 

Disclosure Statement 215 20 – 40 $15,180 –$30,360 11.50 $6,782.40

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 10.80 $8,197.20

Employment and Fee 

Applications 218 100 – 200 $75,900 –$151,800 116.00 $57,455.30

Appeal 219 40 – 60 $30,360 –

$45,540 55.70 $36,937.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 3.30 $1,706.30

TOTALS 1,320 –

2,130

$1,001,880

–

$1,616,670

1,612.50 $925,535.40

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 7 of 45
7

Exhibit D-3

Budget Plan for the Period of April 1, 2018 through April 30, 20181

 1 Budgets are only provided for matters Proskauer actually billed time to in a given month. If no time was billed to a given 

matter during the month, no monthly budget has been provided for that matter.

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 8 of 45
8

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – General (33260/002 and 33260/024)

Tasks Relating to the

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 80 – 100 $60,720 –

$75,900 108.80 $78,936.50

Legal Research 202 40 – 60 $30,360 –

$45,540 43.00 $25,401.50

Hearings and other nonfiled communications 

with the Court

203 10 – 20 $7,590 –

$15,180 8.90 $6,755.10

Communications with 

Claimholders 204 40 – 60 $30,360 –$45,540 46.20 $26,183.60

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 40 – 60 $30,360 –

$45,540 34.30 $25,983.80

Documents Filed on 

Behalf of the Board 206 10 – 20 $7,590 –$15,180 17.30 $11,733.50

Non-Board Court 

Filings 207 20 – 40 $15,180 –

$30,360 27.00 $20,493.00

Stay Matters 208 0 – 10 $0 – $7,590 0.60 $405.50

Adversary Proceeding 209 0 – 10 $0 – $7,590 1.40 $413.90

Analysis and Strategy 210 300 – 400 $227,700 –

$303,600 332.80 $247,655.10

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 2.00 $1,518.00

General Administration 212 400 – 500 $303,600 –

$379,500 416.10 $111,728.90

Labor, Pension Matters 213 10 – 20 $7,590 –

$15,180 12.70 $9,639.30

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 1.50 $1,138.50

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 9 of 45
9

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Plan of Adjustment and 

Disclosure Statement 215 80 – 100 $60,720 –$75,900 85.80 $57,836.80

Confirmation 216 10 – 20 $7,590 –

$15,180 13.40 $10,170.60

Tax 217 10 – 20 $7,590 –

$15,180 15.20 $11,536.80

Employment and Fee 

Applications 218 80 – 100 $60,720 –$75,900 77.80 $42,433.50

Appeal 219 0 – 10 $0 – $7,590 6.00 $4,005.10

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 1.50 $1,138.50

TOTALS 1,130 –

1,580

$857,670 -

$1,199,220 1,252.30 $695,107.50

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 10 of 45
10

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – ACP Master (33260/033 & 33260/933)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 0 – 10 $0 – $7,590 2.30 $1,745.70

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 2.60 $1,973.40

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 3.70 $962.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 0.60 $455.40

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 6.30 $1,638.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 11 of 45
11

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – ACP Master (33260/033 & 33260/933)

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 200 – 300 $151,800 –

$227,700 274.20 $206,121.80

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 200 – 490 $151,800 -

$371,910 289.70 $212,896.30

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 12 of 45
12

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Healthcare (33260/034 and 33260/934)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 3.50 $2,656.50

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.70 $531.30

Documents Filed on 

Behalf of the Board 206 80 – 100 $60,720 –$75,900 82.90 $62,921.10

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 10.10 $7,665.90

Stay Matters 208 0 – 10 $0 – $7,590 2.80 $2,125.20

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 6.30 $4,781.70

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 10 – 20 $7,590 –

$15,180 12.20 $3,172.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 13 of 45
13

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 90 – 300 $68,310 -

$227,700 118.50 $83,853.70

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 14 of 45
14

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – UPR (33260/036 & 33260/936)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 0.80 $607.20

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 0 – 10 $0 – $7,590 0.00 $0.00

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 0.00 $0.00

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 3.00 $2,277.00

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 0.00 $0.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 15 of 45
15

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – UPR (33260/036 & 33260/936)

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 0 – 200 $0 -

$151,800 3.80 $2,884.20

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 16 of 45
16

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Commonwealth/COFINA Dispute (33260/037 and 33260/937)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 3.30 $2,504.70

Hearings and other nonfiled communications 

with the Court

203 40 – 60 $30,360 –

$45,540 50.60 $38,405.40

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.30 $227.70

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.60 $455.40

Documents Filed on 

Behalf of the Board 206 80 – 100 $60,720 –$75,900 71.10 $53,964.90

Non-Board Court 

Filings 207 10 – 20 $7,590 –

$15,180 20.00 $15,180.00

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 4.80 $3,643.20

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 10.30 $2,678.00

General Administration 212 0 – 10 $0 – $7,590 0.00 $0.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 17 of 45
17

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 130 – 350 $98,670 -

$265,650 161.00 $117,059.30

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 18 of 45
18

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Rule 2004 (33260/033 & 33260/933)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 10 – 20 $7,590 –

$15,180 17.80 $13,510.20

Legal Research 202 0 – 10 $0 – $7,590 0.20 $151.80

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 6.10 $4,629.90

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 1.30 $986.70

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 10 – 20 $7,590 –

$15,180 12.70 $9,639.30

Documents Filed on 

Behalf of the Board 206 40 – 60 $30,360 –$45,540 41.30 $31,346.70

Non-Board Court 

Filings 207 10 – 20 $7,590 –$15,180 21.30 $15,917.20

Stay Matters 208 0 – 10 $0 – $7,590 0.60 $455.40

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 40 – 60 $30,360 –

$45,540 55.50 $41,425.90

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.30 $227.70

General Administration 212 10 – 20 $7,590 –

$15,180 11.00 $2,860.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 19 of 45
19

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Rule 2004 (33260/033 & 33260/933)

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 200 – 300 $151,800 –

$227,700 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 200 – 490 $151,800 -

$371,910 168.10 $121,150.80

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 20 of 45
20

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Cooperativas (33260/040 and 33260/940)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 2.20 $1,669.80

Legal Research 202 0 – 10 $0 – $7,590 8.70 $6,353.80

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 2.80 $2,125.20

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 3.30 $2,504.70

Documents Filed on 

Behalf of the Board 206 20 – 40 $60,720 –$75,900 35.60 $27,020.40

Non-Board Court 

Filings 207 20 – 40 $0 – $7,590 12.60 $9,563.40

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 20 – 40 $0 – $7,590 24.80 $18,823.20

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 0.00 $0.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 21 of 45
21

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 60 – 290 $45,540 -

$220,110 90.00 $68,060.50

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 22 of 45
22

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Miscellaneous (33260/041 & 33260/941)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.40 $303.60

Legal Research 202 10 – 20 $7,590 –

$15,180 18.80 $14,269.20

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.20 $151.80

Documents Filed on 

Behalf of the Board 206 10 – 20 $7,590 –$15,180 19.90 $15,104.10

Non-Board Court 

Filings 207 20 – 40 $15,180 –$30,360 31.80 $24,136.20

Stay Matters 208 20 – 40 $15,180 –

$30,360 25.10 $19,001.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 1.80 $1,366.20

Analysis and Strategy 210 10 – 20 $7,590 –

$15,180 11.00 $8,349.00

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 0.70 $182.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 2.80 $2,125.20

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 23 of 45
23

PROJECT 

CATEGORY

TASK 

CODE APRIL APRIL

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Miscellaneous (33260/041 & 33260/941)

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 20 – 40 $15,180 –

$30,360 21.90 $16,622.10

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 90 – 320 $68,310 -

$242,880 134.40 $101,610.40

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 24 of 45
24

Exhibit D-4

Budget Plan for the Period of May 1, 2018 through May 31, 20182

 2 Budgets are only provided for matters Proskauer actually billed time to in a given month. If no time was billed to a given 

matter during the month, no monthly budget has been provided for that matter.

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 25 of 45
25

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – General (33260/002 and 33260/024)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 180 – 210 $95,720 –

$115,500 193.20 $104,822.60

Legal Research 202 40 – 60 $30,360 –

$45,540 42.90 $20,635.00

Hearings and other nonfiled communications 

with the Court

203 10 – 20 $7,590 –

$15,180 19.50 $11,457.20

Communications with 

Claimholders 204 165 – 185 $120,460 –$135,840 172.10 $126,881.40

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 10 – 20 $7,590 –

$15,180 13.30 $10,094.70

Documents Filed on 

Behalf of the Board 206 40 – 60 $30,360 –$45,540 38.60 $27,501.00

Non-Board Court 

Filings 207 20 – 40 $15,180 –

$30,360 31.50 $23,907.80

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 10 – 20 $7,590 –

$15,180 13.40 $10,170.60

Analysis and Strategy 210 500 – 600 $327,700 –

$403,600 516.90 $364,932.00

Non-Working Travel 

Time 211 10 – 20 $7,590 –$15,180 16.10 $12,219.90

General Administration 212 400 – 500 $133,600 –

$140,500 436.20 $133,671.40

Labor, Pension Matters 213 40 – 60 $30,360 –

$45,540 45.80 $34,762.20

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 26 of 45
26

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 2.50 $1,797.70

Plan of Adjustment and 

Disclosure Statement 215 300 – 400 $210,520 –$275,900 357.90 $225,987.60

Confirmation 216 40 – 60 $30,360 –

$45,540 41.10 $30,745.80

Tax 217 0 – 10 $0 – $7,590 .40 $203.80

Employment and Fee 

Applications 218 40 – 60 $30,360 –$45,540 36.20 $26,877.00

Appeal 219 10 – 20 $7,590 –

$15,180 16.20 $6,407.60

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 1.90 $1,442.10

TOTALS 1,815–

2,375

$1,092,660 -

$1,435,570 1,995.70 $1,174,518.10

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 27 of 45
27

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – ACP Master (33260/033 & 33260/933)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 0 – 10 $0 – $7,590 2.80 $2,125.20

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 4.30 $3,263.70

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 9.00 $6,831.00

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 1.80 $468.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 28 of 45
28

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – ACP Master (33260/033 & 33260/933)

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 275 – 375 $240,800 –

$275,700 341.00 $257,222.20

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 275 – 565 $240,800-

$419,910 358.90 $269,910.10

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 29 of 45
29

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Healthcare (33260/034 and 33260/934)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 2.40 $1,821.60

Hearings and other nonfiled communications 

with the Court

203 20 – 40 $15,180 –

$30,360 25.30 $19,202.70

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 40 – 60 $30,360 –$45,540 51.90 $37,745.40

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 7.80 $5,920.20

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 3.20 $1,081.50

Analysis and Strategy 210 0 – 10 $0 – $7,590 2.20 $1,669.80

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 .80 $607.20

General Administration 212 10 – 20 $7,590 –

$15,180 13.40 $3,484.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 30 of 45
30

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 70 – 290 $53,130 -

$220,110 107.00 $71,532.40

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 31 of 45
31

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – UPR (33260/036 & 33260/936)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 .80 $607.20

Legal Research 202 0 – 10 $0 – $7,590 2.90 $2,201.10

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 2.40 $1,821.60

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 2.50 $1,897.50

Documents Filed on 

Behalf of the Board 206 40 – 60 $30,360 –$45,540 48.50 $36,811.50

Non-Board Court 

Filings 207 10 – 20 $7,590 –$15,180 11.80 $8,956.20

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 10 – 20 $7,590 –

$15,180 12.40 $9,411.60

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 1.30 $338.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 .10 $26.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 32 of 45
32

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – UPR (33260/036 & 33260/936)

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 60 – 260 $45,540 -

$204,930 82.70 $62,070.70

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 33 of 45
33

PROJECT 

CATEGORY

TASK

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Commonwealth/COFINA Dispute (33260/037 and 33260/937)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 .50 $379.50

Legal Research 202 0 – 10 $0 – $7,590 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 10 – 20 $7,590 –

$15,180 18.80 $14,269.20

Communications with 

Claimholders 204 10 – 20 $7,590 –$15,180 11.20 $8,500.80

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 10 – 20 $7,590 –$15,180 11.10 $8,424.90

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 4.20 $3,187.80

Stay Matters 208 0 – 10 $0 – $7,590 0.30 $227.70

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 3.10 $2,352.90

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 3.20 $2,428.80

General Administration 212 0 – 10 $0 – $7,590 3.40 $884.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 34 of 45
34

PROJECT 

CATEGORY

TASK

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 30 – 230 $22,770 -

$182,160 55.80 $40,655.60

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 35 of 45
35

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Rule 2004 (33260/033 & 33260/933)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 10 – 20 $7,590 –

$15,180 18.80 $14,269.20

Legal Research 202 0 – 10 $0 – $7,590 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 40 – 60 $30,360 –

$45,540 54.70 $41,517.30

Communications with 

Claimholders 204 20 – 40 $15,180 –$30,360 23.20 $17,608.80

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 20 – 40 $15,180 –

$30,360 26.70 $20,265.30

Documents Filed on 

Behalf of the Board 206 100 – 120 $70,460 –$90,540 105.00 $77,399.60

Non-Board Court 

Filings 207 20 – 40 $15,180 –$30,360 27.80 $21,100.20

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.30 $227.70

Analysis and Strategy 210 100 – 120 $70,460 –

$90,540 107.40 $81,516.60

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 3.20 $2,428.80

General Administration 212 20 – 40 $15,180 –

$30,360 36.80 $9,568.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.90 $683.10

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 36 of 45
36

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Rule 2004 (33260/033 & 33260/933)

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 330 - 600 $239,590 -

$371,910 404.80 $286,584.60

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 37 of 45
37

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Cooperativas (33260/040 and 33260/940)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 .60 $455.40

Legal Research 202 0 – 10 $0 – $7,590 2.90 $2,201.10

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 5.00 $3,795.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 .50 $379.50

Documents Filed on 

Behalf of the Board 206 70 – 90 $60,720 –$75,900 73.50 $55,786.50

Non-Board Court 

Filings 207 0 – 10 $0 – $7,590 2.10 $1,593.90

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 0.00 $0.00

Analysis and Strategy 210 0 – 10 $0 – $7,590 3.20 $2,428.80

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 0.00 $0.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 38 of 45
38

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 70 – 280 $45,540 -

$220,110 87.80 $66,640.20

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 39 of 45
39

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Miscellaneous (33260/041 & 33260/941)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 2.90 $2,201.10

Legal Research 202 0 – 10 $0 – $7,590 4.70 $3,567.30

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 2.80 $2,125.20

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 1.30 $986.70

Documents Filed on 

Behalf of the Board 206 120 – 140 $97,590 –$125,180 135.20 $102,616.80

Non-Board Court 

Filings 207 10 – 20 $7,590 –$15,180 10.10 $7,665.90

Stay Matters 208 10 – 20 $7,590 –

$15,180 13.70 $10,398.30

Adversary Proceeding 209 0 – 10 $0 – $7,590 6.00 $4,554.00

Analysis and Strategy 210 10 – 20 $7,590 –

$15,180 19.70 $14,952.30

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 4.60 $1,196.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 1.50 $1,138.50

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 40 of 45
40

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Miscellaneous (33260/041 & 33260/941)

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 10 – 20 $7,590 –

$15,180 5.90 $4,478.10

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 160 - 370 $127,900 -

$299,750 208.40 $155,880.20

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 41 of 45
41

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Assured (33260/060 & 33260/960)

Tasks Relating to the 

Board, its Members, its 

Staff, its Advisors or its 

Consultants

201 0 – 10 $0 – $7,590 0.00 $0.00

Legal Research 202 0 – 10 $0 – $7,590 0.00 $0.00

Hearings and other nonfiled communications 

with the Court

203 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

Claimholders 204 0 – 10 $0 – $7,590 0.00 $0.00

Communications with 

the Commonwealth, its 

Instrumentalities or 

Representatives of the 

Commonwealth or its 

Instrumentalities

205 0 – 10 $0 – $7,590 0.00 $0.00

Documents Filed on 

Behalf of the Board 206 0 – 10 $0 – $7,590 1.90 $1,442.10

Non-Board Court 

Filings 207 10 – 20 $7,590 –$15,180 14.80 $11,233.20

Stay Matters 208 0 – 10 $0 – $7,590 0.00 $0.00

Adversary Proceeding 209 0 – 10 $0 – $7,590 7.40 $5,616.00

Analysis and Strategy 210 10 – 20 $7,590 –

$15,180 14.10 $10,701.90

Non-Working Travel 

Time 211 0 – 10 $0 – $7,590 0.00 $0.00

General Administration 212 0 – 10 $0 – $7,590 2.40 $624.00

Labor, Pension Matters 213 0 – 10 $0 – $7,590 0.00 $0.00

Legal/ Regulatory 

Matters 214 0 – 10 $0 – $7,590 0.00 $0.00

Plan of Adjustment and 

Disclosure Statement 215 0 – 10 $0 – $7,590 0.00 $0.00

Confirmation 216 0 – 10 $0 – $7,590 0.00 $0.00

Tax 217 0 – 10 $0 – $7,590 0.00 $0.00

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 42 of 45
42

PROJECT 

CATEGORY

TASK 

CODE MAY MAY

EST. 

HOURS

EST.

FEES

HOURS 

BILLED

FEES 

SOUGHT

Commonwealth – Assured (33260/060 & 33260/960)

Employment and Fee 

Applications 218 0 – 10 $0 – $7,590 0.00 $0.00

Appeal 219 0 – 10 $0 – $7,590 0.00 $0.00

Fee Applications for 

Other Parties 220 0 – 10 $0 – $7,590 0.00 $0.00

TOTALS 20 – 220 $15,180 -

$166,980 40.60 $29,617.80

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 43 of 45
43

Exhibit D-5

Staffing Plan for the Compensation Period

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 44 of 45
44

Staffing Plan for the Compensation Period

Category of Timekeeper3 Number of 

Timekeepers Expected 

to Work on The Matter 

During the Budget Period4

Average Hourly Rate5

Partners 28 $759

Senior Counsel 2 $759

Associates 30 $759

Law Clerks 3 $260

Paraprofessionals 22 $260

 3 [Attorney Practice Groups: BSGR&B (13); Tax (3); Labor & Employment (3); Litigation (36); Corporate (8).]

4 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); Tax; 

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.

5 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. As detailed in 

the Second Interim Application, Proskauer’s rates under the Engagement Letter increased from $730 per hour for 

attorneys and $250 per hour for paraprofessionals to $759 per hour for attorneys and $260 per hour for 

paraprofessionals on January 1, 2018, during the second interim compensation period. Rates have not increased 

during this Compensation Period.

Case:17-03283-LTS Doc#:3588-6 Filed:07/16/18 Entered:07/17/18 00:20:23 Desc:

Exhibit D Page 45 of 45