Hearing Date: November 7, 2018 at 9:30 a.m. (Atlantic Time) 

Objection Deadline: August 6, 2018 at 4:00 p.m. (Atlantic Time)

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

PROMESA

Title III

as representative of Case No. 17-BK-3283 (LTS)

THE COMMONWEALTH OF PUERTO RICO, et al., (Jointly Administered)

Debtors.1

THIRD INTERIM APPLICATION OF NILDA M. NAVARRO-CABRER, AS 

LOCAL COUNSEL TO BETTINA M. WHYTE, AS THE COFINA AGENT, FOR 

INTERIM ALLOWANCE OF COMPENSATION 

FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES

INCURRED FROM FEBRUARY 1, 2018 THROUGH MAY 31, 2018

 1 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number and the last 

four (4) digits of each Debtor’s federal tax identification number, as applicable, are the (i) Commonwealth 

of Puerto Rico (Bankruptcy Case No. 17 BK 3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) 

Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last 

Four Digits of Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) 

(Bankruptcy Case No. 17 BK 3567-LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case 

No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); and (v) Puerto Rico Electric Power 

Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 

3747).

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EXHIBITS

Exhibit 1 – Certification of Nilda M. Navarro-Cabrer

Exhibit 2 – Summary of Professionals for the Application Period

Exhibit 3 – Summary of Expenses for the Application Period

Exhibit 4 – Summary of Time by Billing Category for the Application Period

Exhibit 4-A – Time and Expense Detail for the February 2018 Fee Statement

Exhibit 4-B – Time and Expense Detail for the March 2017 Fee Statement

Exhibit 4-C – Time and Expense Detail for the April 2018 Fee Statement

Exhibit 4-D – Time and Expense Detail for the May 2018 Fee Statement

Exhibit 5 – Comparable Compensation Disclosures

Exhibit 6 – Budget and Staffing Plans 

Exhibit 7 – Engagement Letter 

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SUMMARY SHEET TO THE THIRD INTERIM APPLICATION OF NAVARROCABRER FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED 

AND REIMBURSEMENT OF EXPENSES INCURRED AS LOCAL COUNSEL TO THE 

COFINA AGENT FROM FEBRUARY 1, 2018 THROUGH MAY 31, 2018

Name of Applicant Nilda M. Navarro Cabrer

Authorized to Provide Professional Services to Bettina M. Whyte, as COFINA Agent

Date of Retention August 16, 2017

Date of order approving- employment November 3, 2017 (Docket No. 1612), 

nunc pro tunc to August 16, 2017

Period covered by this application February 1, 2018 through May 31, 2018

Amount of interim compensation sought as actual, 

reasonable, and necessary

$103,025.00 (100% Fees)

Amount of interim expense reimbursement sought as 

actual, reasonable, and necessary

$2,379.82 (100% Expenses)

Are your fee or expense totals different from the sum of 

previously-served monthly statements

No

Blended rate in this application for all attorneys $375.00

Blended rate in this application for all timekeepers $342.05

Petition date May 5, 2017 for COFINA (as defined 

below)

Total compensation approved by interim order to date $137,875.001

Total expenses approved by interim order to date $1,215.92

Total allowed compensation paid to date $128,283.75

Total allowed expenses paid to date $1,215.92

Compensation sought in this application already paid 

pursuant to the interim compensation order but not yet 

allowed

$59,826.30

(90% of February fees and $21,103.80 of 

March fees)

Expenses sought in this application already paid 

pursuant to the interim compensation order but not yet

allowed

$ 991.02 

(100% of February and March expenses)

Number of professionals included in this application 2 

If applicable, number of professionals in this application 

not included in staffing plans approved by client

None

If applicable, difference between fees budgeted and 

compensation sought for this period

Fees Budgeted: $159,956.00

Fees Sought: $103,025.00

 1 Reflects an agreed upon fee adjustments in the amount of $750.00 for the Second Interim Period, which 

includes a voluntary reduction of $75.00 and reductions recommended by the Fee Examiner of $675.00.

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Difference: $56,931.00 

Number of professionals billing fewer than 10 hours to 

the case during this period

None

Are any rates higher than those approved or disclosed at 

retention? If yes, calculate and disclose the total 

compensation sought in this application using the rate 

originally disclosed in the retention application.

No

This is an interim application.

The total time expended for monthly and interim fee application preparation for the Application

Period is approximately 33 hours and the corresponding compensation requested is 

approximately $9,300. In addition to time expended for fee application preparation, Time billed

to the B-160 (Fee Applications and Retentions) category includes time expended for fee-related 

tasks not relating to fee application preparation, such as analysis and correspondence concerning 

Fee Examiner memoranda, communications with co-counsel an others concerning compliance 

with the Interim Compensation Order and the COFINA Protections Order (as defined below), 

and reviewing the COFINA Agent’s and co-counsel Second Interim Fee Applications to include 

Navarro-Cabrer’s signature as Local Counsel in compliance with Local Rules. Accordingly, 

even though the total amount listed in this paragraph is necessarily less than the total amount of 

fees in category B-160, this amount is accurate.

[Remainder of Page Intentionally Left Blank.]

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PRIOR INTERIM FEE APPLICATIONS & ADJUSTMENTS

Requested Approved

Date

[Docket No.]

Interim Fee 

Period (“IFP”) 

Covered

Fees Expenses Fees Expenses

12/15/2017

Dkt. No. 2038

08/16/2017 –

09/30/2017 $35,962.50 $431.50 $35,962.50 $431.50

03/19/2018

Dkt. No. 2726

10/01/2017 –

01/31/2018 $102,662.50 $784.42 $101,912.502 $784.42

Total fees and expenses approved by interim orders to date: $137,875.00 $1,215.92

PRIOR INTERIM OR MONTHLY FEE PAYMENTS TO DATE

Requested Paid

Date 

Payment 

Received

Monthly Fee Statement Paid Fees Expenses Fees Expenses

12/4/17 Monthly Fee Statement for the 

period of August 16, 2017 

through August 31, 2017 

$10,925.00 $62.50 $9,832.50 $62.50

12/4/17 Monthly Fee Statement for 

September 2017 

$25,062.50 $369.00 $22,531.253 $369.00

12/27/17 Monthly Fee Statement for 

October 2017 

$17,662.50 $323.10 $15,871.254 $323.10

 2 Navarro Cabrer and the Fee Examiner consensually agreed to a reduction of Navarro-Cabrer fees in the 

amount of $750.00.

3 The Debtors paid $25.00 less for the month of September 2017. No reason was given, but Navarro-Cabrer 

agreed to this reduction.

4 The Debtors paid $25.00 less for the month of October 2017. No reason was given, but Navarro-Cabrer 

agreed to this reduction.

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1/24/18 Monthly Fee Statement for 

November 2017

$33,837.50 $20.50 $30,428.755 $20.50

2/13/18 Monthly Fee Statement for 

December 2017

$23,450.00 $23.80 $21,080.006 $23.80

4/18/18 Monthly Fee Statement for 

January 2018

$27,712.50 $417.02 $24,941.25 $417.02

4/18/18 Monthly Fee Statement for 

February 2018

$43,025.00 $ 410.00 $38,722.50 $410.00

4/18/18 Monthly Fee Statement March 

2018

$25,100.00 $ 581.02 $21,103.80* $581.02

4/18/18 First Interim Fee Application

(August 16 – September 30

31, 2017)

$3,598.75

(10% 

holdback)

$0.00 (no 

holdback)

$3,598.75

-----

Total fees and expenses PAID to date: $188,110.05 $2,206.94

* There is an unpaid balance of $1,486.20 of the 90% of the March Fee Statement. On April 18, 2018, 

Debtors made a global payment to Navarro-Cabrer in the amount of $89,193.32, which according to an 

email dated April 24, 2018 from Mr. Joseph Spina, O’Melveny & Myers, counsel for AAFAF, was paying 

90% of the of the December 2017, January and February 2018 Monthly Fee Statements and the 10% 

holdback for August and September 2017. Since the December 2017 Statement had already been paid, it 

was agreed to apply the overpayment to the March Fee Statement, leaving an unpaid balance of $1,486.20

of the 90% of the March Fee Statement.

 5 The Debtors paid $25.00 less for the month of November 2017. No reason was given, but Navarro-Cabrer 

agreed to this reduction

6 The Debtors paid $25.00 less for the month of December 2017. No reason was given, but Navarro-Cabrer 

agreed to this reduction

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To the Honorable United States District Court Judge Laura Taylor Swain:

Nilda M. Navarro Cabrer, d/b/a Navarro-Cabrer Law Offices (“Navarro–Cabrer”), as 

Local Counsel to Bettina M. Whyte, the COFINA Agent (the “COFINA Agent”) in the abovecaptioned Title III cases ( the “Title III Cases”), hereby submits her third interim fee application 

(the “Application”) for an award of interim compensation for professional services rendered in 

the amount of $103,025.00 and reimbursement for actual and necessary expenses in connection 

with such services in the amount of $2,379.82, for the period of February 1, 2018 through May

31, 2018 (the “Application Period”). Navarro-Cabrer submits this Application pursuant to 

sections 316 and 317 of the Puerto Rico Oversight, Management, and Economic Stability Act 

(“PROMESA”),1 48 U.S.C. §§ 2176, 2177; sections 105(a) and 503(b) of chapter 11 of the 

United States Code (the “Bankruptcy Code),2 Rule 2016(a) of the Federal Rules of Bankruptcy 

Procedure (the “Bankruptcy Rules”),

3 Rule 2016-1 of the Bankruptcy Rules for the United 

States Bankruptcy Court for the District of Puerto Rico (the “Local Rules”)4, the First Amended 

Order Setting Procedures for Interim Compensation and Reimbursement of Expenses of 

Professionals (“Interim Compensation Order”) [Dkt. No. 1715] and the United States 

Trustee’s Guidelines for Reviewing Applications for Compensation and Reimbursement of 

Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Large Chapter 11 Cases Effective as of 

 1 PROMESA is codified at 48 U.S.C. §§ 2101–2241.

2 Unless otherwise noted, all Bankruptcy Code sections cited in the Application are made applicable to these 

Title III Cases pursuant to section 301(a) of PROMESA.

3 All Bankruptcy Rules referenced in the Application are made applicable to these Title III Cases pursuant to 

section 310 of PROMESA.

4 The Local Rules are made applicable to these Title III Cases by the Court’s Order (A) Imposing and 

Rendering Applicable Local Bankruptcy Rules to These Title III Cases, (B) Authorizing Establishment of 

Certain Notice, Case Management, and Administrative Procedures, and (C) Granting Related Relief [Dkt. 

No. 249].

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November 1, 2013 (the “UST Guidelines”)5 and the Fee Examiner’s Fee Review – Timeline and 

Process Memo dated November 10, 2017. In support of the Application, Navarro-Cabrer 

respectfully represents: 

PRELIMINARY STATEMENT 

1. Navarro-Cabrer’s services to the COFINA Agent have been and continue 

to be substantial, necessary and beneficial to the COFINA Agent and have materially advanced 

the Commonwealth-COFINA Dispute. During the Application Period, Navarro-Cabrer has 

worked diligently on behalf of the COFINA Agent, including among other things: (i) providing 

required services as local counsel in compliance with Rule 83A (f) of the Local Rules of the 

District Court for the District of Puerto Rico (“Local District Court Rules”) and Rule 2090-1 of 

the Local Rules, to advance the Commonwealth-COFINA Dispute6; (ii) providing local counsel 

expertise and perspective; (iii) reviewing, analyzing and revising all motions and pleadings to be 

filed on behalf of the COFINA Agent, as required by the Local District Court Rules; (iv)

conducting legal research and analysis regarding Puerto Rico law and other related topics and 

working on memoranda and pleadings regarding the Commonwealth-COFINA Dispute; and (iv) 

regularly discussing strategy and key issues in the Commonwealth-COFINA Dispute with the 

COFINA Agent and her other professionals. Throughout the Application Period, the variety and 

complexity of the issues involved in these cases and the need to address many of those issues on 

an expedited basis, have required Navarro-Cabrer to devote substantial time on a daily basis.

 5 Pursuant to the Interim Compensation Order and Local Rule 2016-1, Navarro-Cabrer is required to comply 

with the UST Guidelines.

6 Terms used but not defined herein shall have the meaning ascribed to them in the Stipulation and Order 

Approving Procedure to Resolve Commonwealth-COFINA Dispute (the “Commonwealth-COFINA 

Stipulation”).

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2. Navarro-Cabrer’s services to the COFINA Agent during the Application 

Period were reasonable and necessary, and Navarro-Cabrer respectfully requests that the Court 

approve the fees and expenses requested in this Application.

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction over this matter pursuant to 

section 306(a) of PROMESA.

4. Venue is proper pursuant to section 306(a) of PROMESA.

5. Navarro-Cabrer makes this Application pursuant to sections 316 and 317

of PROMESA, sections 105(a) and 503(b) of the Bankruptcy Code, Bankruptcy Rule 2016, 

Local Rule 2016-1, the Commonwealth-COFINA Stipulation (as defined below), the Interim 

Compensation Order and the UST Guidelines.

BACKGROUND

A. General Background 

6. On May 3, 2017, the Commonwealth of Puerto Rico (the 

“Commonwealth”), by and through the Financial Oversight and Management Board for Puerto 

Rico (the “Oversight Board”), as the Commonwealth’s representative pursuant to section 

315(b) of PROMESA, filed a petition with the Court under title III of PROMESA.

7. On May 5, 2017, the Puerto Rico Sales Tax Financing Corporation 

(“COFINA”), by and through the Oversight Board, as COFINA’s representative pursuant to 

section 315(b) of PROMESA, filed a petition with the Court under title III of PROMESA. 

8. On May 21, 2017, the Employees Retirement System for the 

Commonwealth of Puerto Rico (“ERS”), by and through the Oversight Board, as ERS’s 

representative pursuant to section 315(b) of PROMESA, filed a petition with the Court under 

title III of PROMESA.

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9. On July 3, 2017, the Puerto Rico Electric Power Authority (“PREPA”), 

by and through the Oversight Board, as PREPA’s representative pursuant to section 315(b) of

PROMESA, filed a petition with the Court under title III of PROMESA.

10. Through Orders of this Court, the Commonwealth, COFINA, HTA, ERS, 

and PREPA Title III Cases (collectively, the “Title III Cases”) are jointly administered for 

procedural purposes only pursuant to section 304(g) of PROMESA and Bankruptcy Rule 1015. 

[See Dkt. Nos. 242, 537 and 1417.]

B. Navarro-Cabrer’s Retention by the COFINA Agent

11. On August 10, 2017, the Court entered the Commonwealth-COFINA 

Stipulation. The Commonwealth-COFINA Stipulation appointed Bettina M. Whyte as the 

COFINA Agent and authorized her to retain such legal and other professionals as she reasonably 

deems appropriate to meet her responsibilities and to compensate such professionals in 

conformity with PROMESA section 316 and any interim compensation procedures ordered by 

the Court. The Commonwealth-COFINA Stipulation appointed Willkie Farr & Gallagher LLP 

(“WF&G”) as lead counsel to the COFINA Agent and Klee, Tuchin, Bogdanoff & Stern LLP 

(“KTB&S”) as special municipal bankruptcy counsel to the COFINA Agent. 

12. Rule 83A (f) of the Local District Court Rules and Rule 2090-1 of the 

Local Rules, require the COFINA Agent to retain Puerto Rico counsel to appear in litigation in 

this forum. Said Rules require attorneys admitted por hac vice to remain associated with local 

counsel and require local counsel to sign all filings submitted to the Court and to attend all 

proceedings. 

13. In compliance with said Rules and pursuant to the CommonwealthCOFINA Stipulation, on August 16, 2017, the COFINA Agent engaged Navarro-Cabrer as local 

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counsel in the Title III Cases to, among other things, endorse the requests for admission pro hac 

vice of the lead counsel and the special municipal bankruptcy counsel to the COFINA Agent;

consult as to the interpretation of Puerto Rico law; appear as local counsel at hearings; and 

perform those tasks for which the COFINA Agent, the lead counsel and the special municipal 

bankruptcy counsel to the COFINA Agent choose to assign and request Navarro-Cabrer’s

involvement as local counsel. On November 3, 2017 [Dkt No. 1612], the Court approved, nunc 

pro tunc, the COFINA Agent’s retention of Navarro-Cabrer as local counsel, “without need for 

further application or order”.

14. The Commonwealth-COFINA Stipulation authorized the applicable 

Debtor (in Navarro-Cabrer’s case, COFINA) to compensate the legal professionals retained, for 

the professional fees and the actual and necessary out-of-pocket expenses incurred, subject to 

application to this Court as set forth herein. The Commonwealth-COFINA Stipulation further 

provides that the Commonwealth must make such payments within fourteen (14) days of 

receiving notice of nonpayment. As set forth more fully below, pursuant to the Interim 

Compensation Order (as defined below), Navarro-Cabrer has filed four (4) monthly fee 

statements during the Application Period and has been paid 90% of the fees and 100% of the 

expenses for the February Fee Statement. In addition, Navarro-Cabrer received payment of 100% 

of the expenses for the March Fee Statement and $21,103.80 72 representing a portion of its fees 

for its March 2018 fees statement.

7

 Despite repeated requests, Navarro-Cabrer has received no 

payment for the balance of the March 2018 fees, or for her April 2018 and May 2018 fees and 

expenses. 

C. Appointment of Fee Examiner

 7 There is an unpaid balance of $1,486.20 of the 90% of the March Fee Statement

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15. On October 6, 2017, the Court entered the Order Pursuant to PROMESA 

Sections 316 and 317 and Bankruptcy Code Section 105(a) Appointing a Fee Examiner and 

Related Relief [Dkt. No. 1416], thereby appointing Brady Williamson to serve as the fee 

examiner (the “Fee Examiner”) in the Title III Cases.

SUMMARY OF PROFESSIONAL COMPENSATION 

AND REIMBURSEMENT OF EXPENSES REQUESTED

By this Application and pursuant to sections 316 and 317 of PROMESA, sections 105(a) 

and 503(b) of the Bankruptcy Code, Rule 2016(a) of the Bankruptcy Rules and Rule 2016-1 of 

the Local Rules, Navarro-Cabrer requests that this Court authorize interim allowance of 

compensation for professional services rendered and reimbursement of expenses incurred during 

the Application Period in the amount of $105,404.82 (the “Application Amount”), which 

includes (a) compensation of $103,025.00 in fees for services rendered to COFINA and 

(b) reimbursement of $2,389.82 in actual and necessary expenses in connection with these 

services. As of the date hereof, in respect to the Application Period, Navarro-Cabrer has been 

paid a total of $60,817.32, which represents 90% of Navarro-Cabrer’s fess ($38,722.50) and 

100% of expenses ($410.00) for February 2018, and a portion of her fees ($21,103.80) and 100% 

of the expenses for March 2018. Navarro-Cabrer is owed $34,285.00 in respect of the 

Application Period (without accounting for the 10% holdback) and is also owed additional 

amounts from the prior interim period and subsequent interim period.

PRIOR INTERIM AWARDS AND REQUESTS

16. On December 15, 2017, Navarro-Cabrer filed her First Interim 

Application of Nilda M. Navarro-Cabrer, as Local Counsel to Bettina M. Whyte, as the COFINA 

Agent, for Interim Allowance of Compensation for Services Rendered and Reimbursement of 

Expenses Incurred From August 16, 2017 Through September 30, 2017 [Dkt. No. 2038] (the 

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“First Interim Application”), by which Navarro-Cabrer sought allowance of fees in the amount 

of $35,962.50 and expenses in the amount of $431.50 in respect of services rendered between 

August 16, 2017 through September 30, 2017 (the “First Interim Period”). 

17. On March 1, 2018, the Fee Examiner filed the Fee Examiner’s Initial Report

[Dkt. No. 2645] with respect to interim fee applications filed by professionals retained in the 

Title III Cases and recommended payment of the fees and expenses requested in the First Interim 

Application.

18. The First Interim Application was approved by order of this Court on March 7, 

2018 [Dkt. No. 2685] allowing fees in the amount of $35,962.50 and expenses in the amount of 

$431.50. Navarro-Cabrer has been paid in full for services rendered and expenses incurred 

during the First Interim Period.

19. On March 19, 2018, Navarro-Cabrer filed her Second Interim Application of

Nilda M. Navarro-Cabrer, as Local Counsel to Bettina M. Whyte, as the COFINA Agent, for 

Interim Allowance of Compensation for Services Rendered and Reimbursement of Expenses 

Incurred from October 1, 2017 Through January 31, 2018 [Dkt. No. 2726] (the “Second 

Interim Application”), by which Navarro-Cabrer sought allowance of fees in the amount of 

$102,662.50 and expenses in the amount of $784.42 in respect of services rendered between 

October 1, 2017 through January 31, 2018 (the “Second Interim Period”). 

20. On March 1, 2018, the Fee Examiner filed the Fee Examiner’s Second Report on 

Professional Fees and Expenses [Dkt. No. 3193] with respect to second interim fee applications 

filed by professionals retained in the Title III Cases. Navarro-Cabrer and the Fee Examiner 

consensually agreed to a reduction of Navarro-Cabre’s fees in the amount of $750.00.

21. The Second Interim Application was approved by order of this Court on June 8, 

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2018 [Dkt. No. 3279] allowing fees in the amount of $101,912.50 and expenses in the amount of 

$784.42. Navarro-Cabrer has not been paid in full for services rendered during the Second 

Interim Period. Specifically, Navarro-Cabrer is owed $9,516.25 in respect of its holdback for the 

Second Interim Period.8

NAVARRO-CABRER’S FEES AND EXPENSES FOR THE APPLICATION PERIOD 

22. Navarro-Cabrer’s services in these cases have materially advanced the 

Commonwealth-COFINA Dispute. Throughout the Application Period, the variety and 

complexity of the issues involved and the need to address those issues on an expedited basis 

required Navarro-Cabrer, in the discharge of her professional responsibilities, to devote 

substantial time on a daily basis 

23. Specifically, and as further reflected in the subject matter narratives 

below, Navarro-Cabrer requested compensation reflects the requisite time, skill and effort 

Navarro-Cabrer expended during the Application Period towards, inter alia: (a) providing 

required services as local counsel in compliance with the Local District Court Rules and the 

Local Rules; (b) conducting research regarding Puerto Rico law and other related topics with the 

Commonwealth-COFINA Dispute; (c) contributing to various pleadings and motions on behalf 

of the COFINA Agent; and (d) providing local counsel expertise and perspective. 

24. Navarro-Cabrer respectfully submits that its efforts on behalf of the 

COFINA Agent during the Interim Period have been both (i) at the request of the COFINA 

Agent, and (ii) not duplicative of work performed by the COFINA Agent’s other professionals. 

 

8

 This amount reflects a holdback of $10,266.25, less Fee Examiner reductions on the Second Interim Period 

of $750.00. 

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MONTHLY FEE STATEMENTS

25. The Interim Compensation Order provides, among other things, that 

professionals are required to serve monthly itemized billing statements (the “Monthly Fee 

Statements”) on counsel to the Oversight Board, counsel to AAFAF, the U.S. Trustee, counsel 

to the Official Committee of Unsecured Creditors, counsel to the Official Committee of Retired 

Employees and the Fee Examiner (collectively, the “Notice Parties”). Upon passage of the

objection period, if no objections were received, the Debtors were authorized to pay to the 

professionals 90% of the fees and 100% of the expenses requested. In addition to the Interim 

Compensation Order authorizing payment, the COFINA Agent received further confirmation of 

the Debtors’ obligation to pay pursuant to the Order Approving COFINA Agent’s Motion 

Pursuant to 48 U.S.C. § 2161 and 11 U.S.C. § 105(a) for Order: (I) Confirming that 48 U.S.C. § 

2125 Applies to COFINA Agent; (II) Confirming Retention of Local Counsel; and (III) 

Clarifying Payment of Fees and Expenses of COFINA Agent and her Professionals [Dkt. No. 

1612] (the “COFINA Protections Order”). The COFINA Protections Order directs payment to 

the COFINA Agent’s professionals out of the collateral “purportedly pledged to COFINA 

bondholders because the services of the COFINA Agent (i) serve as adequate protection for the 

collateral and/or (ii) are “reasonable” and “necessary” to protect the collateral pursuant to section 

506(c) of the Bankruptcy Code, the Agent/Professional Fees shall be paid pursuant to the Interim 

Compensation Order or any other order of the Court. . . . .” COFINA Protections Order ¶ 5. The 

COFINA Protections Order further provides that if COFINA is unable to make payments to the 

COFINA Agent’s professionals for any reason, the Commonwealth must make such payments 

within fourteen days of receiving notice of COFINA’s nonpayment. 

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26. In compliance with the Interim Compensation Order, Navarro-Cabrer has 

submitted four (4) Monthly Fee Statements relating to the Application Period. Payment on 

account of these Monthly Fee Statements was requested as follows:

(a) Pursuant to the Monthly Fee Statement for the period February 1, 

2018 through February 28, 2018 (the “February Fee Statement”),

Navarro-Cabrer requested payment of $ 39,132.50, representing the total 

of (i) $38,722.50, which is 90% of the fees requested for services rendered 

(i.e., $43,025.00) plus (ii) $410.00, representing 100% of the expenses 

incurred during the period.

(b) Pursuant to the Monthly Fee Statement for the period March 1, 2018 

through March 31, 2018 (the “March Fee Statement”), Navarro-Cabrer

requested payment of $ 23,171.02, representing the total of (i) $22,590.00,

which is 90% of the fees requested for services rendered (i.e., $ 25,100.00)

plus (ii) $581.02, representing 100% of the expenses incurred during the 

period. 

(c) Pursuant to the Monthly Fee Statement for the period April 1, 2018 

through April 30, 2018 (the “April Fee Statement”), Navarro-Cabrer

requested payment of $ 15,592.50, representing the total of $ 15,592.50,

which is 90% of the fees requested for services rendered (i.e., $17,325.00), 

since there were 0 expenses incurred during the period. 

(d) Pursuant to the Monthly Fee Statement for the period May 1, 2018 

through May 31, 2018 (the “May Fee Statement”), Navarro-Cabrer

requested payment of $ 17,206.30, representing the total of (i) $

15,817.50, which is 90% of the fees requested for services rendered (i.e., $ 

17,575.00) plus (ii) $1,388.80, representing 100% of the expenses incurred 

during the period. 

Navarro-Cabrer did not receive any objections to her February, March, April or May Fee 

Statements. A review of the Court Docket reflects that there is no answer, objection, or other 

responsive pleading to these Fee Statements. Despite all requirements set by the Interim 

Compensation Order being satisfied, Navarro-Cabrer has only received payment of a 90% of 

Navarro-Cabrer’s fess ($38,722.50) and 100% of expenses ($410.00) for February 2018, and a 

portion of her fees ($21,103.80) and 100% of the expenses for March 2018, for a total of total of 

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$60,817.32. Navarro-Cabrer has not been paid the remaining balance of the 90% of the March 

Fees ($1,486.20 and has not received any payments for her April or May Fee Statements.

FEES AND EXPENSES INCURRED DURING APPLICATION PERIOD

27. Annexed hereto as Exhibit 1 is the Certification of Nilda M. NavarroCabrer pursuant to the Local Rules (the “Certification”).

28. Annexed hereto as Exhibit 2 is a summary sheet listing each attorney and 

paraprofessional who has worked on these cases during the Application Period, his or her hourly 

billing rate during the Application Period, and the amount of Navarro-Cabrer’s fees attributable 

to each individual. 

29. Navarro-Cabrer also maintains records of all actual and necessary out-ofpocket expenses incurred in connection with the rendition of professional services. A schedule 

setting forth the categories of expenses and amounts for which reimbursement is requested for 

the Application Period is annexed hereto as Exhibit 3.

30. Navarro-Cabrer maintains written records of the time expended by 

attorneys and paraprofessionals carrying out professional services to the Debtors. Such time 

records are made contemporaneously with the rendition of services by the person rendering such 

services. Annexed hereto as Exhibit 4 is a list of all of the matters for which services were 

rendered by Navarro-Cabrer during the Application Period, the aggregate number of hours and 

fees expended for each of those matters, and the budgeted number of hours and fees.

31. In accordance with the UST Guidelines, Navarro-Cabrer recorded her

services rendered and disbursements incurred in different project matters that reasonably could 

have been expected to constitute a substantial portion of the fees sought during any given

application period.

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32. No agreement or understanding exists between Navarro-Cabrer and any 

other entity for the sharing of compensation to be received for services rendered in or in 

connection with these cases. 

33. The fees charged by Navarro-Cabrer in these chapter 11 cases are billed in 

accordance with her existing billing rates and procedures. The hourly rates of Navarro-Cabrer in 

these Title III Cases are commensurate with the complexity, importance, and nature of the 

problems, issues, and tasks addressed, and with the demands imposed by the expedited nature 

and extraordinary environment—legal and practical—of these proceedings. Navarro-Cabrer’s 

hourly rates in this matter are comparable to the hourly rates charged in the Title III Cases and in 

comparable non-bankruptcy by similarly-skilled local counsel and substantially lower than those 

fees charged in the competitive national legal market. Consistent with the UST Guidelines, 

Exhibit 5 discloses the blended hourly rate for all non-bankruptcy timekeepers and the blended 

hourly rate for timekeepers who billed to the Debtors during the Application Period. 

SUMMARY OF SERVICES RENDERED

34. Recitation of each and every item of professional services that NavarroCabrer performed during the Application Period would unduly burden the Court. Hence, the 

following summary highlights the major areas to which Navarro-Cabrer devoted substantial time 

and attention during the Application Period. The full breadth of Navarro-Cabrer’s services is 

reflected in Navarro-Cabrer’s time records, copies of which are annexed hereto as Exhibits 4(A)-

(D).

A. Litigation/Adversary Proceeding - Billing Code: L-200

(Fees: $75,200.00 Hours Billed: 210.40)

35. During the Application Period, Navarro-Cabrer, as local counsel to the 

COFINA Agent, spent a significant amount of time providing services required to comply with

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Rule 83A (f) of the Local District Court Rules and Rule 2090-1 of the Local Rules, and to assist 

the COFINA Agent’s discharge of her duty to litigate and/or settle the Commonwealth-COFINA 

Dispute (as defined in the Stipulation). Among the most significant tasks in this Subject Matter 

during the Interim Period was the preparation of the COFINA Agent’s Motion for Summary 

Judgment [Adv. Docket No. 317] (the “Motion for Summary Judgment”), and the COFINA 

Agent’s Motion to Certify Questions Under Puerto Rico Law to The Supreme Court of Puerto 

Rico [Adv. Docket No. 329] (the “Certification Motion”).

36. During the Application Period, Navarro-Cabrer conducted legal research 

as to various issues of Puerto Rico law in connection with the development of various arguments 

for the Motion for Summary Judgment and the Certification Motion, including Puerto Rico case 

law and procedure for certifying questions to the Supreme Court of Puerto Rico. Navarro-Cabrer 

worked diligently and efficiently in connection with these matters, delegating work to a 

paraprofessional when appropriate. Navarro-Cabrer spent substantial time analyzing and 

revising the Motion for Summary Judgment, the Certification Motion and the list of questions to 

propose for certification, as well as communicating with the COFINA Agent and co-counsel 

regarding those motions and questions, providing with unique and beneficial input that was not 

duplicative of the co-counsel’s work.

37. The Certification Motion was prepared at the request of the COFINA Agent to, 

among other things, preserve her ability to seek this relief on appeal. Navarro-Cabrer’s work on 

this matter included research as to issues of Puerto Rico law and the applicable procedure for 

certifying questions to the Supreme Court of Puerto Rico, and drafting analysis and 

recommendations regarding the certification process. 

38. Navarro-Cabrer also worked analyzing numerous motions for summary 

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judgment filed by, among others, the Commonwealth Agent, and numerous COFINA-side and 

Commonwealth-side constituents. Navarro-Cabrer assisted in the preparation of the COFINA 

Agent's opposition and reply to the numerous filed motions (as well as the analysis of 

oppositions and replies filed by other parties) and revising these pleadings and communicated 

with the COFINA Agent and co-counsel regarding the same. Time in this Subject Matter also 

includes significant time analyzing issues as to the discrepancy between the English and the 

Spanish versions of the Puerto Rico Constitution and the discussions in the Constitutional 

Convention as to certain sections of the Constitution. Navarro-Cabrer also analyzed other 

parties’ motions and objections as to the Certification Motion and assisted the COFINA Agent in 

preparing the Reply to the Objections to the Certification Motion and analyzed related pleadings. 

39. In addition, to comply with the Local District Court Rules and Local Rules 

that require local counsel to sign all filings, Navarro-Cabrer spent time reviewing, analyzing and 

revising all motions and pleadings to be filed on behalf of the COFINA Agent. To responsibly 

sign all filings summited to the Court as required by the Local District Court Rules and the Local 

Rules and to remain informed of all legal arguments that might implicate the CommonwealthCOFINA Dispute, Navarro-Cabrer was required to examine and analyze all pleadings and filings 

relevant to the COFINA Agent. 

40. Navarro-Cabrer attended the April 10, 2018 summary judgment hearing in

compliance with Local District Court Rules and Local Rules, that require local counsel 

attendance to all hearings. To reduce expenses, rather than traveling to New York for the 

hearing, Navarro-Cabrer attended the hearing in United States District Court for the District of 

Puerto Rico, via closed circuit. 

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41. In compliance with Local District Court Rules and the Local Rules, and at 

the COFINA Agent’s request, Navarro-Cabrer attended the hearing on the Certification Motion

in New York on May 9, 2018, and spent time preparing for that hearing and conferring and 

meeting with co-counsel in preparation for the hearing, providing with unique and beneficial 

counsel that was not duplicative of the co-counsel’s participation.9

 

42. Navarro-Cabrer assisted the COFINA Agent, the lead counsel to the COFINA 

Agent and the municipal bankruptcy counsel to the COFINA Agent in various ways, including 

but not limited to, providing local counsel expertise and perspective. 

B. Meetings/Creditor Communications-Billing Code: B-150

(Fees: $1,800.00/ Hours Billed: 4.8)

43. This Subject Matter reflects reasonable time spent in communications with 

local counsel for the constituents, including communication with local counsel to various 

COFINA bondholders as to the possible certification of questions to the Supreme Court of Puerto 

Rico. 

C. Mediation - Billing Code: L-160

(Fees: $10,575.00 / Hours Billed: 28.2)

44. This Subject Matter includes all time spent on issues related to the

mediation and negotiation of the Commonwealth-COFINA Dispute. At the express request of the 

COFINA Agent, Navarro-Cabrer participated in weekly conference calls with the COFINA 

Agent and co-counsel regarding mediation strategy, and analyzed memoranda and information 

sent by the mediation team. Navarro-Cabrer assisted the COFINA Agent providing local counsel 

expertise and perspective, as well as information and analysis as to economic and political 

 9 Although the Certification Motion was denied, its prosecution was necessary to preserve the matter for 

appeal, and, as noted by the Court in the order denying certification [Adv. Docket No. 483], “the 

[Commonwealth-COFINA Stipulation] clearly contemplates the possibility of certification motion 

practice.” Adv. Docket No. 483, at 4 (emphasis added).

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developments in Puerto Rico relevant to the Commonwealth-COFINA Dispute and the 

mediation process. Also, at the request of the COFINA Agent, Navarro-Cabrer attended (via 

webcast) the Governor’s State of the Commonwealth Address and drafted a Memorandum 

summarizing and analyzing the message and the topics relevant to the mediation and negotiation 

of the Commonwealth-COFINA Dispute.

D. Fee Applications & Retention - Billing Code: B-160

(Fees: $12,925.00 / Hours Billed: 47.4)

45. This Subject Matter includes all matters related to the retention and 

compensation of the COFINA Agent’s professionals. Specifically, time billed to this Subject 

Matter during the Compensation Period includes preparing four monthly fee statements, covering 

the period from February 1, 2018 through May 31, 2018. In addition, Navarro-Cabrer prepared 

her Second Interim Application, covering the period from October 1, 2017 through January 31, 

2018. 

46. Navarro-Caber also spent time analyzing compensation-related orders, and 

communicating with, among others, the Fee Examiner and attending on March 7, 2018, a 

meeting with the Fee Examiner and other counsel as to the fee application process. NavarroCabrer delegated several appropriate tasks related to application and retention to a 

paraprofessional, minimizing the costs incurred.

47. In addition, to comply with the Local District Court Rules and Local Rules 

that require local counsel to sign all filings, Navarro Cabrer had to review the Second Interim 

Fee Applications to be filed by the COFINA Agent, the lead counsel to the COFINA Agent and 

the municipal bankruptcy counsel to the COFINA Agent, to responsibly sign said filings. 

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E. Fee Application & Retention Objections - Billing Code: B-170

(Fees: $725.00 / Hours Billed: 3.2)

48. This category reflects reasonable time spent preparing the Statements of 

No Objection. Navarro-Cabrer delegated appropriate tasks related to application and retention 

objections to a paraprofessional, minimizing the costs incurred.

F. Budget - Billing Code: L-150

(Fees: $1,500.00 / Hours Billed: 6.4)

49. This category reflects reasonable time spent preparing the required 

budgets. Navarro-Cabrer delegated appropriate tasks to a paraprofessional, minimizing the costs 

incurred.

G. Discovery/Fact Analysis - Billing Code: L-300

(Fees: $300.00 / Hours Billed: 0.80)

50. This category reflects reasonable time spent with discovery maters, 

including follow-up as to of discovery requests addressed to third parties located in Puerto Rico

and corresponding with co-counsel as to discovery issues.

EVALUATING NAVARRO-CABRER’S SERVICES

51. Section 317 of PROMESA authorizes interim compensation of 

professionals and incorporates the substantive standards of section 316 of PROMESA to govern 

the Court’s award of interim compensation. Section 316 of PROMESA provides that a court 

may award a professional employed by the debtor “reasonable compensation for actual, 

necessary services rendered,” and “reimbursement for actual, necessary expenses.” 48 U.S.C. §

2176(a)(1) and (2). Section 316(c) sets forth the criteria for such an award:

In determining the amount of reasonable compensation to be awarded to a 

professional person, the court shall consider the nature, the extent, and the

value of such services, taking into account all relevant factors including—

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(1) the time spent on such services;

(2) the rates charged for such services;

(3) whether the services were necessary to the administration of, 

or beneficial at the time at which the service was rendered to the 

completion of, a case under this chapter;

(4) whether the services were performed within a reasonable 

amount of time commensurate with the complexity, importance, 

and nature of the problem, issue, or task addressed;

(5) with respect to a professional person, whether the person is 

board certified or otherwise has demonstrated skill and experience 

in the restructuring field; and

(6) whether the compensation is reasonable based on the 

customary compensation charged by comparably skilled 

practitioners in cases other than cases under this title or title 11 of 

the United States Code.

48 U.S.C. § 2176(c).

52. Navarro-Cabrer respectfully submits that the services as local counsel for 

which she seeks compensation in this Application were necessary for and beneficial to the 

COFINA Agent. Navarro-Cabrer was engaged as local counsel to the COFINA Agent due to her 

knowledge and expertise as to Puerto Rico law, Puerto Rico Constitutional provisions relevant to 

the Commonwealth-COFINA dispute, and the Local District Court Rules and Local Rules.10

During the Application Period, Navarro-Cabrer has provided local counsel expertise and 

 10 Since 1999, Navarro-Cabrer has served as Member of the District Court Examination Committee,

appointed by the United States District Court for the District of Puerto Rico, in charge of Local District 

Court Rules and Civil Procedure. Since 2006, she has been an Adjunct Professor at the University of Puerto 

Rico Law School, where she teaches Civil Procedure and trial advocacy courses. Navarro-Cabrer has an 

LL.M. degree from Harvard University (1985); a J.D. degree from the University of Puerto Rico (1983 

Magna Cum Laude), where she was the Editor in Chief of the Law Review; and a BA from Georgetown 

University (Magna Cum Laude, 1980). After graduating from law school, she served as law clerk to the 

Hon. Jose Trias-Monge, Chief Justice of the Supreme Court of Puerto Rico, and to the Hon. Stephen G. 

Breyer at the United States Court of Appeals for the First Circuit. 

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perspective to the COFINA Agent in a variety of challenging legal issues, often requiring 

research and analysis of Puerto Rico law. 

53. Navarro-Cabrer further submits that the services rendered to the COFINA 

Agent were performed efficiently and effectively. Indeed, the small size of Navarro-Cabrer Law 

Offices guarantees that there is no duplication or overlap in work performed, precludes 

overlapping billing by multiple attorneys, and results in reduced fees. Finally, Navarro-Cabrer

submits that the compensation requested herein is reasonable in light of the nature, extent and 

value of such services to the COFINA Agent and those parties impacted by her actions and that 

the compensation requested is based on the customary compensation charged by comparably 

skilled practitioners in cases other than cases under title 11.

54. Courts typically employ the “lodestar” approach to calculate awards of 

attorneys’ fees. See New York State Ass’n for Retarded Children, Inc. v. Casey, 711 F.2d 1136, 

1140 (2d Cir. 1983); In re West End Fin. Advisors, LLC, No. 11-11152, 2012 Bankr. LEXIS 

3045, at *11 (Bankr. S.D.N.Y. July 2, 2012); In re Drexel Burnham Lambert Group, Inc., 133 

B.R. 13, 21-22 (Bankr. S.D.N.Y. 1991) (“In determining the reasonableness of the requested 

compensation under § 330, Bankruptcy Courts now utilize the lodestar method”). “The lodestar 

amount is calculated by multiplying the number of hours reasonably expended by the hourly rate, 

with the ‘strong presumption’ that the lodestar product is reasonable under § 330.” Drexel, 133 

B.R. at 22 (citations omitted). 

55. In determining the reasonableness of the services for which compensation 

is sought, the court should note that:

the appropriate perspective for determining the necessity of the 

activity should be prospective: hours for an activity or project 

should be disallowed only where a Court is convinced it is 

readily apparent that no reasonable attorney should have 

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undertaken that activity or project or where the time devoted 

was excessive.

Id. at 23; see also In re Cenargo Int’l PLC, 294 B.R. 571, 595-96 (Bankr. S.D.N.Y. 2003) (“The 

Court’s benefit of ‘20/20 hindsight’ should not penalize professionals.”). 

56. Moreover, courts should be mindful that professionals “must make 

practical judgments, often with severe time constraints, on matters of staffing, assignments, 

coverage of hearings and meetings, and a wide variety of similar matters.” Drexel, 133 B.R. 

at 23. These judgments are presumed to be made in good faith. Id. 

NAVARRO-CABRER’S REQUEST FOR INTERIM COMPENSATION

57. Navarro-Cabrer submits that this request for interim allowance of 

compensation is reasonable. The services rendered by Navarro-Cabrer, as highlighted above, 

were necessary, resulting in substantial progress and success in these cases. The services 

rendered by Navarro-Cabrer during the Application Period were performed diligently and 

efficiently, with no duplication or overlap. When appropriate, Navarro-Cabrer delegated tasks to 

a paraprofessional, which resulted in reduced fees and enhanced cost efficiency. 

58. Navarro-Cabrer has rendered advice with skill and efficiency, providing 

insight and expertise as to Puerto Rico law relevant to the Commonwealth-COFINA dispute, and 

the required knowledge and expertise with the Local District Court Rules.

59. The professional services performed by Navarro-Cabrer on behalf of the 

COFINA Agent during the Application Period required an aggregate expenditure of 301.20 

hours, consisting of 261.50 hours expended by partners; and 39.7 hours expended by 

paraprofessionals.

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60. For the Application Period, allowance of compensation in the amount 

requested will result in a blended hourly billing rate for attorneys of $375.00 and a total blended 

hourly billing rate (including paraprofessionals) of $342.05. 

61. Navarro-Cabrer’s hourly rates and fees charged are consistent with the 

market rate for comparable services and commensurate with the complexity, importance, and 

nature of the problems, issues, and tasks addressed, and with the demands imposed by the 

expedited nature and extraordinary environment—legal and practical—of these proceedings. 

Navarro-Cabrer’s hourly rates in this matter are comparable to the hourly rates charged in the 

Title III Cases by comparably-skilled local counsel and substantially lower than those fees 

charged in the competitive national legal market. In addition, the small size of Navarro-Cabrer 

Law Offices guarantees efficiency and precludes duplication of effort or overlapping billing by 

multiple attorneys. 

DISCUSSION OF BUDGET AND STAFFING PLAN

62. In accordance with the UST Guidelines, Navarro-Cabrer prepared monthly

budgets and staffing plans covering the Application Period, copies of which are annexed hereto 

as part of Exhibit 6. These budgets were provided to and approved by the COFINA Agent.

63. The estimated amount of fees Navarro-Cabrer expected to incur during the 

Application Period was $159,956.00. Navarro-Cabrer’s fees incurred during the Application 

Period were $56,931.00 less than budgeted by Navarro-Cabrer from the actual fees incurred by 

Navarro-Cabrer during the Application Period. 

64. Navarro-Cabrer provided necessary and beneficial services to the 

COFINA Agent during the the Interim Period. The small size of Navarro-Cabrer Law Offices 

precludes duplication of effort or overlapping billing by multiple attorneys, resulting in 

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efficiency and reduced fees. When appropriate, Navarro-Cabrer delegated work to a 

paraprofessional. 

65. Local Rules require that local counsel be present at all hearings. To reduce 

expenses, Navarro-Cabrer attended the summary judgment hearing in the United States District 

Court for the District of Puerto Rico, via closed circuit, rather than traveling to New York. 

Navarro-Cabrer traveled to New York to attend the hearing on the Certification Motion, at the 

request of the COFINA Agent and co-counsel, to be available for and to participate in the 

hearing preparation and hearing, in which Navarro-Cabrer provided with unique and beneficial 

counsel that was not duplicative of the co-counsel’s participation.

66. Navarro-Cabrer further respectfully submits that the COFINA Agent was 

provided with Navarro-Cabrer’s monthly invoices for her review and has expressed no objection 

to those invoices.

DISBURSEMENTS

67. Navarro-Cabrer incurred actual and necessary out-of-pocket expenses 

during the Application Period, in the amounts set forth in Exhibit 3. By this Application, 

Navarro-Cabrer respectfully requests allowance of such reimbursement in full. The expenses 

requested comply with all applicable guidelines, including those set forth in the Fee Examiner’s 

Memorandum dated November 10, 2017. Accordingly, receipts for all travel expenses 

exceeding $300.00 were provided. In addition, reimbursement of out-of-office meals and hotel 

expenses while Navarro-Cabrer traveled to prepare for and attend a hearing in New York, is only 

requested up to the amount of the applicable caps. 

68. The disbursements for which Navarro-Cabrer seeks reimbursement 

include the duplicating, charged at $0.10 per page based upon the cost of supplies.

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PROCEDURE

69. In accordance with the Interim Compensation Order, Navarro-Cabrer has 

provided: (a) notice and copies of the Application to the Notice Parties and (b) notice of this 

Application to all parties that have requested notice pursuant to Bankruptcy Rule 2002.11 

Navarro-Cabrer submits that no other or further notice is required.

70. No previous application for the relief sought herein has been made to this 

or any other court. 

[Remainder of Page Intentionally Left Blank.]

 11 Copies of the Application, including exhibits, are available on the Debtors’ claims and noticing agents’ 

website: https://cases.primeclerk.com/puertorico.

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CONCLUSION

WHEREFORE, Navarro-Cabrer respectfully requests that this Court enter an order: 

(a) allowing interim approval of compensation to Navarro-Cabrer for services 

rendered from February 1, 2018 through May 31, 2018, inclusive, in the amount 

of $103,025.00;

(b) allowing interim approval of reimbursement to Navarro-Cabrer of actual, 

necessary expenses incurred in connection with the rendition of such services 

from February 1, 2018 through May 31, 2018, inclusive, in the amount of 

$2,379.82;

(c) approving and directing the payment of all fees and expenses incurred by 

Navarro-Cabrer that remain unpaid, including all Holdbacks; and

(d) such other relief as may be just or proper.

Dated: San Juan, Puerto Rico

July 16, 2018

/s/ Nilda M. Navarro-Cabrer

Nilda M. Navarro-Cabrer

USDC – PR No. 201212

NAVARRO-CABRER LAW OFFICES

El Centro I, Suite 206

500 Muñoz Rivera Avenue

San Juan, Puerto Rico 00918

Telephone: (787) 360-9584 (787)764-9595

Facsimile: (787) 765-7575

Email: navarro@navarrolawpr.com

Local Counsel to the COFINA Agent

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EXHIBIT 1

CERTIFICATION OF NILDA M. NAVARRO CABRER

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

PROMESA

Title III

as representative of Case No. 17-BK-3283 (LTS)

THE COMMONWEALTH OF PUERTO RICO, et al., (Jointly Administered)

Debtors.1

CERTIFICATION OF NILDA M. NAVARRO-CABRER PURSUANT TO

LOCAL BANKRUPTY RULE 2016-1(a)(4) REGARDING CERTIFICATION OF 

APPLICATIONS FOR COMPENSATION IN PUERTO RICO BANKRUPTCY CASES

I, Nilda M. Navarro Cabrer Esq., certify as follows:

1. I am an attorney duly licensed and in good standing in the Commonwealth 

of Puerto Rico, member of the bar of the District Court for the District of Puerto Rico, d/b/a 

Navarro-Cabrer Law Offices (“Navarro–Cabrer”), local counsel to the COFINA Agent in the 

above-captioned cases. 

2. I submit this certification in conjunction with Navarro–Cabrer’s third 

interim application (the “Application”)2 for allowance of fees and reimbursement of expenses 

for the period February 1, 2018 through May 31, 2018 (the “Application Period”) in accordance 

 1 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number and the last 

four (4) digits of each Debtor’s federal tax identification number, as applicable, are the (i) Commonwealth 

of Puerto Rico (Bankruptcy Case No. 17 BK 3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) 

Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17 BK 3284-LTS) (Last 

Four Digits of Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) 

(Bankruptcy Case No. 17 BK 3567-LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) Employees 

Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case 

No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); and (v) Puerto Rico Electric Power 

Authority (“PREPA”) (Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 

3747). 2 Capitalized terms used but not otherwise defined herein have the meaning ascribed to them in the 

Application.

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with Rule 2016-1(a)(4) of the Local Bankruptcy Rules for the District of Puerto Rico, the 

Bankruptcy Rules, the Bankruptcy Code, the Guidelines for Reviewing Applications for 

Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in 

Larger Chapter 11 Cases (the “UST Guidelines”) and the Interim Compensation Order 

(collectively, the “Guidelines”).

3. I am the professional with the responsibility for Navarro–Cabrer’s 

compliance in these cases with the Guidelines. This certification is made in connection with the 

Application for interim allowance of compensation for professional services and reimbursement 

of expenses for the Application Period in accordance with the Guidelines.

4. Pursuant to Local Rule 2016-1(a)(4) of the Local Rules, I have read 

Navarro–Cabrer’s Application; to the best of my knowledge, information, and belief, formed 

after reasonable inquiry (except as stated herein or in the Application), the fees and 

disbursements sought in the Application fall within the Guidelines; except to the extent the fees 

and disbursements are prohibited by the Guidelines, the fees and disbursements sought are billed 

at rates and in accordance with practices customarily employed by Navarro–Cabrer and generally 

accepted in matters of this nature.

5. I believe that the COFINA Agent has reviewed Navarro–Cabrer’s 

Monthly Fee Statements that form the basis for the Application and has not objected to the 

amounts requested therein. Such Monthly Fee Statements were provided to the Notice Parties as 

required by the Interim Compensation Order and no objections were filed or received.

6. A copy of the daily time records for each of the Monthly Fee Statements, 

broken down by matter and listing the name of the attorney or paraprofessional, the date on 

which the services were performed, and the amount of time spent in performing the services has

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previously been provided to the Notice Parties. The time records set forth in reasonable detail 

the services rendered by Navarro–Cabrer in these cases.

7. Included in Exhibit 4 of the Application is a list of the different matter 

headings under which time was recorded during the Application Period. The list includes all 

discrete matters within these cases during the Application Period that reasonably could have 

been expected to constitute a substantial portion of the fees sought during any given application 

period.

8. No agreement or understanding exists between Navarro-Cabrer and any 

person for a division of compensation or reimbursement received or to be received herein or in 

connection with these cases.

9. Navarro-Cabrer has sought to keep its fees and expenses at a reasonable 

level and to utilize professional services and incur expenses as necessary to competently 

represent the Debtors.

10. The following is provided in response to the request for additional 

information set forth in Section C.5 of the UST Guidelines.

Question: Did you agree to any variations from, or alternatives to, your standard 

or customary billing rates, fees or terms for services pertaining to this engagement 

that were provided during the application period?

Response: No.

Question: If the fees sought in this fee application as compared to the fees 

budgeted for the time period covered by this fee application are higher by 10% or 

more, did you discuss the reasons for the variation with the client?

Response: N/A. For the Application Period, Navarro-Cabrer is not seeking fees 

that exceeded the overall budgets by 10% or more. 

Question: Have any of the professionals included in this fee application varied 

their hourly rate based on the geographic location of the bankruptcy case?

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Response: No.

Question: Does the fee application include time or fees related to reviewing or 

revising time records or preparing, reviewing, or revising invoices? (This is 

limited to work involved in preparing and editing billed records that would not be 

compensable outside of bankruptcy and does not include reasonable fees for 

preparing a fee application.) If so, please quantify by hours and fees.

Response: No.

Question: Does this fee application include time or fees for reviewing time 

records to redact any privileged or other confidential information?

Response: No.

Question: Does this fee application include rate increases since retention?

Response: No.

Dated: San Juan, Puerto Rico

July 16, 2018

 /s/ Nilda M. Navarro-Cabrer

Nilda M. Navarro-Cabrer

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EXHIBIT 2

SUMMARY OF PROFESSIONALS FOR THE APPLICATION PERIOD

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COMPENSATION BY INDIVIDUAL

Name Department Bar 

Admission 

Date1

Position Hourly 

Rate

Hours

Billed

Fees Billed

PARTNERS

Nilda M. Navarro-Cabrer Litigation 1984 Partner $375.00 261.50 $98,062.50

PARAPROFESSIONALS

Rosa M. Rivera Litigation N/A Paralegal $125.00 39.7 $ 4,965.50

 1 Unless otherwise indicated, the admission date included herein reflects the earliest admission of each 

attorney to the Puerto Rico Bar.

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EXHIBIT 3

SUMMARY OF EXPENSES FOR THE APPLICATION PERIOD

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EXPENSE SUMMARY

Category Total Expenses

Postage/Messenger/Overnight Delivery $555.52

Out of Town Transportation $134.35

Telephone – Long Distance 0

Out of Town Meals $133.65

Lodging $500.00

Airfare $620.80

Reproduction $46.50

Data Acquisition (includes Legal Research) $89.00

Process Server 0

Deposition fees and mileage for deponent 0

Pro hac vice fee $300.00

TOTAL DISBURSEMENTS: $2,379.82

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EXHIBIT 4

SUMMARY OF TIME BY BILLING CATEGORY FOR THE APPLICATION PERIOD

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SUMMARY OF SERVICES RENDERED BY CATEGORY

COMPENSATION BY PROJECT CATEGORY

Category Hours Fees

Meetings/Creditor Communications (B150) 4.80 $1,800.00

Fee Application and Retention (B160) 47.40 $12,925.00

Fee Application Retention and Objections (B170) 3.20 $725.00

Budget (L150) 6.40 $1,500.00

Mediation (L160) 28.20 $10,575.00

Litigation/Adversary Proceeding (L200) 210.40 $75,200.00

Discovery/Facts Analysis (L300_ 0.80 $300.00

TOTAL HOURS AND FEES: 301.20 $103,025.00

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EXHIBIT 4-A

TIME AND EXPENSE DETAIL FOR FEBRUARY 2018 FEE STATEMENT

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Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

03-15-2018

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 18022863

Invoice Period: 02-01-2018 - 02-28-2018

RE: Multiple Matters

B-150 Meetings/Creditor Communications

B-160 Fee Application and Retention

E-100 Expenses

L-150 Budget

L-160 Mediation

L-200 Litigation/Adversary Proceeding

L-300 Discovery/Facts Analysis

B-150 Meetings/Creditor Communications

Professional Services

Date Timekeeper Description Hours Amount

02-21-2018 NN Correspond with co-counsel from WF&G and KTBS re 

conference call with constituents' counsel and local counsel as to 

possible certification of questions to PR Supreme Court

0.500 187.50

02-21-2018 NN Correspond with D. Bussel (KTBS) re constituents' input as to 

possible certification of questions to PR Supreme Court

0.300 112.50

02-21-2018 NN Correspond with J. Minias (WF&G) re constituents' input as to 

possible certification of questions to PR Supreme Court

0.200 75.00

02-21-2018 NN Confer with J. Minias in preparation for conference call with local 

counsel to constituents as to possible certification of questions of 

PR law to PR Supreme Court

0.400 150.00

02-21-2018 NN Confer with E. Pérez-Ochoa (counsel for National) re possible 

certification of questions of PR law to Supreme Court of PR

0.300 112.50

02-21-2018 NN Confer with local counsel for constituents (R. Escalera, E. Pérez 

Ochoa, Luis Oliver, M. Fernández, R. Cámara, D. Salinas, J. 

Sánchez, A. Díaz and others) re possible certification to PR 

Supreme Court

0.900 337.50

02-21-2018 NN Draft Memorandum re conference call with local counsel for 

constituents (R. Escalera, E. Pérez Ochoa, Luis Oliver, M. 

Fernández, R. Cámara, D. Salinas, J. Sánchez, A. Díaz and 

others) re possible certification to PR Supreme Court

1.200 450.00

02-21-2018 NN Correspond with B. Whyte and co-counsel re conference call 

with local counsel for constituents as to possible certification to 

0.400 150.00

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Date Timekeeper Description Hours Amount

PR Supreme Court

02-21-2018 NN Correspond with M. Fernández, counsel for Mutual Funds 

Group, re possible certification to PR Supreme Court

0.100 37.50

02-23-2018 NN Correspond with B. Whyte re communication with constituents 

as to partial certification of questions to PR Supreme Court

0.100 37.50

Total Fees 1,650.00

Time Summary

Timekeeper Hours Rate Amount

NN 4.400 375.00 1,650.00

Total Fees 1,650.00

B-160 Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

02-03-2018 NN Review stipulated disclosure agreements and protective Order 

filed by Fee Examiner, including those for B. Whyte's counsel

0.200 75.00

02-12-2018 NN Work with Fee Application for January 2018 0.400 150.00

02-12-2018 RR Work on Fee Application for January 2018 0.700 87.50

02-14-2018 RR Finalize Fee Application for January 2018 0.500 62.50

02-14-2018 NN Final revision of January Fee Application 0.300 112.50

02-14-2018 NN Analyze letter Report from Fee Examiner and exhibits re Interim 

Fee Application

0.300 112.50

02-19-2018 RR Adjust matter codes for fee applications to comply with Fee 

Examiner's request

1.400 175.00

02-19-2018 NN Draft response to Fee Examiner's letter and report as to our First 

Interim Fee Application

0.700 262.50

02-21-2018 NN Revise and conclude letter to Fee Examiner in response to his 

Letter Report

0.200 75.00

02-27-2018 NN Correspond with B. Whyte re communication from Fee Examiner 0.100 37.50

Total Fees 1,150.00

Time Summary

Timekeeper Hours Rate Amount

NN 2.200 375.00 825.00

RR 2.600 125.00 325.00

Total Fees 1,150.00

E-100 Expenses

Expenses

Date Description Price Qty Amount

02-13-2018 Legal research in PACER for brief to certify questions to PR Supreme 

Court

45.40 1 45.40

02-14-2018 Pro hac vice fee for Alexander Cheney 300.00 1 300.00

02-16-2018 Legal research in PACER for brief to certify questions to PR Supreme 

Court

10.90 1 10.90

02-17-2018 Legal research in PACER for brief to certify questions to PR Supreme 

Court

21.00 1 21.00

02-20-2018 Legal research in PACER for brief to certify questions to PR Supreme 

Court

8.80 1 8.80

02-23-2018 Legal research in PACER for brief to certify questions to PR Supreme 2.90 1 2.90

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Date Description Price Qty Amount

Court

02-28-2018 In house copies 0.10 210 21.00

Total Expenses 410.00

L-150 Budget

Professional Services

Date Timekeeper Description Hours Amount

02-19-2018 RR Assist N. Navarro with calculations for March budget 0.600 75.00

02-19-2018 NN Correspond with B. Whyte re budget for March 0.100 37.50

02-19-2018 NN Prepare monthly budget for March as required by Fee Examiner 0.400 150.00

Total Fees 262.50

Time Summary

Timekeeper Hours Rate Amount

NN 0.500 375.00 187.50

RR 0.600 125.00 75.00

Total Fees 262.50

L-160 Mediation

Professional Services

Date Timekeeper Description Hours Amount

02-01-2018 NN Review draft of Joint Motion to extend mediation authority and 

proposed order

0.200 75.00

02-01-2018 NN Correspond with C. Koenig (WF&G) re draft of Motion to extend 

mediation authority

0.100 37.50

02-01-2018 NN Read final version of filed Joint Mediation Motion 0.200 75.00

02-03-2018 NN Correspond with co-counsel and B. Whyte re opinion and Order 

granting Motion to Dismiss claims in AP filed by Assured, FGIC 

and National

0.200 75.00

02-05-2018 NN Read limited objection QTCB Noteholder group's to Joint Urgent 

Motion for order expanding scope of mediation

0.100 37.50

02-05-2018 NN Draft Memorandum re Governor's message at B. Whyte's 

request to identify issues relevant to COFINA GO-Dispute

0.300 112.50

02-05-2018 NN Read updates sent by WF&G re new developments in PR 

relevant to COFINA Agent and GO-COFINA dispute

0.100 37.50

02-05-2018 NN Listen to Governor's message at B. Whyte's request and draft 

Memorandum re same

0.200 75.00

02-06-2018 NN Read updates of new economic developments in PR re Fiscal 

Plan relevant to COFINA GO-Dispute sent by B. Whyte and 

WF&G

0.400 150.00

02-06-2018 NN Analyze AAFAF's Objection to Joint Urgent Motion of the FOMB, 

the Commonwealth Agent and the COFINA Agent for Order 

expanding authority and immunity

0.300 112.50

02-06-2018 NN Read Ad Hoc Group of GO Bondholders' Joinder in QTCB's 

Limited Objection to Joint Urgent Motion for Order expanding 

scope of mediation

0.100 37.50

02-06-2018 NN Correspond with B. Whyte and co-counsel re Go Bondholder's 

and AAFAF's Objections to Motion for Order expanding 

mediation scope

0.300 112.50

02-07-2018 NN Revise draft of Reply to Joint Motion to expand mediation 0.300 112.50

02-07-2018 NN Correspond with C. Koenig (co-counsel) re draft of Reply to Joint 

Motion to expand mediation

0.300 112.50

02-07-2018 NN Read various news reports sent by WF&G re new developments 

in PR with SUT relevant to COFINA Agent and the COFINA-GO 

Dispute

0.200 75.00

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Date Timekeeper Description Hours Amount

02-08-2018 NN Read update reports sent by B. Whyte re new developments 

with federal budget relevant to PR and mediation and COFINAGO dispute

0.200 75.00

02-09-2018 NN Read update reports sent by B. Whyte re new developments 

with federal budget allocation for PR and PR's response

0.300 112.50

02-10-2018 NN Read Court Order granting Joint Motion expanding mediation 0.100 37.50

02-10-2018 NN Correspond with B. Whyte and co-counsel re Court Order as to 

scope of mediation

0.200 75.00

02-12-2018 NN Read news reports and updates sent to B. Whyte re FOMB's 

statements as to federal budget and PR

0.100 37.50

02-12-2018 NN Analyze draft of Mediation Statement of out of scope issues 0.700 262.50

02-12-2018 NN Correspond with co-counsel and B. Whyte re draft of Mediation 

Statement of out of scope issues

0.200 75.00

02-13-2018 NN Read and analyze revisions made to draft of Mediation 

Statements of out of scope issues

0.600 225.00

02-13-2018 NN Correspond with co-counsel re draft of Mediation Statement of 

out of scope issues

0.500 187.50

02-13-2018 NN Read Mediation Statement re in scope issues 0.300 112.50

02-13-2018 NN Read report sent by WF&G re new fiscal plan 0.100 37.50

02-14-2018 NN Read updates sent by B. Whyte re new developments in PR 

relevant to COFINA Agent

0.300 112.50

02-14-2018 NN Correspond with C. Koenig re statement submitted to mediator 0.100 37.50

02-15-2018 NN Correspond with co-counsel re Statement submitted to mediator 

as to out of scope claims

0.100 37.50

02-15-2018 NN Review final version of Statement to mediator re out of scope 

claims

0.300 112.50

02-16-2018 NN Correspond with co-counsel and B. Whyte re Motion as to 

Commonwealth's Motion re mediation

0.200 75.00

02-16-2018 NN Read draft of Commonwealth Motion re mediation 0.100 37.50

02-16-2018 NN Read report sent by WF&G re FOMB's press release as to Fiscal 

Plan and read press release

0.100 37.50

02-21-2018 NN Read news updates re Governor's declarations sent by B. Whyte 

as to Commonwealth's liquidity

0.100 37.50

02-21-2018 NN Read updates sent by A. Ambeault (WF&G) re developments 

with SUT

0.100 37.50

02-21-2018 NN Read news report re new Fiscal Plan in PR sent by B. Whyte 0.100 37.50

02-23-2018 NN Read Judge Housser's Memorandum re mediation 0.100 37.50

02-24-2018 NN Correspond with B. Whyte and co-counsel re mediation strategy 0.400 150.00

02-24-2018 NN Read report re economists' explanations as to Fiscal Plan 0.100 37.50

02-25-2018 NN Correspond with B. Whyte and co-counsel re mediation strategy 0.300 112.50

02-26-2018 NN Read news report sent by B. Whyte re Governor's criticism to 

Treasury Department

0.100 37.50

02-26-2018 NN Read news report sent by B. Whyte re Fiscal Plan and recovery 0.100 37.50

02-27-2018 NN Read news report sent by B. Whyte re Government's declaration 

that payment to Bondholders is out of budget

0.100 37.50

02-27-2018 NN Read updates re PR TSA report as to net cash flow sent by 

WF&G

0.100 37.50

02-27-2018 NN Read news updates sent by B. Whyte re PR Government's 

statements as to US Treasury Departments' delay in providing 

relief

0.100 37.50

Total Fees 3,562.50

Time Summary

Timekeeper Hours Rate Amount

NN 9.500 375.00 3,562.50

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Timekeeper Hours Rate Amount

Total Fees 3,562.50

L-200 Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

02-01-2018 NN Read Ambac's Motion re February Omnibus hearing 0.100 37.50

02-01-2018 NN Read case updates sent by WF&G 0.300 112.50

02-01-2018 NN Confer with C. Koenig re upcoming Omnibus hearing in PR 0.200 75.00

02-01-2018 NN Correspond with A. Yanez re issues of PR law relevant to Motion 

for Summary Judgment

0.300 112.50

02-01-2018 NN Legal research re issues of PR law as to possible Certification to 

PR Supreme Court

0.800 300.00

02-01-2018 NN Read FOMB's Urgent Motion for Order clarifying scope of Interim 

Hearing and Order re same

0.100 37.50

02-01-2018 NN Review dockets to identify new filings relevant to COFINA Agent 0.400 150.00

02-01-2018 NN Read various Informative Motions re Omnibus hearing 0.500 187.50

02-01-2018 NN Review Objections filed to FOMB's and AAFAF's Urgent Joint 

Motion for Orders Authorizing Post-petition Secured Financing

0.800 300.00

02-01-2018 NN Read Order establishing procedure for filings due to CM/ECF 

maintenance

0.100 37.50

02-01-2018 NN Read Order granting Ad Hoc Group of GO Bondholders' Urgent 

Motion to expedite consideration of Urgent Cross-motion

0.100 37.50

02-02-2018 NN Correspond with A. Yanez re issue of PR law for Motion for 

Summary Judgment

0.300 112.50

02-02-2018 NN Study new draft of Motion for Summary Judgment to provide 

comments

1.200 450.00

02-02-2018 NN Read Order scheduling briefing re Joint Motion for Order 

expanding scope of Mediation

0.100 37.50

02-02-2018 NN Read Informative Motions re Omnibus hearing 0.300 112.50

02-03-2018 NN Analyze Opinion and Order granting Motion to Dismiss claims in 

AP filed by Assured, FGIC and National against the Debtors

0.400 150.00

02-03-2018 NN Read news and updates sent by B. Whyte re new developments 

in the Title III cases relevant to GO-COFINA dispute

0.400 150.00

02-03-2018 NN Read Mutual Fund Group's Motion for Voluntary Dismissal in AP 

against COFINA Agent

0.100 37.50

02-03-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.600 225.00

02-03-2018 NN Read Order denying FOMB's Urgent Motion to clarify the scope 

of interim financing hearinf

0.100 37.50

02-03-2018 NN Correspond with C. Koenig re Omnibus hearing 0.200 75.00

02-05-2018 NN Read FOMB's Urgent Informative Motion withdrawing request for 

interim financing with respect to Urgent Joint Motion

0.100 37.50

02-05-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.400 150.00

02-05-2018 NN Read AAFAF's Amended Motion re Omnibus hearing 0.100 37.50

02-05-2018 NN Correspond with B. Whyte and co-counsel re Governor's 

message

0.200 75.00

02-05-2018 NN Correspond with B. Whyte and co-counsel re QTCB Objection 0.200 75.00

02-05-2018 NN Read litigation updates sent by WF&G 0.200 75.00

02-05-2018 NN Correspond with B. Whyte and co-counsel re QTCB Objection 0.200 75.00

02-05-2018 NN Correspond with B. Whyte re Governor's message 0.100 37.50

02-06-2018 NN Read Ambac's Reply in further support of its Urgent Cross-Motion 0.100 37.50

02-06-2018 NN Read Agenda for Omnibus hearing 0.100 37.50

02-06-2018 NN Read Informative Motions and Amended Informative Motions re 0.500 187.50

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Date Timekeeper Description Hours Amount

Omnibus hearing

02-06-2018 NN Read litigation updates sent by WF&G 0.200 75.00

02-07-2018 NN Attend Omnibus hearing 2.300 862.50

02-07-2018 NN Correspond with D. Bussel and A. Yanez (co-counsel) re 

procedure for certification of issues to PR Supreme Court

0.400 150.00

02-07-2018 NN Study current Rules of the Supreme Court of PR for procedure 

for USDC to certify questions to PR Supreme Court and previous 

Rules

0.600 225.00

02-07-2018 NN Weekly conference call with B. Whyte and co-counsel re new 

developments and strategy

0.700 262.50

02-07-2018 NN Correspond with B. Whyte and co-counsel re draft of Reply to 

Joint Motion to expand mediation

0.500 187.50

02-07-2018 NN Read final version of Joint Omnibus Reply in support of Joint 

Urgent Motion for an Order expanding for mediation purposes 

only authority and immunity protection

0.200 75.00

02-07-2018 NN Read litigation updates sent by WF&G 0.200 75.00

02-07-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

02-07-2018 NN Read Order granting Mutual Fund's Motion for Voluntary 

Dismissal with prejudice in AP against COFINA Agent

0.100 37.50

02-07-2018 NN Read Order granting Urgent Motion of Ad Hoc Group of PREPA 

Bondholders and others to set briefing

0.100 37.50

02-07-2018 NN Read Court Minutes of Omnibus hearing 0.100 37.50

02-08-2018 NN Read litigation update sent by WF&G 0.100 37.50

02-08-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

02-08-2018 NN Correspond with a. Cheney (WF&G) re requirements for 

certification of issues to PR Supreme Court

0.100 37.50

02-09-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

02-09-2018 NN Analyze draft of proposed questions for certification to PR 

Supreme Court in light of requirements of PR Supreme Court 

Rules

1.300 487.50

02-10-2018 NN Read litigation update sent by WF&G 0.100 37.50

02-10-2018 NN Revise new draft of proposed questions for certification to PR 

Supreme Court in light of relevant pleadings, Orders and 

legislation

1.800 675.00

02-10-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

02-10-2018 NN Read Supplemental Objections to FOMB's, Commonwealth's 

and PREPA's Urgent Motion for Order authorizing post-petition 

secured financing filed by U.S. Bank National, Assured Guaranty 

Corp., National and Syncora

0.600 225.00

02-10-2018 NN Read Court Order re February 15 hearing 0.100 37.50

02-10-2018 NN Read Court Order granting limited intervention in connection with 

the financing motion

0.100 37.50

02-10-2018 NN Read Informative Motion re February 15 hearing 0.200 75.00

02-11-2018 NN Draft comments and questions as to draft of proposed questions 

for certification to PR Supreme Court

0.600 225.00

02-11-2018 NN Legal research re Certification process to respond to co-counsel 

comments as to draft of proposed questions for certification

1.400 525.00

02-11-2018 NN Correspond with B. Whyte and co-counsel re draft of proposed 

questions for certification

0.400 150.00

02-12-2018 NN Correspond with co-counsel re proposed questions for 

certification to PR Supreme Court

0.200 75.00

02-12-2018 NN Confer with D. Bussel (co-counsel) re draft of questions for 

certification before the Supreme Court

0.500 187.50

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Date Timekeeper Description Hours Amount

02-12-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

02-12-2018 NN Review multiple Informative Motions filed re February 15 hearing 0.300 112.50

02-12-2018 NN Read case updates sent by B. Whyte re litigation and new 

developments relevant to Go-COFINA dispute

0.200 75.00

02-12-2018 NN Read Order granting Mutual's Motion for Voluntary Dismissal 

without prejudice

0.100 37.50

02-13-2018 RR Legal research on PACER to obtain pleadings and orders from 

dockets of cases certified to PR Supreme Court to use for 

certification brief

4.400 550.00

02-13-2018 NN Correspond with A. Cheney (WF&G) re procedure to request 

questions to be certified to Supreme Court of PR

0.500 187.50

02-13-2018 NN Study case law, pleadings and Orders in cases certified by 

federal courts to PR Supreme Court to answer questions from cocounsel re certification process and requirements

3.100 1,162.50

02-13-2018 NN Correspond with A. Ambeault (WF&G) re new Pro Hac Vice 

Motion

0.200 75.00

02-13-2018 NN Review draft of Pro Hac Vice Motion for A. Cheney 0.100 37.50

02-13-2018 NN Analyze revised draft of questions for certification to PR 

Supreme Court

0.400 150.00

02-13-2018 NN Correspond with S. Hussein and D. Bussel (co-counsel) re 

revised draft of questions for certification to PR Supreme Court

0.300 112.50

02-14-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

02-14-2018 NN Read litigation update sent by WF&G 0.300 112.50

02-14-2018 NN Read Second Supplemental Declaration of Despins re retention 

of Paul Hastings as counsel to Official Committee of Unsecured 

Creditors

0.100 37.50

02-14-2018 NN Read FOMB's Unopposed Urgent Informative Motion requesting 

Court Approval of Joint Stipulation

0.100 37.50

02-14-2018 NN Read Assured's Motion to File Under Seal 0.100 37.50

02-14-2018 NN Read Pro Hac Vice Motion for A. Cheney filed on behalf of 

COFINA Agent

0.100 37.50

02-14-2018 NN Read Agenda for February 15 hearing 0.100 37.50

02-14-2018 NN Review Stipulated Protective Order filed by Commonwealth, 

FOMB, AAFAF and PREPA

0.200 75.00

02-14-2018 NN Read FOMB, AAFAF and PREPA's Joint Motion re February 15 

hearing

0.100 37.50

02-14-2018 NN Read Joint Stipulation and Order re experts testimony filed by 

FOMB, AAFAF and PREPA

0.100 37.50

02-14-2018 NN Read Order referring to Magistrate Judge FOMB's Urgent Motion 0.100 37.50

02-14-2018 NN Read Commonwealth Agent's Answer to COFINA Agent's 

Second Amended Counterclaim in AP against COFINA Agent

0.200 75.00

02-14-2018 NN Weekly conference call with B. Whyte and co-counsel to discuss 

new developments, pending matters and strategy

0.400 150.00

02-14-2018 NN Correspond with A. Cheney re procedure for requesting 

certification of questions to PR Supreme Court

0.200 75.00

02-14-2018 NN Read Commonwealth's reservation of rights as to Ambac's 

Amended Counterclaim in AP against COFINA Agent

0.100 37.50

02-14-2018 NN Read Commonwealth Agent's Answer to National's Amended 

Counterclaim in AP against COFINA

0.100 37.50

02-14-2018 NN Read Commonwealth Agent's Answer to COFINA Senior 

Bondholders' Amended Counterclaim in AP against COFINA 

Agent

0.100 37.50

02-14-2018 NN Read Commonwealth Agent's Answer to Mutual Fund's 

Amended Counterclaims in AP against COFINA Agent

0.100 37.50

02-14-2018 RR Round trip to Court to process payment of Pro Hac Vice fees for 0.900 112.50

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Date Timekeeper Description Hours Amount

A. Cheney and obtain required receipt

02-14-2018 RR Finalize for filing and file Pro Hac Vice Motion for A. Cheney 0.300 37.50

02-15-2018 NN Correspond with S. Hussein re certified translator needed for 

translating cases to submit to USDC in support of Motion

0.200 75.00

02-15-2018 NN Read reports sent by B. Whyte re court hearing 0.200 75.00

02-15-2018 NN Read emails from A. Cheney (WF&G) with questions re 

applicable procedure if USDC certifies questions to PR Supreme 

Court

0.100 37.50

02-15-2018 NN Analyze Rules of Supreme Court of PR (in English and original 

in Spanish) to respond to A. Cheney's questions

0.400 150.00

02-15-2018 NN Review Ad Hoc Group of GO Bondholder's Answers to COFINA 

Agent's Amended Counterclaim

0.200 75.00

02-15-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

02-15-2018 NN Read Ad Hoc Group of GO Bondholder's Answer to COFINA 

Agent Senior Bondholders Coalition's Amended Counterclaim

0.100 37.50

02-15-2018 NN Read Commonwealth Agent's Urgent Motion for leave to exceed 

page limit

0.100 37.50

02-15-2018 NN Read Court Order re February 13 hearing 0.100 37.50

02-15-2018 NN Read Court Order granting our Motion to allow A. Cheney to 

appear Pro Hac Vice

0.100 37.50

02-15-2018 NN Read Informative Motions re February 15 hearing 0.200 75.00

02-15-2018 NN Read Court Order establishing deadlines and procedures for 

filing proofs of claim

0.100 37.50

02-16-2018 NN Correspond with A. Ambeault re draft of expert witness disclosure 0.100 37.50

02-16-2018 NN Review draft of expert witness disclosure 0.100 37.50

02-16-2018 NN Legal research to respond to question from A. Cheney (WF&G) 

re certification procedure before Supreme Court of PR

2.800 1,050.00

02-16-2018 NN Draft email correspondence to A. Cheney re procedure before 

Supreme Court of PR after questions are certified

0.900 337.50

02-16-2018 NN Read reports sent by WF&G re new developments in Title III 

cases relevant to Go-COFINA dispute

0.400 150.00

02-16-2018 NN Read email correspondence from A. Ambeault (WF&G) re 

analysis of Amended Answers to COFINA Agent's Amended 

Counterclaim and attachments

0.200 75.00

02-16-2018 NN Read COFINA Senior Bondholder Coalition's Motion for leave to 

exceed page limit

0.100 37.50

02-17-2018 NN Study and analysis of case law of PR Supreme Court re 

requirements and procedure for certification to PR Supreme 

Court to provide futher comments as to A. Cheney's questions

2.700 1,012.50

02-17-2018 NN Draft email to A. Cheney (WF&) with further details re procedure 

before the PR Supreme Court once USDC certifies questions

0.400 150.00

02-17-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

02-17-2018 NN Read filed Motion of FOMB, Commonwealth Agent and COFINA 

Agent Motion re undertaking of mediation

0.100 37.50

02-17-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.400 150.00

02-17-2018 NN Read Court Minutes re February 15 hearing 0.100 37.50

02-17-2018 NN Correspond with A. Ambeault re upcoming filings in AP against 

COFINA Agent

0.100 37.50

02-17-2018 NN Read Order granting FOMB's and AAFAF's Urgent Motion to 

schedule Resolution Urgent Application and Notice of Revised 

Proposed Loan from Commonwealth to PREPA

0.100 37.50

02-17-2018 NN Correspond with H. Honig re Joint undertaking 0.100 37.50

02-17-2018 NN Correspond with A. Cheney re draft of brief seeking certification 

of questions to the PR Supreme Court

0.200 75.00

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Date Timekeeper Description Hours Amount

02-17-2018 NN Analyze draft seeking certification of questions to the PR 

Supreme Court

0.600 225.00

02-17-2018 NN Study cases cited in draft of brief seeking certification of 

questions to the PR Supreme Court

1.800 675.00

02-17-2018 NN Conduct further legal research as to cases in which Certification 

was granted for brief in support of certification of questions to the 

PR Supreme Court

2.400 900.00

02-19-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

02-19-2018 NN Read Court Order re FOMB's and AAFAF's Urgent Application 

and Notice of Revised Proposed Loan from Commonwealth to 

PREPA

0.100 37.50

02-19-2018 NN Correspond with B. Whyte and co-counsel re draft of brief 

requesting Court to certify questions to PR Supreme Court

0.500 187.50

02-19-2018 NN Study applicable First Circuit case law re the process for the 

USDC to certify questions of PR law to the PR Supreme Court

3.600 1,350.00

02-19-2018 NN Draft Memorandum with Analysis of the process and 

requirements for the USDC to certify questions of PR law to the 

PR Supreme Court

1.400 525.00

02-19-2018 NN Correspond with D. Bussel (KTBS) re process of certification of 

questions to the PR Supreme Court

0.100 37.50

02-19-2018 NN Correspond with A. Yanez, J. Korn, A. Cheney and D. Bussel re 

requirements for certification of questions of PR law to PR 

Supreme Court

0.300 112.50

02-19-2018 NN Read Court Order granting COFINA Senior Bondholder's Motion 

to exceed page limit

0.100 37.50

02-19-2018 RR Legal research as to PR case law re issues suitable for 

Certification for brief requesting Court to certify questions of PR 

law to PR Supreme Court

4.200 525.00

02-20-2018 NN Correspond with S. Hussein re new findings as to cases cited in 

brief requesting certification to PR Supreme Court

0.300 112.50

02-20-2018 NN Read reports sent by A. Ambeault (WF&G) re new developments 

in PROMESA Article III litigation

0.300 112.50

02-20-2018 NN Correspond with S. Hussein re revised draft of brief in support of 

Motion for Summary Judgment and statement of undisputed facts

0.100 37.50

02-20-2018 NN Read and analyze draft of statement of undisputed facts in 

support of Motion for Summary Judgment

1.400 525.00

02-20-2018 NN Confer with D. Bussel (KTBS) re new draft of proposed 

questions of PR

0.400 150.00

02-20-2018 NN Correspond with J. Korn and S. Hussein (WF&G) re new 

revisions to brief requesting district court to certify questions of 

PR law as to the Supreme Court of PR

0.500 187.50

02-20-2018 RR Obtain Certified Translation of recent Supreme Court case re 

interjurisdictional certification

0.300 37.50

02-20-2018 RR Study Court dockets in Federal cases cited in brief requesting 

Court to certify questions of PR law to the Supreme Court of PR 

to verify if PR Supreme Court granted certification

1.200 150.00

02-20-2018 NN Correspond with B. Whyte and co-counsel to coordinate weekly 

conference call

0.200 75.00

02-20-2018 NN Correspond with B. Whyte and co-counsel re revision to draft of 

questions for certification to PR Supreme Court proposed by 

constituents

0.500 187.50

02-20-2018 NN Analyze new draft of revised proposed questions for 

certifications to PR Supreme Court

0.600 225.00

02-20-2018 NN Confer with S. Hussein and J. Korn (WF&G) re draft of brief 

requesting Court to certify questions of PR law to PR Supreme 

Court

0.400 150.00

02-20-2018 NN Read update sent by WF&G re new developments in Title III 

cases relevant to COFINA Agent

0.200 75.00

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Date Timekeeper Description Hours Amount

02-20-2018 NN Draft revision to the brief requesting Court to certify questions of 

PR law to the Supreme Court of PR

1.200 450.00

02-21-2018 NN Correspond with S. Hussein re revised draft of Motion for 

Summary Judgment

0.400 150.00

02-21-2018 NN Revise new draft of statement of undisputed facts in support of 

Motion for Summary Judgment

0.800 300.00

02-21-2018 NN Review additional changes to draft of statement of undisputed 

facts for Motion for Summary Judgment

0.500 187.50

02-21-2018 NN Correspond with A . Yanez re issue of PR law and review 

documents sent

0.300 112.50

02-21-2018 NN Preliminary review of new draft of Motion for Summary Judgment 0.500 187.50

02-21-2018 NN Read Order scheduling briefing re Joint Motion for Order 

expanding scope of mediation

0.100 37.50

02-21-2018 NN Read various Informative Motions re Omnibus hearing 0.300 112.50

02-21-2018 NN Analyze revised Memorandum in support of Motion for Summary 

Judgment

1.600 600.00

02-21-2018 NN Correspond with S. Hussein re new changes to brief in support 

of Motion for Summary Judgment

0.100 37.50

02-21-2018 NN Review new changes to draft of statement of facts in support of 

Motion for Summary Judgment

0.200 75.00

02-22-2018 NN Read litigation update sent by A. Ambeault (WF&G) re multiple 

Motion for Summary Judgment

0.300 112.50

02-22-2018 NN Correspond with S. Hussein re request for Certification to 

Supreme Court of PR

0.100 37.50

02-22-2018 NN Confer with S. Hussein re request for Certification to Supreme 

Court

0.100 37.50

02-22-2018 NN Read Motion for Summary Judgment of Official Committee of 

Retirees in AP against COFINA Agent

0.100 37.50

02-22-2018 NN Read Commonwealth Agent's Urgent Motion for amendment of 

trial expert discovery deadlines

0.200 75.00

02-22-2018 NN Weekly conference call with B. Whyte and co-counsel re new 

developements and strategy

0.600 225.00

02-22-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

02-22-2018 NN Read Urgent Motion of Commonwealth Agent to expedite 

consideration of Urgent Motion

0.100 37.50

02-22-2018 NN Read Notice of filing of Motion for Summary Judgment of 

COFINA Senior Bondholders' Coalition

0.100 37.50

02-22-2018 NN Analyze Memorandum of Law of COFINA Senior Bondholders' 

Coalition in support of Motion for Summary Judgment

0.900 337.50

02-22-2018 NN Read Statement of undisputed material facts in support of the 

Motion for Summary Judgment of COFINA Senior Bondholders

0.300 112.50

02-22-2018 NN Review exhibits submitted by COFINA Senior Bondholders' 

Coalition in support of Motion for Summary Judgment

0.800 300.00

02-22-2018 NN Read COFINA Agent's Notice of Motion for Summary Judgment 0.100 37.50

02-22-2018 NN Read Notice of Motion for Summary Judgment of the Ad Hoc 

Group of GO Bondholders

0.100 37.50

02-22-2018 NN Review of Declaration and exhibits in support of the Motion for 

Summary Judgment of the AD HOC Group of GO Bondholders

0.700 262.50

02-22-2018 NN Review Declaration and exhibits in support of the Motion for 

Summary Judgment of Mutual Funds Group Motion for Summary 

Judgment

0.800 300.00

02-22-2018 NN Read statement of Undisputed Material Facts in support of the 

Motion for Summary Judgment of COFINA Agent

0.200 75.00

02-22-2018 NN Analyze Motion for Summary Judgment of the AD HOC Group of 

GO Bondholders

1.200 450.00

02-22-2018 NN Review exhibits filed in support of COFINA Agent's Motion for 1.700 637.50

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Date Timekeeper Description Hours Amount

Summary Judgment

02-22-2018 NN Review filed Memorandum of Law of COFINA Agent in support 

of Motion for Summary Judgment

0.100 37.50

02-22-2018 NN Read Mutual Fund Group's and PR Funds' Motion for Summary 

Judgment

0.100 37.50

02-22-2018 NN Read Mutual Funds Group and PR Funds' Statement of 

Undisputed material facts in support of Motion for Summary 

Judgment

0.200 75.00

02-22-2018 NN Read Joinder of National Public Finance Guarantee Corporation 

to COFINA Agent's Motion for Summary Judgment

0.100 37.50

02-22-2018 NN Read Notice of Commonwealth Agent's Motion for Summary 

Judgment

0.100 37.50

02-23-2018 NN Analyze Commonwealth Memorandum of Law in Support of 

Motion for Summary

0.900 337.50

02-23-2018 NN Read Statement of Undisputed Material Facts in support of the 

Motion for Summary Judgment filed by Commonwealth

0.100 37.50

02-23-2018 NN Revise new draft of certification brief to suggest edits 1.400 525.00

02-23-2018 NN Correspond with S. Hussein (WF&G) re revised certification brief 0.200 75.00

02-23-2018 NN Confer with S. Hussein (WF&G) re revised certification brief 0.100 37.50

02-23-2018 NN Revise draft of Order for Certification of questions to PR 

Supreme Court

0.500 187.50

02-23-2018 NN Correspond with B. Whyte and co-counsel re constituents' 

position as to Certification of questions of PR Law to PR 

Supreme Court

0.500 187.50

02-23-2018 NN Read news update sent by B. Whyte re Assured's declarations 

as to developments in the Title III litigation and impact to creditors

0.100 37.50

02-23-2018 NN Draft new language to include in proposed Order for Certification 

to PR Supreme Court

0.400 150.00

02-23-2018 NN Correspond with S. Hussein and A.Yanez re draft of proposed 

Order for Certification to PR Supreme Court

0.300 112.50

02-23-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

02-23-2018 NN Read A. López' Motion withdrawing as local counsel for AAFAF 

and announcing new local counsel

0.100 37.50

02-23-2018 NN Read Declaration in support of Commonwealth Agent's Motion 

for Summary Judgment

0.100 37.50

02-23-2018 NN Review exhibits submitted by the Commonwealth Agent in 

support of Motion for Summary Judgment

1.300 487.50

02-23-2018 NN Read Joinder of Ambac Assurance to COFINA Agent's Motion 

for Summary Judgment

0.100 37.50

02-24-2018 RR Legal research re cases cited in proposed changes to brief 

requesting certification to PR Supreme Court

0.900 112.50

02-24-2018 NN Correspond with B. Whyte and co-counsel as to Memorandum 

from constituents' local counsel re possible certification to PR 

Supreme Court

0.300 112.50

02-24-2018 NN Analyze Memorandum from E. Pérez-Ochoa (National's local 

counsel) re Certification to PR Supreme Cout

0.200 75.00

02-24-2018 NN Correspond with A. Yanez (WF&G) re new proposed changes 

received from constituents to draft brief requesting certification to 

PR Supreme Court

0.300 112.50

02-24-2018 NN Analyze new changes proposed by constituents to brief 

requesting certification to PR Supreme Court

0.600 225.00

02-24-2018 NN Draft comments to new changes proposed by constituents to 

brief requesting certification to PR Supreme Court

0.700 262.50

02-24-2018 NN Correspond with S. Hussein (WF&G) re revised draft of brief 

requesting certification to PR Supreme Court

0.200 75.00

02-24-2018 NN Analyze additional proposed changes to questions for 0.300 112.50

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Date Timekeeper Description Hours Amount

certification to PR Supreme Court

02-24-2018 NN Correspond with A. Yanez, J. Korn and S. Hussein (WF&G) re 

proposed new changes to questions for certification to Supreme 

Court of PR

0.200 75.00

02-24-2018 NN Review Court dockets to identify new filings relevant to COFINA 0.300 112.50

02-24-2018 NN Read Court Order enlarging the time within which PREPA may 

file notices of removal

0.100 37.50

02-24-2018 NN Read Third Supplemental verified statement of the Mutual Fund 

Group pursuant to FRBP 2019

0.100 37.50

02-24-2018 NN Study case law cited in proposed new language to brief re 

Cetification

0.300 112.50

02-25-2018 NN Analyze new revised version of the brief requesting certification 

incorporating constituents' suggestions

0.400 150.00

02-25-2018 NN Correspond with B. Whyte and co-counsel re new revised 

version of brief requesting certification

0.500 187.50

02-25-2018 NN Correspond with B. Whyte and co-counsel re constituents' 

position as to certification

0.400 150.00

02-25-2018 NN Analyze draft of Order for certification sent by WF&G 0.300 112.50

02-25-2018 NN Correspond with B. Whyte and co-counsel re draft Order for 

certification

0.500 187.50

02-25-2018 NN Correspond with co-counsel and B. Whyte re possible hearing as 

to request for certification to PR Supreme Court

0.200 75.00

02-26-2018 NN Read news sent by B. Whyte as to Court's Order re process for 

creditors to file proof of claims

0.100 37.50

02-26-2018 NN Read changes proposed by KTBS to the draft Order for 

certification to PR Supreme Court

0.100 37.50

02-26-2018 NN Read changes proposed by KTBS to the brief requesting 

certification to PR Supreme Court

0.100 37.50

02-26-2018 NN Correspond with B. Whyte and co-counsel re draft of brief 

requesting certification to PR Supreme Court

0.500 187.50

02-26-2018 NN Revise draft of Urgent Motion requesting hearing as to request 

for certification

0.200 75.00

02-26-2018 NN Correspond with B. Whyte and co-counsel re Urgent Motion for 

hearing of request of Certification to PR Supreme Court

0.200 75.00

02-26-2018 NN Review last changes made to draft of brief requesting Court to 

verify questions to PR Supreme Court to approve for filing

0.100 37.50

02-26-2018 NN Correspond with S. Hussein and A. Ambeault re filing of brief 

requesting Court to certify questions to PR Supreme Court to 

approve for filing

0.200 75.00

02-26-2018 NN Read filed Motion and Memorandum of Law of COFINA Agent 

requesting Certification of questions to PR Supreme Court

0.200 75.00

02-26-2018 NN Read filed Urgent Motion of the COFINA Agent to set expedited 

briefing schedule on the COFINA Agent's Motion to Certify

0.100 37.50

02-26-2018 NN Review Court dockets in Title III main case and AP against 

COFINA Agent to identify new filings relevant to COFINA Agent

0.200 75.00

02-26-2018 NN Analyze Court Order re discovery as to Fiscal Plan 0.200 75.00

02-27-2018 NN Read litigation updates sent by WF&G as to new developments 

in AP against COFINA Agent

0.200 75.00

02-27-2018 NN Read Statement of the COFINA Senior Bondholders' Coalition in 

support of and Joinder to the COFINA Agent's motion

0.100 37.50

02-27-2018 NN Read Mutual Funds Group's and PR Funds Motion to Certify 

questions of law to the Supreme Court of Puerto Rico

0.100 37.50

02-27-2018 NN Read Court Order setting the response deadlines for Urgent 

Motion to set the briefing schedule on our Motion to Certify

0.100 37.50

02-27-2018 NN Correspond with B. Whyte and co-counsel re Order setting the 

response deadlines for Urgent Motion to set the briefing 

schedule on our Motion to certify

0.200 75.00

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14

Date Timekeeper Description Hours Amount

02-27-2018 NN Review Court dockets to identify new filings in Title III main case 

and AP against COFINA Agent relevant to COFINA

0.200 75.00

02-27-2018 NN Review Court docket to identify new filings in Title III main cas 

and AP against COFINA Agent relevant to COFINA Agent

0.200 75.00

02-27-2018 NN Read Motion for Leave to withdraw as counsel to the Employees 

Retirement System

0.100 37.50

02-27-2018 NN Read updates sent by WF&G re new Motions filed in AP against 

COFINA Agent

0.200 75.00

02-28-2018 NN Analyze FOMB's Opposition to Urgent Motion of COFINA Agent 

to set expedited briefing schedule on COFINA Agent's Motion to 

certify questions to the PR Supreme Court

0.200 75.00

02-28-2018 NN Analyze Commonwealth Agent's Objection to Urgent Motion of 

COFINA Agent to set expedited briefing schedule on COFINA 

Agent's Motion to Certify

0.200 75.00

02-28-2018 NN Read Joinder of AAFAF to the Oversight Board's Opposition to 

the COFINA Agent's Motion to Certify Questions to the PR 

Supreme Court

0.100 37.50

02-28-2018 NN Correspond with S. Hussein re Reply to Commonwealth's 

Objection

0.100 37.50

02-28-2018 NN Revise draft of Reply to Opposition to the COFINA Agent's 

Motion to Certify questions to PR Supreme Court

0.300 112.50

02-28-2018 NN Correspond with S. Hussein and A. Yanez re strategy for draft of 

Reply to Opposition to the COFINA Agent's Motion for expedited 

hearing of Motion to Certify questions to PR Supreme Court

0.200 75.00

02-28-2018 NN Correspond with co-counsel from KTBS and WF&G re draft 

Reply to Opposition to the COFINA Agent's Motion requesting 

expedited hearing on Motion to Certify questions to PR Supreme 

Court

0.400 150.00

02-28-2018 NN Weekly conference call with B. Whyte and co-counsel re new 

developments and strategy

0.300 112.50

02-28-2018 NN Read final version filed of COFINA Agent's Reply to Objection to 

Motion for expedited hearing on Motion requesting Certification

0.100 37.50

02-28-2018 NN Read Reply filed by COFINA Senior Bondholders' Coalition to 

FOMB's Opposition to Urgent Motion of COFINA Agent to set 

expedited briefing schedule on Motion to Certify questions under 

Puerto Rico Law to the Supreme Court of PR

0.200 75.00

02-28-2018 NN Review Court dockets of Title III main case and AP against 

COFINA Agent to identify filings relevant to COFINA Agent

0.200 75.00

02-28-2018 NN Read Order granting Motion resigning legal representation of the 

Employees Retirement System

0.100 37.50

Total Fees 36,137.50

Time Summary

Timekeeper Hours Rate Amount

NN 92.300 375.00 34,612.50

RR 12.200 125.00 1,525.00

Total Fees 36,137.50

L-300 Discovery/Facts Analysis

Professional Services

Date Timekeeper Description Hours Amount

02-01-2018 NN Correspond with S. Hussein (WF&G) re Pagan's and Irizarry's 

depositions

0.100 37.50

02-01-2018 NN Read Joint Status Report on Ambac discovery requests related 

to SUT collections

0.200 75.00

02-03-2018 NN Read Order re FGIC's Joinder to National's Motion re Rule 2004 0.100 37.50

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Date Timekeeper Description Hours Amount

as to discovery from GDB

02-23-2018 NN Read Order amending schedule re expert discovery 0.100 37.50

02-23-2018 NN Correspond with co-counsel and B. Whyte re implications of 

Order amending schedule re expert discovery

0.200 75.00

Total Fees 262.50

Time Summary

Timekeeper Hours Rate Amount

NN 0.700 375.00 262.50

Total Fees 262.50

Total for this Invoice 43,435.00

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Exhibit B

(Itemized expenses for the period of February 1, 2018 through February 28, 2018)

Date Expense Amount Description

2/13/18 Data Acquisition (includes 

Legal Research)

$45.40 Legal research in PACER for brief to certify 

questions to PR Supreme Court

2/14/18 Pro hac vice fee $300.00 Application for admission pro hac vice for A. 

Cheney

2/16/18 Data Acquisition (includes 

Legal Research)

$10.90 Legal research in PACER for brief to certify 

questions to PR Supreme Court

2/17/18 Data Acquisition (includes 

Legal Research)

$21.00 Legal research in PACER for brief to certify 

questions to PR Supreme Court

2/20/18 Data Acquisition (includes 

Legal Research)

$8.80 Legal research in PACER for brief to certify 

questions to PR Supreme Court

2/23/18 Data Acquisition (includes 

Legal Research)

$2.90 Legal research in PACER for brief to certify 

questions to PR Supreme Court

2/28/18 Reproduction $21.00 In house copies

TOTAL $410.00

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EXHIBIT 4-B

TIME AND EXPENSE DETAIL FOR MARCH 2018 FEE STATEMENT

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10

Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

04-12-2018

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 18033163

Invoice Period: 03-01-2018 - 03-31-2018

RE: Multiple Matters

B-160 Fee Application and Retention

B-170 Fee Application Retention and Objections

E-100 Expenses

L-150 Budget

L-160 Mediation

L-200 Litigation/Adversary Proceeding

B-160 Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

03-01-2018 NN Read email from Fee Examiner re adjustment to Interim Fee 

Application

0.100 37.50

03-01-2018 NN Analyze Fee Examiners initial report 0.300 112.50

03-02-2018 NN Read Memorandum sent by Fee Examiner re information 

session with all retained professionals

0.100 37.50

03-02-2018 NN Correspond with Fee Examiner re information session with 

retained professionals

0.100 37.50

03-02-2018 NN Analyze proposed draft Order re uncontested fees 0.300 112.50

03-07-2018 NN Attend meeting with Fee Examiner and other counsel for 

orientation and discussion re fee applications

0.900 337.50

03-13-2018 NN Correspond with Fee Examiner re draft of Stipulated Disclosure 

Agreement and Protective Order

0.100 37.50

03-13-2018 NN Review revised Stipulated Disclosure Agreement and Protective 

Order

0.200 75.00

03-14-2018 NN Work on February Fee Application to comply with Fee 

Examiner's recommendations and requirements

0.800 300.00

03-14-2018 RR Work on February Fee Statement 1.300 162.50

03-15-2018 RR Conclude draft of February Fee Application 0.800 100.00

03-15-2018 NN Final Revision to February Fee Application 0.400 150.00

03-15-2018 NN Correspond with B. Whyte re draft of February Fee Application 0.100 37.50

03-15-2018 NN Correspond with S. Pearson (KTBS) and A. Ambeault (WF&G) 

re Second Interim Fee Application

0.200 75.00

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Date Timekeeper Description Hours Amount

03-16-2018 NN Correspond with A. Ambeault (WF&G) re Second Interim Fee 

Application and Omnibus Notice

0.200 75.00

03-16-2018 NN Review WF&G draft of Second Interim Fee Application in order 

to authorize my signature as local counsel

0.400 150.00

03-16-2018 NN Commence drafting Second Interim Fee Application 3.200 1,200.00

03-17-2018 NN Review draft of Omnibus Notice of Second Interim Fee 

Application

0.100 37.50

03-17-2018 NN Correspond with A. Ambeault and co-counsel re draft of 

Omnibus Notice of Second Interim Fee Application

0.100 37.50

03-17-2018 NN Draft section of summary of services rendered for Second 

Interim Fee Application for each category of services

3.700 1,387.50

03-17-2018 RR Obtain information needed for preparing Second Interim Fee 

Application

2.300 287.50

03-17-2018 RR Prepare cover for Interim Fee Application requested by Fee 

Examiner and perform necessary calculations to include in cover

1.200 150.00

03-18-2018 RR Verify correction of amounts, information and cites included in 

Second Interim Fee Application

2.700 337.50

03-18-2018 RR Prepare the exhibits for the Second Interim Fee Application, 

including Summary of Professionals, Summary of Expenses and 

Summary of Time by billing category and comparable 

compensation disclosure

2.400 300.00

03-18-2018 NN Draft sections of Second Interim Fee Application re discussion of 

budgets

0.500 187.50

03-18-2018 NN Revise cover sheet and calculations prepared by R. Rivera for 

Second Interim Application

0.900 337.50

03-18-2018 NN Draft sections of Second Interim Fee Application re fees and 

expenses incurred and re evaluation of services

3.300 1,237.50

03-18-2018 NN Draft section of Second Interim Fee Application re monthly fee 

statements

1.200 450.00

03-18-2018 NN Draft Certification to include with Second Interim Fee Application 0.600 225.00

03-19-2018 RR Finalize for filing and file with the CM/ECF system Navarro's 

Second Interim Fee Application

0.800 100.00

03-19-2018 RR File with CM/ECF system B. Whyte's Second Interim Fee 

Application

0.200 25.00

03-19-2018 NN Confirm to A. Ambeault filing of B. Whyte's and our Second 

Interim Applications

0.100 37.50

03-19-2018 NN Confer with A. Ambeault re Amended Notice of Second Interim 

Fee Applications

0.100 37.50

03-19-2018 NN Read Amended Notice of Second Interim Fee Applications 0.100 37.50

03-19-2018 NN Correspond with A. Ambeault (WF&G) re B. Whyte's Second 

Interim Fee Application

0.100 37.50

03-19-2018 NN Review B. Whyte's draft of Second Interim Fee Application to be 

able to sign it as local counsel as required by Local Rules

0.300 112.50

03-19-2018 NN Final revision of Second Interim Fee Application 2.400 900.00

03-19-2018 NN Correspond with A. Ambeault (WF&G) re KTBS' Second Interim 

Fee Application

0.200 75.00

03-19-2018 NN Correspond with A. Ambeault (WF&G) re revised version of 

WF&G's Second Interim Fee Application

0.100 37.50

03-23-2018 NN Review changes incorporated to Stipulated Disclosure 

Agreement and Protective Order sent by Fee Examiner

0.100 37.50

03-23-2018 NN Read email from K. Stadler (Fee Examiner) re Notice of 

Presentment of the Stipulated Disclosure Agreement and 

Protective Order to incorporate a change

0.100 37.50

Total Fees 9,487.50

Time Summary

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Timekeeper Hours Rate Amount

NN 21.400 375.00 8,025.00

RR 11.700 125.00 1,462.50

Total Fees 9,487.50

B-170 Fee Application Retention and Objections

Professional Services

Date Timekeeper Description Hours Amount

03-06-2018 RR Prepare Statement of No Objection re January Fee Statement 0.800 100.00

03-06-2018 NN Revise and finalize State of No Objection re January Fee 

Statement

0.300 112.50

03-06-2018 NN Notify Statement of No Objection re January Fee Statement 0.200 75.00

03-26-2018 RR Prepare Statement of No Objection re February Fee Statement 0.400 50.00

03-26-2018 NN Revise Statement of No Objection re February Fee Statement 0.200 75.00

03-26-2018 NN Correspond with S. Pearson and J. Weiss (KTBS) re joint 

notification of No Objection Statement for KTBS and Navarro to 

reduce expenses

0.100 37.50

Total Fees 450.00

Time Summary

Timekeeper Hours Rate Amount

NN 0.800 375.00 300.00

RR 1.200 125.00 150.00

Total Fees 450.00

E-100 Expenses

Expenses

Date Description Price Qty Amount

03-05-2018 Fedex Fees for mailing of January monthly statements 29.40 9 264.60

03-05-2018 In house copies 0.10 210 21.00

03-05-2018 Fedex Fees for mailing of January monthly statements 0 42.56

03-06-2018 No Objection Fee Statement mailing via FedEx 29.40 3 88.20

03-06-2018 No Objection Fee Statement mailing via FedEx 21.28 1 21.28

03-07-2018 No Objection Fee Statement mailing via FedEx 29.40 4 117.60

03-07-2018 No Objection Fee Statement mailing via FedEx 21.28 1 21.28

03-18-2018 In house copies 0.10 45 4.50

Total Expenses 581.02

L-150 Budget

Professional Services

Date Timekeeper Description Hours Amount

03-15-2018 RR Assist N. Navarro with calculations for budget for April 2018 0.600 75.00

03-15-2018 NN Prepare budget for April 2018 0.400 150.00

03-15-2018 NN Correspond with B. Whyte re budget for April 2018 0.100 37.50

Total Fees 262.50

Time Summary

Timekeeper Hours Rate Amount

NN 0.500 375.00 187.50

RR 0.600 125.00 75.00

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Timekeeper Hours Rate Amount

Total Fees 262.50

L-160 Mediation

Professional Services

Date Timekeeper Description Hours Amount

03-01-2018 NN Read news update sent by B. Whyte re PR addiction to debt 

relevant to GO-COFINA dipute

0.100 37.50

03-01-2018 NN Read news update sent by B. Whyte re Representative J. 

Gonzalez' proposal for paying debt's interest to bondholders

0.100 37.50

03-02-2018 NN Read report sent by WF&G re Resident Commissioner's 

statements as to using budget surplus to make interest debt 

payments

0.100 37.50

03-03-2018 NN Correspond with C. Koenig (WF&G), B. Whyte and co-counsel 

from WF&G and KTBS re draft materials for mediation

0.200 75.00

03-03-2018 NN Analyze draft of COFINA Agent’s Term Sheet for Potential 

Settlement of Commonwealth-COFINA Dispute

0.300 112.50

03-03-2018 NN Analyze Risk Assessment Summary Analysis sent by WF&G 0.200 75.00

03-03-2018 NN Analyze charts of core disputes and secondary disputes sent by 

WF&G for discussion

0.400 150.00

03-04-2018 NN Conference call with B. Whyte and co-counsel re upcoming 

mediation

0.400 150.00

03-05-2018 NN Analyze documents for mediation sent by C. Koenig (WF&G) 0.300 112.50

03-05-2018 NN Correspond with B. Whyte as to Governor's state of the 

Commonwealth address

0.200 75.00

03-05-2018 NN Listen to the Governor's state of the Commonwealth address at 

B. Whyte's request to identify any messages relevant to the 

COFINA Agent and the GO-COFINA dispute

1.400 525.00

03-05-2018 NN Draft Memorandum to B, Whyte summarizing Governor's state of 

the Commonwealth address

0.800 300.00

03-05-2018 NN Analyze Ambac's settlement principles for COFINA Agent sent 

by C. Koenig

0.200 75.00

03-05-2018 NN Correspond with B,. Whyte and co-counsel re Ambac's 

settlement principles for COFINA Agent and upcoming mediation 

session

0.300 112.50

03-06-2018 NN Correspond with B. Whyte and co-counsel re National's position 

as to possible settlement

0.200 75.00

03-06-2018 NN Read Judge Housser's Memorandum re conference call as to 

modification to Hacienda's historical reporting on its website of 

COFINA Accounts

0.100 37.50

03-06-2018 NN Correspond with B. Whyte and co-counsel re constituents' 

mediation views

0.200 75.00

03-06-2018 NN Analyze Memoranda constituents' mediation views 0.300 112.50

03-06-2018 NN Read new updates sent by B. Whyte re Govenor's message and 

his statement that the SUT for processed food will be reduced

0.200 75.00

03-06-2018 NN Read updates sent by A. Ambeault re COFINA Senior 

Bondholders' Coalition

0.100 37.50

03-07-2018 NN Read news report as to Federal Reserve's President statement 

as to PR economy sent by B. Whyte

0.100 37.50

03-07-2018 NN Read report as to PR weekly cash flow sent by WF&G 0.100 37.50

03-07-2018 NN Analyze settlement proposed term sheet sent by C. Koenig 0.300 112.50

03-07-2018 NN Analyze summary of mediation positions sent by C. Koenig 0.400 150.00

03-07-2018 NN Correspond with B. Whyte and co-counsel re proposed 

settlement term sheet and summary of mediation positions

0.200 75.00

03-14-2018 NN Weekly conference call with B. Whyte and co-counsel from 

WF&G and KTBS re mediation status

0.200 75.00

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Date Timekeeper Description Hours Amount

03-14-2018 NN Read emails and documents sent b y B. Whyte re recent 

developments with mediation

0.200 75.00

03-14-2018 NN Confer with D. Bussel (KTBS) re new developments in mediation 

and strategy

0.300 112.50

03-15-2018 NN Read news report sent by B. Whyte re Fiscal Plan and FOMB 0.100 37.50

03-15-2018 NN Read news report sent by B. Whyte re bill to eliminate SUT for 

certain articles

0.100 37.50

03-15-2018 NN Read news report sent by WF&G re COFINA Creditors 

statement that Tax Report "distorts" SUT collection data

0.100 37.50

03-16-2018 NN Read news report sent by B. Whyte re Government's agreement 

with Amazon for charging SUT

0.100 37.50

03-21-2018 NN Study commentary sent by B. Whyte on PR destabilizing 

decisions

0.200 75.00

03-22-2018 NN Read news report sent by B. Whyte re Puerto Rico's bankruptcy 

impact on the municipal bond world

0.100 37.50

03-22-2018 NN Review TSA and SUT collection tracker and liquidity report sent 

by B. Whyte

0.100 37.50

03-22-2018 NN Correspond with D. Bussel re status of mediation 0.100 37.50

03-22-2018 NN Read news reports sent by B. Whyte re PR Governor's meeting 

with US Treasury Secretary and re revised fiscal turnaround plan 

and allocation to debt service

0.200 75.00

03-22-2018 NN Confer with D. Bussel re new developments in mediation 0.100 37.50

03-23-2018 NN Read various news reports re new Fiscal Plan, US Treasury and 

PR Governor's Agreement and re Cooperative's Complaint 

against FOMB and Commonwealth sent by B. Whyte

0.200 75.00

03-23-2018 NN Correspond with B. Whyte and co-counsels re new development 

with mediation

0.100 37.50

03-23-2018 NN Read news report sent by A. Ambeault (WF&G) re FOMB's 

press release as to Fiscal Plan

0.100 37.50

03-23-2018 NN Review of PR new Fiscal Plan 0.700 262.50

03-28-2018 NN Weekly conference call with B. Whyte and co-counsel 0.400 150.00

03-28-2018 NN Listen to Governor's message re FOMB 0.200 75.00

03-28-2018 NN Draft Memorandum to B. Whyte re Governor's message 0.200 75.00

03-28-2018 NN Correspond with B. Whyte re Governor's message 0.100 37.50

03-28-2018 NN Read report sent by A. Ambeault (WF&G) re FOMB's 

requirements for Fiscal Plans

0.100 37.50

03-28-2018 NN Read FOMB's press release and letter to PR Governor re Fiscal 

Plan

0.200 75.00

Total Fees 4,275.00

Time Summary

Timekeeper Hours Rate Amount

NN 11.400 375.00 4,275.00

Total Fees 4,275.00

L-200 Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

03-01-2018 NN Read news report sent by B. Whyte re our Motion requesting 

Court to certify questions of PR law to PR Supreme Court

0.100 37.50

03-01-2018 NN Revise draft of Motion for Omnibus hearing 0.100 37.50

03-01-2018 NN Correspond with C. Koenig re draft of Motion for Omnibus 

hearing

0.100 37.50

03-01-2018 NN Read Court Order denying COFINA's Agent Motion to set an 0.100 37.50

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Date Timekeeper Description Hours Amount

expedited briefing schedule re Motion to certify and scheduling 

argument for Omnibus hearing

03-01-2018 NN Correspond with B. Wyhte and co-counsel re Court Order as to 

hearing on Motion to certify

0.200 75.00

03-01-2018 NN Review Court dockets in Title III main case and AP against 

COFINA Agent to identify new filings relevant to COFINA Agent

0.300 112.50

03-01-2018 NN Read Informative Motion of the Official Committee of Retired 

Employees re March 7 Omnibus Hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of counsel for PREPA and AAFAF on 

behalf of PREPA for appearance at March 7 Omnibus hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of the Official Committee of Retired 

Employees re participation in the March 7 Omnibus hearing

0.100 37.50

03-01-2018 NN Read further Informative Motion of counsel for PREPA and 

AAFAF on behalf of PREPA for appearance at March 7 Omnibus 

hearing

0.100 37.50

03-01-2018 NN Read Ambac Assurance Corporation's Informative Motion re 

March 7 Omnibus hearing

0.100 37.50

03-01-2018 NN Rad Information Motion of International Union UAW re 

observation of March 7-8, 2018 Omnibus hearing

0.100 37.50

03-01-2018 NN Read Peaje Investments, LLC Informative Motion and Notice of 

Request to be Heard at the March 7 hearing

0.100 37.50

03-01-2018 NN Read FGIC's Informative Motion for Appearance at Omnibus 

hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of Official Committee of Unsecured 

Creditors re Ominbus hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of QTBC Noteholder re Omnibus 

hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of American Federation os State, 

Country and Municipal Employees re Omnibus hearing

0.100 37.50

03-01-2018 NN Read filed COFINA Agent's Informative Motion re Omnibus 

hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of AAFAF re Omnibus hearing 0.100 37.50

03-01-2018 NN Read Notice of correspondence received by the Court and 

review correspondence notified by Court

0.200 75.00

03-01-2018 NN Read United States Trustee's Notice of Request to be heard at 

March 7 hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of American Federation of Teachers re 

Omnibus hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of National Public Finance Guarantee 

Corporation re Omnibus hearing

0.100 37.50

03-01-2018 NN Read Informative Motion of the PBS Funds re Omnibus hearing 0.100 37.50

03-01-2018 NN Read Informative Motion of Fee Examiner's Informative Motion 

re Omnibus hearing

0.100 37.50

03-01-2018 NN Read Notice of Request to be Heard at Omnibus hearing of GO 

Bondholders

0.100 37.50

03-01-2018 NN Read PREPA's Bondholder's Motion re Omnibus hearing 0.100 37.50

03-01-2018 NN Read Mitsubishi's Motion and amended Motion re Omnibus 

hearing

0.100 37.50

03-02-2018 NN Read litigation update sent by WF&G re new developments in 

Title III litigation relevant to COFINA Agent

0.200 75.00

03-02-2018 NN Review Court dockets of main Title III case and AP against 

COFINA Agent to identify new filings relevant to COFINA Agent

0.100 37.50

03-02-2018 NN Read Amended Informative Motion of Official Committee of 

Unsecured Creditors re Omnibus hearing

0.100 37.50

03-02-2018 NN Read Amended Informative Motion re National Public Finance 

Guarantee Corps. appearance at Omnibus hearing

0.100 37.50

03-05-2018 NN Read GO-Bondholders' Notice of filing unredacted versions of 0.100 37.50

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Date Timekeeper Description Hours Amount

documents in support of Motion for Summary Judgment in AP 

against COFINA Agent

03-06-2018 NN Read Order re new dates for Omnibus hearings 0.100 37.50

03-06-2018 NN Read agenda for March 7 hearing 0.300 112.50

03-06-2018 NN Read Commonwealth Agent's notice of filing unredacted version 

of documents

0.100 37.50

03-06-2018 NN Read AAFAF's revised Informative Motion regarding attendance 

at the March 7-8, 2018 Omnibus hearing

0.100 37.50

03-06-2018 NN Read Amended Informative Motion if the Official Committee of 

Retired Employees re participation in Omnibus Hearing

0.100 37.50

03-06-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.100 37.50

03-06-2018 NN Correspond with A. Ambeault to coordinate details for Yanez's 

attendance to April hearing in PR

0.200 75.00

03-07-2018 NN Attend Omnibus hearing at PR USDC 2.800 1,050.00

03-07-2018 NN Correspond with J. Minias (WF&G) re todays hearing 0.100 37.50

03-07-2018 NN Correspond with A. Ambeault (WF&G) re Notice of Filing of 

unredacted version of Declaration and documents in support of 

Motion for Summary Judgment

0.100 37.50

03-07-2018 NN Read as filed COFINA Agent's notice of filing unredacted version 

of documents in AP against COFINA Agent

0.100 37.50

03-07-2018 NN Read as filed COFINA Agent's notice of filing unredacted version 

of documents in AP against COFINA Agent

0.100 37.50

03-07-2018 NN Read Motion of new local counsel appearing on behalf of FOMB 0.100 37.50

03-07-2018 NN Read Order awarding interim allowance of compensation for 

professional services rendered and reimbursement of expenses

0.100 37.50

03-07-2018 NN Read Court Minutes of hearing 0.100 37.50

03-11-2018 NN Read Motion by Commonwealth Agent requesting leave to 

exceed number of pages

0.100 37.50

03-11-2018 NN Read Motion filed by Commonwealth Agent to exceed number of 

pages of Opposition to Motion for Summary Judgment in AP 

against COFINA Agent

0.100 37.50

03-11-2018 NN Read Order granting Commonwealth Agent's Motion to exceed 

number of pages of Opposition to Motion for Summary Judgment 

in AP against COFINA Agent

0.100 37.50

03-13-2018 NN Correspond with S. Hussein re draft of Opposition to Motion for 

Summary Judgment in AP against COFINA Agent

0.100 37.50

03-13-2018 NN Study draft of Opposition to Motion for Summary Judgment in AP 

against COFINA Agent

1.800 675.00

03-13-2018 NN Draft proposed revisions to Opposition to Motion for Summary 

Judgment in AP against COFINA Agent

0.900 337.50

03-13-2018 RR Legal research re Public Law 600 and Public Law 447 for 

Opposition to Motion for Summary Judgment in AP against 

COFINA Agent

1.400 175.00

03-13-2018 RR Read Assured's Objections to the Magistrate Judge's February 

26, 2018 Order

0.100 12.50

03-13-2018 RR Read Ad Hoc Group of GO Bondholers' Limited Joinder as to 

objections of Assured to the Magistrate Judge's February 26, 

2018 Order

0.100 12.50

03-14-2018 NN Correspond with S. Hussein re draft of Opposition to Motion for 

Summary Judgment

0.100 37.50

03-14-2018 NN Study Memorandum of Official Committee of Retirees in 

Opposition of Motions for Summary Judgment of COFINA Agent

0.300 112.50

03-14-2018 NN Correspond with B. Whyte re SUT 0.100 37.50

03-15-2018 NN Read COFINA Agent's response to Statement of Undisputed 

Facts filed by Commonwealth Agent

0.300 112.50

03-15-2018 NN Analyze Omnibus Opposition of GO Bondholders to COFINA 0.400 150.00

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Date Timekeeper Description Hours Amount

Agent's Motion for Summary Judgment

03-15-2018 NN Review Omnibus Opposition Statement of material facts of 

COFINA Senior Bondholders and its exhibits

0.500 187.50

03-15-2018 NN Read National's Joinder to COFINA Agent's Memorandum of 

Law in support of Motion for Summary Judgment

0.100 37.50

03-15-2018 NN Read Mutual Funds Group's and PR Funds' response to GO 

Bondholder's Statement of Undisputed Facts

0.100 37.50

03-15-2018 NN Read Mutual Fund Group's and PR Funds' response to 

Commonwealth Agent's Statement of Undisputed Facts

0.200 75.00

03-15-2018 NN Read Mutual Fund Group's and PR Funds' Objection to Motions 

for Summary Judgment

0.200 75.00

03-15-2018 NN Read Opposing Statement of Undisputed Material Facts of GO 

Bondholders in response to Mutual Fund Group's and PR Funds' 

Statement of Undisputed Facts

0.300 112.50

03-15-2018 NN Analyze Opposing Statement of Undisputed Material Facts of 

GO Bondholders in response to COFINA Agent's Statement of 

Undisputed Facts

0.300 112.50

03-15-2018 NN Read Attmore's Preliminary Expert Report submitted with J. 

Dugan's Declaration on behalf of B. Whyte

0.200 75.00

03-15-2018 NN Review portions of Malloy's deposition submitted with J. Dugan's 

Declaration on behalf of B. Whyte

0.200 75.00

03-15-2018 NN Read Añeses' Declaration and exhibits in support of 

Commonwealth Agent's Opposition to COFINA parties Motion for 

Summary Judgment

0.500 187.50

03-15-2018 NN Review Commonwealth Agent's responses to COFINA Agent's 

COFINA Senior Bondholders and Mutual Funds Group's 

Statement of Undisputed Facts

0.200 75.00

03-15-2018 NN Analyze Commonwealth Agent's Omnibus Opposition to 

COFINA parties' Motions for Summary Judgment

0.700 262.50

03-15-2018 NN Analyze COFINA Senior Bondholders' Omnibus Opposition to 

Motions for Summary Judgment filed by the Commonwealth 

Agent, the GO Bondholders and Retirees Committee

0.600 225.00

03-15-2018 NN Study report sent by WF&G summarizing the multiple Opposition 

to Cross Motions for Summary Judgment filed in the AP against 

the COFINA Agent

0.600 225.00

03-15-2018 NN Read COFINA Agent's response to Statement of Undisputed 

Facts filed by GO Bondholders

0.100 37.50

03-15-2018 NN Review final version as filed of Omnibus Memorandum of 

COFINA Agent to Commonwealth parties' Motion for Summary 

Judgment

0.300 112.50

03-15-2018 NN Read Burke's Declaration in Support of GO Bondholders' 

Omnibus Opposition to Motion for Summary Judgment

0.100 37.50

03-15-2018 NN Read Ambac's Joinder and Opposition to Motion for Summary 

Judgment

0.200 75.00

03-15-2018 NN Brief review of Omnibus Opposing Statement of Undisputed 

Material Facts of the COFINA Senior Bondholders' Coalition

0.100 37.50

03-15-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-19-2018 NN Review draft of the COFINA Agent's Urgent Motion for Extension 

of the page limit for the Omnibus Reply Memorandum in support 

of Motion for Summary Judgment

0.100 37.50

03-19-2018 NN Review draft of proposed Order allowing the COFINA Agent to 

exceed number of pages for Omnibus Reply

0.100 37.50

03-19-2018 NN Correspond with W. O'Brien re draft of Motion for Extension of 

page limit

0.100 37.50

03-19-2018 NN Correspond with A. Ambeault (WF&G) re draft of Motion to 

Exceed number of pages

0.100 37.50

03-19-2018 NN Review Court dockets to identify new filings relevant to COFINA 0.300 112.50

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Date Timekeeper Description Hours Amount

Agent

03-19-2018 NN Read Urgent Motion for Leave to exceed page limit for the 

Omnibus Reply of the Ad Hoc Group of GO Bondholders in 

support of Motion for Summary Judgment

0.100 37.50

03-19-2018 NN Read Urgent Motion for Leave to Exceed page limit for 

Commonwealth Agent's Reply in support of Motion for Summary 

Judgment

0.100 37.50

03-19-2018 NN Review filed COFINA Agent's Urgent Motion for Extension of 

page limit for the Omnibus Reply Memorandum of Law in 

support of Motion for Summary Judgment

0.100 37.50

03-19-2018 NN Read Urgent Motion of the COFINA Senior Bondholders' 

Coalition to exceed the page limit of its Reply

0.100 37.50

03-20-2018 NN Correspond with co-counsel and B. Whyte re draft of Reply to 

Opposition to COFINA Agent's Motion for Summary Judgment

0.500 187.50

03-20-2018 NN Analyze draft of Reply brief to Opposition to COFINA Agent's 

Motion for Summary Judgment

0.900 337.50

03-20-2018 NN Legal research re statutory interpretation to suggest revisions to 

Reply brief to Opposition to COFINA Agent's Motion for 

Summary Judgment

0.800 300.00

03-20-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-20-2018 NN Read Order granting Ad Hoc Group of GO's Motion to exceed 

page limit in Reply

0.100 37.50

03-20-2018 NN Read Order granting COFINA Agent's Motion to exceed page 

limit in Reply

0.100 37.50

03-20-2018 NN Read Order granting COFINA Senior Bondholders' Motion to 

exceed page limit in Reply

0.100 37.50

03-20-2018 NN Read Order granting Commonwealth Agent's Motion to exceed 

page limit in Reply

0.100 37.50

03-21-2018 NN Correspond with co-counsel (WF&G and KTBS) and B. Whyte re 

draft of Reply to Opposition to Motion for Summary Judgment

0.300 112.50

03-21-2018 NN Review revised version of Reply to Opposition to Motion for 

Summary Judgment

0.400 150.00

03-21-2018 NN Correspond with S. Hussein (WF&G) re possible case law from 

Supreme Court of PR to include in Reply

0.200 75.00

03-21-2018 NN Read Urgent Motion of Banco Popular de Puerto Rico to seal 

certain confidential information in AP against COFINA Agent and 

brief review of exhibits

0.300 112.50

03-21-2018 NN Analyze Reply Memorandum of Law of COFINA Senior 

Bondholders Coalition in support of Motion for Summary 

Judgment

0.200 75.00

03-21-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-21-2018 NN Review Reply Statement of Undisputed Material Facts of the 

COFINA Senior Bondholders' Coalition

0.100 37.50

03-21-2018 NN Read reply Memorandum of Intervenor Official Committee of 

Retirees in support of Motions for Summary Judgment

0.100 37.50

03-21-2018 NN Review filed COFINA Agent's Reply Memorandum 0.100 37.50

03-21-2018 NN Read Joinder of National Public Finance Guarantee to the 

COFINA Agent's Omnibus Reply Memorandum

0.100 37.50

03-21-2018 NN Review filed COFINA Agent's Reply to the Commonwealth 

Agent's counter statement of additional undisputed material facts

0.100 37.50

03-21-2018 NN Read Mutual Fund Group and Puerto Rico Funds' Reply in 

support of Summary Judgment

0.100 37.50

03-21-2018 NN Review Mutual Fund's response to Commonwealth Agent's 

counter statement of additional undisputed facts

0.100 37.50

03-21-2018 NN Read Ambac's Joinder to COFINA Agent's Omnibus Reply 0.100 37.50

03-21-2018 NN Analyze Omnibus Reply of the Ad Hoc Group of Go Bondholders 0.300 112.50

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Date Timekeeper Description Hours Amount

in support of Motion for Summary Judgment

03-21-2018 NN Analyze Commonwealth Agent's Omnibus Reply Memorandum 

in support of Motion for Summary Judgment

0.300 112.50

03-21-2018 NN Read Commonwealth Agent's responses to COFINA Senior 

Bondholders' Counter statement

0.100 37.50

03-21-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-22-2018 NN Read report sent by A. Ambeault (WF&G) re Cooperativas 

Complaint against Commonwealth and Oversight Board

0.200 75.00

03-22-2018 NN Read Court Order re BPPR Motion to appeal confidential 

information

0.100 37.50

03-23-2018 NN Review Court docket to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-23-2018 NN Review Commonwealth's Response to Assured's and National's 

Objections to the Magistrate Judge's Order

0.100 37.50

03-23-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-23-2018 NN Review Commonwealth's Response to Assured's and National's 

Objections to the Magistrate Judge's Order

0.100 37.50

03-26-2018 NN Brief review of multiple Interim Fee Applications filed 0.100 37.50

03-26-2018 NN Read Examiner's filed Notice of presentation of Revised 

Stipulated Disclosure Agreement and Protective Order

0.100 37.50

03-26-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.100 37.50

03-26-2018 NN Read Order scheduling briefing of Motion 0.100 37.50

03-27-2018 NN Read Assured's and National's Informative Motion re recent 

authority supporting their objections to the Magistrate Judge's 

Order

0.100 37.50

03-27-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-28-2018 NN Read Urgent Motion by AAFAF for entry of an Order authorizing 

the sealing of bank account numbers

0.100 37.50

03-28-2018 NN Review Court dockets to identify new filings relevant to COFINA 0.100 37.50

03-29-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

03-29-2018 NN Read Informative Motion regarding entities constituting the 

central Government of the Commonwealth

0.100 37.50

03-29-2018 NN Read AAFAF's Urgent Motion for entry of an Order in AP against 

COFINA Agent authorizing the sealing of bank account numbers

0.100 37.50

03-29-2018 NN Read Court Order re April 10 hearing as to Motions for Summary 

Judgment in AP against COFINA Agent

0.100 37.50

Total Fees 10,625.00

Time Summary

Timekeeper Hours Rate Amount

NN 27.800 375.00 10,425.00

RR 1.600 125.00 200.00

Total Fees 10,625.00

Total for this Invoice 25,681.02

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Exhibit B

(Itemized expenses for the period of March 1, 2018 through March 31, 2018)

Date Expense Amount Description

3/5/18 Postage $ 307.16 Federal Express postage fees

3/5/18 Copies $ 21.00 In house copies 

3/6/18 Postage $ 109.48 Federal Express postage fees for No 

Objection Statement

3/7/18 Postage $ 138.88 Federal Express postage fees for No 

Objection Statement

3/18/18 Copies $ 4.50 In house copies

TOTAL $581.02

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EXHIBIT 4-C

TIME AND EXPENSE DETAIL FOR APRIL 2018 FEE STATEMENT

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Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

05-07-2018

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 18043063

Invoice Period: 04-01-2018 - 04-30-2018

RE: Multiple Matters

B-150 Meetings/Creditor Communications

B-160 Fee Application and Retention

B-170 Fee Application Retention and Objections

L-150 Budget

L-160 Mediation

L-200 Litigation/Adversary Proceeding

L-300 Discovery/Facts Analysis

B-150 Meetings/Creditor Communications

Professional Services

Date Timekeeper Description Hours Amount

04-10-2018 NN Confer with local counsel for constituents re oral argument of 

Summary Judgment Motion in AP against COFINA Agent and 

upcoming hearing on certification

0.400 150.00

Total Fees 150.00

Time Summary

Timekeeper Hours Rate Amount

NN 0.400 375.00 150.00

Total Fees 150.00

B-160 Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

04-04-2018 RR Commence preparing March Fee Statement 0.600 75.00

04-04-2018 NN Correspond with Debtor's counsel re failure to pay January Fee 

Statement as required by Court Order

0.300 112.50

04-12-2018 NN Conclude and revise March Fee Statement 1.400 525.00

04-12-2018 NN Correspond with debtor's counsel re failure to pay January and 

February Fee Statement as required by Court Order

0.300 112.50

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Date Timekeeper Description Hours Amount

04-12-2018 NN Correspond with S. Pearson re joint notification of March Fee 

Statement to reduce expenses

0.100 37.50

04-12-2018 RR Prepare March Fee Statement 3.600 450.00

04-24-2018 NN Correspond with J. Spina re payment of Fee Statement 0.200 75.00

04-25-2018 NN Draft email to J. Spina re questions as to global payment 

received

0.200 75.00

Total Fees 1,462.50

Time Summary

Timekeeper Hours Rate Amount

NN 2.500 375.00 937.50

RR 4.200 125.00 525.00

Total Fees 1,462.50

B-170 Fee Application Retention and Objections

Professional Services

Date Timekeeper Description Hours Amount

04-25-2018 NN Revise No Objection Fee Statement 0.300 112.50

04-25-2018 NN Correspond with S. Pearson (WF&G) re joint service of No 

Objection Statement to reduce expenses

0.200 75.00

04-25-2018 RR Prepare no objection statement re March Fee Statement with 

calculation of credit

0.700 87.50

Total Fees 275.00

Time Summary

Timekeeper Hours Rate Amount

NN 0.500 375.00 187.50

RR 0.700 125.00 87.50

Total Fees 275.00

L-150 Budget

Professional Services

Date Timekeeper Description Hours Amount

04-05-2018 NN Read email sent by A. Ambeault (WF&G ) re independent 

investigator's Second Interim Report

0.100 37.50

04-12-2018 RR Assist N. Navarro with calculations for preparation of budget for 

April 2018

1.600 200.00

04-12-2018 NN Correspond with B. Whyte re budget for April 2018 0.100 37.50

04-12-2018 NN Prepare budget for April 2018 0.900 337.50

04-13-2018 NN Read email from B. Whyte approving budget for May 0.100 37.50

04-13-2018 NN Draft email to Fee Examiner sending required estimated budget 

for May

0.100 37.50

Total Fees 687.50

Time Summary

Timekeeper Hours Rate Amount

NN 1.300 375.00 487.50

RR 1.600 125.00 200.00

Total Fees 687.50

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L-160 Mediation

Professional Services

Date Timekeeper Description Hours Amount

04-04-2018 NN Correspond with B. Whyte re PR Senate's Resolution to stop 

FOMB's funding

0.100 37.50

04-05-2018 NN Read report sent by H. Honig (WF&G) re new fiscal plan review 

new fiscal plan

0.300 112.50

04-05-2018 NN Read report sent by A. Ambeault (WF&G) re increase of market 

value of COFINA debt service account

0.100 37.50

04-05-2018 NN Read news report sent by B. Whyte re Governor's statement re 

fiscal plan

0.100 37.50

04-05-2018 NN Read Independent Investigator's Second Interim Report 0.200 75.00

04-06-2018 NN Read news reports sent by B. Whyte re Fiscal Plan and 

government's debt

0.100 37.50

04-06-2018 NN Correspond with B. Whyte and co counsel re new developments 

in mediation

0.200 75.00

04-06-2018 NN Correspond with B. Whyte and co counsel re new developments 

in mediation

0.200 75.00

04-06-2018 NN Read news reports sent by B. Whyte re Fiscal Plan and 

PROMESA

0.200 75.00

04-09-2018 NN Read news reports sent by B. Whyte re economic developments 

in PR relevant to the GO-COFINA dispute

0.200 75.00

04-09-2018 NN Read report sent by A. Ambeault (WF&G) re AAFAF's updated 

bank account report

0.100 37.50

04-11-2018 NN Weekly call with B. Whyte and co-counsel 0.100 37.50

04-13-2018 NN Read news report sent by A. Ambeault (WF&G) re CDL 

Financing term sheet

0.100 37.50

04-16-2018 NN Read report sent by WF&G re lawsuit filed by counsel for 

COFINA Senior Bondholders against PR Government

0.100 37.50

04-17-2018 NN Read news report sent by B. Whyte relevant to COFINA-GO 

dispute

0.200 75.00

04-18-2018 NN Read news report sent by B. Whyte re Commonwealth's 

additional terms to the CDL loan

0.100 37.50

04-18-2018 NN Read news report sent by B. Whyte re changed criteria to 

receive federal loan to PR

0.100 37.50

04-18-2018 NN Read Informative Motion of the Official Committee of Retired 

Employees re Omnibus hearing

0.100 37.50

04-18-2018 NN Read news report sent by B. Whyte re tax reform in PR 0.100 37.50

04-18-2018 NN Read news report sent by B. Whyte re FOMB's requirements for 

Fiscal Plan

0.100 37.50

04-18-2018 NN Read report sent by B. Whyte re Bishop's warning to PR 

Government as to Fiscal Plan

0.100 37.50

04-19-2018 NN Read news reports sent by B. Whyte re Fiscal Plan and FOMB 0.200 75.00

04-19-2018 NN Read report sent by WF&G re FOMB's hearing as to Fiscal Plan 0.100 37.50

04-20-2018 NN Analyze report sent by WF&G re new developments with Fiscal 

Plan

0.200 75.00

04-20-2018 NN Read FOMB's press release re Fiscal Plan 0.100 37.50

04-23-2018 NN Read news report sent by B. Whyte re banks in PR 0.100 37.50

04-23-2018 NN Read news report re statements issued by Carrion (FOMB) re 

Bondholders and pension holders

0.100 37.50

04-25-2018 NN Read news report sent by B. Whyte re AAFAF's Summary of 

bank accounts

0.100 37.50

04-25-2018 NN Read letter from FOMB to House Natural Resources Committee 

re Fiscal Plan

0.100 37.50

04-26-2018 NN Analyze report sent by WF&G re FOMB revised budget timeline 

and forecasts

0.200 75.00

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Date Timekeeper Description Hours Amount

04-26-2018 NN Read news report sent by B. Whyte re Young's new PREPA bill 0.100 37.50

04-27-2018 NN Read news report re FOMB modified calendar to approve budget 0.100 37.50

04-30-2018 NN Read report sent by WF&G re COFINA Senior Bondholder's 

increase in holdings

0.100 37.50

Total Fees 1,650.00

Time Summary

Timekeeper Hours Rate Amount

NN 4.400 375.00 1,650.00

Total Fees 1,650.00

L-200 Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

04-02-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

04-02-2018 NN Read Order scheduling briefing on Motion 0.100 37.50

04-02-2018 NN Read Court Order in AP against COFINA Agent instructing 

parties to file partially unredacted documents

0.100 37.50

04-02-2018 NN Correspond with S. Hussein re new version of Reply to comply 

with redaction Order

0.200 75.00

04-02-2018 NN Review to approve for filing new version of Reply to comply with 

redaction Order

0.200 75.00

04-02-2018 NN Review partially unredacted version of Commonwealth Agent's 

Minibus Opposition to COFINA Parties’ Motions for Summary 

Judgment and exhibits

0.600 225.00

04-02-2018 NN Read Notice of filing of unredacted version of Commonwealth 

Agent's Omnibus Reply Memorandum in support of Motion for 

Summary Judgment

0.100 37.50

04-02-2018 NN Read COFINA Senior Bondholders' Notice of filing of unredacted 

and partially unredacted documents and review documents

0.300 112.50

04-02-2018 NN Read Notice of Mutual Fund's sealed Motion in AP against 

COFINA Agent

0.100 37.50

04-02-2018 NN Read Mutual Fund's Notice of filing of partially unredacted 

version of pleading

0.100 37.50

04-02-2018 NN Review Stipulated Disclosure Agreement and Protective Order 0.200 75.00

04-02-2018 NN Read Assured's and National's Reply Memorandum in further 

support of objections to the Magistrate Judge's Order

0.100 37.50

04-03-2018 NN Read as filed COFINA Agent's Notice of filing unredacted 

version of documents

0.100 37.50

04-03-2018 NN Read Informative Motion of the Official Committee of Retired 

Employees of April 10 hearing in AP against COFINA Agent

0.100 37.50

04-03-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-03-2018 NN Read Ad Hoc Group of GO Bondholders' limited joinder as to 

Assured's Reply

0.100 37.50

04-04-2018 NN Correspond with S. Hussein re draft of Motion for hearing 0.100 37.50

04-04-2018 NN Review and approve for filing the Motion as to April 10 hearing 0.100 37.50

04-04-2018 NN Read email from H. Honig (WF&G) re Ambac's and NPFG's 

objection to Motion to certify questions as to the PR Supreme 

Court

0.100 37.50

04-04-2018 NN Analyze Ambac's and NPFG's objection to COFINA Agent's 

Motion to certify questions to the PR Supreme Court

0.200 75.00

04-04-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

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Date Timekeeper Description Hours Amount

04-04-2018 NN Analyze Order further amending case management procedures 0.300 112.50

04-04-2018 NN Read stipulated Disclosure Agreement and Protective Order 0.100 37.50

04-04-2018 NN Read Urgent Motion for Leave to respond to Assured's Reply 

Memorandum

0.100 37.50

04-05-2018 NN Read Order scheduling briefing 0.100 37.50

04-05-2018 NN Read Order requiring FOMB to confer with parties re April 25 

Omnibus hearing

0.100 37.50

04-05-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-05-2018 NN Read Informative Motion of Commonwealth Agent re April 10, 

2018 Commonwealth-COFINA hearing

0.100 37.50

04-05-2018 NN Read as filed COFINA Agent Motion re April 10 hearing 0.100 37.50

04-05-2018 NN Read Mutual Fund Group's Informative Motion and request to be 

heard at April 10 hearing

0.100 37.50

04-05-2018 NN Read Ambac's Informative Motion re April 10 hearing 0.100 37.50

04-05-2018 NN Read COFINA Senior Bondholders' Informative Motion re 

request to be heard at the April 10 hearing

0.100 37.50

04-06-2018 NN Read the Puerto Rico Funds' Informative Motion regarding April 

10 Commonwealth-COFINA hearing

0.100 37.50

04-06-2018 NN Read Order scheduling briefing 0.100 37.50

04-06-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

04-06-2018 NN Brief review of O&B's Second Interim Fee Application 0.200 75.00

04-06-2018 NN Read the Puerto Rico Fund's Informative Motion re April 10 

Commonwealth-COFINA hearing

0.100 37.50

04-06-2018 NN Read the Ad Hoc Group of GO-Bondholders' Informative Motion 

and request to be heard at the April 10 hearing

0.100 37.50

04-06-2018 NN Read FOMB's Informative Motion re April 10 hearing 0.100 37.50

04-06-2018 NN Read National's Informative Motion re April 10 hearing on 

COFINA Agent Summary Judgment Motion

0.100 37.50

04-09-2018 NN Read for approval the Joint Motion on evidentiary issues 0.200 75.00

04-09-2018 NN Confer with S. Hussein re hearing on Summary Judgment 

Motions

0.100 37.50

04-09-2018 NN Review as filed Joint Motion on evidentiary issues 0.100 37.50

04-09-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

04-09-2018 NN Read response to Reply Memorandum in further support of 

objections of Assured and National to the Magistrate Judge's 

Order

0.200 75.00

04-09-2018 NN Read Motion to Compel in compliance with February 26 Order 

and for entry of Protective Order of Ad Hoc Group of GO 

Bondholders, Ambac, Assured, Mutual Fund and National

0.200 75.00

04-09-2018 NN Brief review of Prosauker's Second Interim Fee Application as 

FOMB's attorney and representative of the varios debtors

0.400 150.00

04-10-2018 NN Attend hearing re Motion for Summary Judgment in AP against 

COFINA Agent

4.700 1,762.50

04-10-2018 NN Read reports sent by WF&G re hearing on Summary Judgment 

Motions

0.100 37.50

04-10-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-10-2018 NN Read Assured's and National's Urgent Motion for Leave to Reply 0.100 37.50

04-11-2018 NN Read report sent by A. Ambeault (WF&G) re various objections 

filed to the COFINA Agent's Motion to certify questions to 

Supreme Court of PR

0.200 75.00

04-11-2018 NN Review Court docket to identify new filings relevant to COFINA 

Agent

0.200 75.00

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Date Timekeeper Description Hours Amount

04-11-2018 NN Read Order scheduling briefs 0.100 37.50

04-11-2018 NN Read FOMB's Informative Motion re April 25 Omnibus hearing 0.100 37.50

04-11-2018 NN Read Order relocating Omnibus hearing 0.100 37.50

04-11-2018 NN Read Order to compel compliance 0.100 37.50

04-11-2018 NN Ananlyze Omnibus objection of the Ad Hoc Group of Go 

Bondholders to Motion to certify questions to the Supreme Court 

of PR

0.200 75.00

04-11-2018 NN Analyze Omnibus Objection of Commonwealth Agent to various 

motions to certify questions of law to the Supreme Court

0.400 150.00

04-11-2018 NN Analyze FOMB's Opposition to Motion of COFINA Agent for 

Order certifying questions to the Supreme Court of PR

0.500 187.50

04-13-2018 NN Analyze Commonwealth Agent's Motion submitting documents in 

AP case against COFINA Agent and documents submitted

0.400 150.00

04-13-2018 NN Correspond with S. Hussein re COFINA Agent's objection to 

Commonwealth Agent's Motion

0.100 37.50

04-13-2018 NN Review for approval COFINA Agent's objection to 

Commonwealth Agent's Motion

0.100 37.50

04-13-2018 NN Correspond with S. Hussein re translation of PR Supreme Court 

case for Reply

0.100 37.50

04-13-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-15-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

04-15-2018 NN Read Order granting second supplemental report and Order 

extending deadlines

0.200 75.00

04-15-2018 NN Read as filed COFINA Agent responses to Commonwealth 

Agent's

0.100 37.50

04-15-2018 NN Read order permitting supplemental briefing of COFINA-GO 

dispute

0.100 37.50

04-15-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

04-15-2018 NN Read Order granting second supplemental report and Order 

extending deadlines

0.200 75.00

04-15-2018 NN Correspond with S. Hussein re Court Order in AP against 

COFINA Agent

0.200 75.00

04-16-2018 NN Confer with S. Hussein re Reply and Opposition to Motion 

submitting new materials

0.200 75.00

04-16-2018 NN Read report sent by WF&G re developments with PROMESA 

litigation

0.100 37.50

04-16-2018 NN Detail study and analysis of supplemental materials submitted by 

Commonwealth re language of PR Constitution for drafting a 

response

1.200 450.00

04-16-2018 NN Legal research regarding prevailing language of the PR 

Constitution

2.300 862.50

04-16-2018 NN Study Puerto Rico case law re discrepancies between English 

and Spanish versions of law

1.300 487.50

04-16-2018 NN Study law review articles re language issue for drafting response 

to Commonwealth Motion

0.800 300.00

04-16-2018 NN Study relevant portions of the Diary of the Constitutional 

Convention as to the English translation and Spanish versions of 

the PR Constitution

1.400 525.00

04-16-2018 NN Draft email to A. Yanez and S. Hussein analyzing issue of 

discrepancy between English and Spanish versions of the PR 

Constitution for response to Commonwealth Motion

0.900 337.50

04-17-2018 RR Obtain relevant pages of Diary of Constitutional Convention of 

PR for translation into English to submit to Court

0.700 87.50

04-17-2018 RR Obtain official translation of Supreme Court case requested by 0.300 37.50

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Date Timekeeper Description Hours Amount

S. Hussein

04-17-2018 NN Select portions of Diary of Constitutional Convention to submit to 

Court in response to Commonwealth Motion

0.800 300.00

04-17-2018 NN Confer with S. Hussein re response to Commonwealth Motion re 

language issue

0.300 112.50

04-17-2018 NN Correspond with S. Hussein re official translation of Supreme 

Court case to submit to Court

0.100 37.50

04-17-2018 NN Correspond with A. Yanez and S. Hussein in response to 

Commonwealth Motion as to language issue

0.500 187.50

04-17-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-17-2018 NN Study draft of Reply to Opposition to Motion for certification of 

questions to Supreme Court of PR

0.600 225.00

04-17-2018 NN Correspond with co-counsel re draft of Reply to Opposition to 

Motion for certification to Supreme Court of PR

0.200 75.00

04-17-2018 NN Read Fee Examiner's Supplemental Report and Informative 

Motion on uncontested fee applications for First Interim Fee 

Compensation

0.100 37.50

04-17-2018 NN Correspond with J. Dugan regarding language issue for the 

objection to the Commonwealth Motion

0.100 37.50

04-18-2018 NN Correspond with S. Hussein re new draft of response of COFINA 

Agent to Commonwealth Motion submitting evidence

0.200 75.00

04-18-2018 NN Revise new draft of response of COFINA Agent to 

Commonwealth's Motion submitting evidence

0.300 112.50

04-18-2018 NN Review translations of the documents to include with the 

response of COFINA Agent to Commonwealth Motion submitting 

evidence

0.200 75.00

04-18-2018 NN Draft email to S. Hussein with comment as to translation of 

Diario de Sesiones

0.200 75.00

04-18-2018 NN Read Omnibus Order allowing Interim Fees 0.100 37.50

04-18-2018 NN Read Ambac's and National's Reply re issue of certification of 

questions to the PR Supreme Court

0.100 37.50

04-18-2018 NN Analyze Reply Memorandum of Law of the COFINA Senior 

Bondholders' Coalition Support of Motion to certify questions

0.400 150.00

04-18-2018 NN Read COFINA Senior Bondholders' Motion to submit exhibits in 

Spanish

0.100 37.50

04-18-2018 NN Read Mutual Fund Group and Puerto Rico Funds' Reply in 

support of Motion to Certify Questions to PR Supreme Court

0.100 37.50

04-18-2018 NN Read update report sent by WF&G re new developments in AP 

proceeding against B. Whyte

0.100 37.50

04-18-2018 NN Read as filed COFINA Agent supplemental brief 0.100 37.50

04-19-2018 NN Correspond with co-counsel re draft of Informative Motion for 

hearing

0.200 75.00

04-19-2018 NN Review for approval the Informative Motion for hearing 0.100 37.50

04-19-2018 NN Read Commonwealth Agent's Motion re Omnibus hearing 0.100 37.50

04-19-2018 NN Read FOMB's Motion re Omnibus hearing 0.100 37.50

04-19-2018 NN Rad Ad Hoc Group of GO Bondholders' Motion re Omnibus 

hearing

0.100 37.50

04-19-2018 NN Read Stipulation filed by Commonwealth 0.100 37.50

04-19-2018 NN Read Ambac's Motion re Omnibus 0.100 37.50

04-20-2018 NN Read AAFAF's Motion re Omnibus hearing 0.100 37.50

04-20-2018 NN Read COFINA Senior Bondholders' Motion re hearing 0.100 37.50

04-20-2018 NN Read FOMB's Motion re hearing 0.100 37.50

04-20-2018 NN Correspond with A. Yanez re certification hearing 0.100 37.50

04-20-2018 NN Read Peaje's Motion re certification hearing 0.100 37.50

04-20-2018 NN Read PR Fund's Motion re certification hearing 0.100 37.50

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Date Timekeeper Description Hours Amount

04-22-2018 NN Correspond with C. Koenig re Urgent Motion to adjourn hearing 0.100 37.50

04-22-2018 NN Review for approval Urgent Motion to adjourn hearing 0.100 37.50

04-22-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-23-2018 NN Read update sent by WF&G re new developments in AP against 

COFINA Agent

0.100 37.50

04-23-2018 NN Read Court Order granting Motion to Adjourn hearing re request 

to certify questions to PR Supreme Court

0.100 37.50

04-23-2018 NN Read update re new developments in litigation sent by WF&G 0.100 37.50

04-23-2018 NN Read Court Order cancelling Omnibus hearing 0.100 37.50

04-23-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-23-2018 NN Read Assured's and National's Joinder to Motion to Compel 0.100 37.50

04-23-2018 NN Read FOMB's response to Motion to Compel 0.100 37.50

04-24-2018 NN Read news report sent by B. Whyte re new lawsuit filed in Title 

III case challenging constitutionality of FOMB

0.100 37.50

04-24-2018 NN Analyze complaint filed against FOMB, USA and PR 

Government challenging constitutionality of FOMB, Fiscal Plan 

and certain bonds

0.800 300.00

04-24-2018 NN Analyze Memorandum Order remanding Government 

challenging constitutionality of FOMB, Fiscal Plans and certain 

bonds

0.200 75.00

04-24-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.300 112.50

04-25-2018 NN Read report sent by WF&G re FOMB's Informative Motion re 

status report

0.100 37.50

04-25-2018 NN Read news report sent by B. Whyte re Judge's recent Order as 

to discovery of drafts of Fiscal Plan

0.100 37.50

04-25-2018 NN Read FOMB's Informative Motion re the case status report 0.100 37.50

04-26-2018 NN Review Court dockets to identify new filings relevant to COFINA 

Agent

0.200 75.00

04-30-2018 NN Read Fifth Supplemental Verified Statement of the COFINA 

Senoir Bondholders' Coalition pursuant to FRBP 2019

0.100 37.50

Total Fees 13,062.50

Time Summary

Timekeeper Hours Rate Amount

NN 34.500 375.00 12,937.50

RR 1.000 125.00 125.00

Total Fees 13,062.50

L-300 Discovery/Facts Analysis

Professional Services

Date Timekeeper Description Hours Amount

04-05-2018 NN Read letter from UBS counsel re production of documents 0.100 37.50

Total Fees 37.50

Time Summary

Timekeeper Hours Rate Amount

NN 0.100 375.00 37.50

Total Fees 37.50

Total for this Invoice 17,325.00

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EXHIBIT 4-D

TIME AND EXPENSE DETAIL FOR MAY 2018 FEE STATEMENT

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Nilda M. Navarro-Cabrer

Navarro-Cabrer Law Offices

500 Muñoz Rivera Ave., El Centro I, Suite 206

San Juan, PR 00918

787.764.9595

www.navarrolawpr.com

Taxpayer ID: 66-0507620

06-08-2018

Bettina Whyte

Bettina Whyte as COFINA Agent

545 West Sagebrush Drive

Jackson, WY 83001

Invoice Number: 18053163

Invoice Period: 05-01-2018 - 05-31-2018

RE: Multiple Matters

B-160 Fee Application and Retention

E-100 Expenses

L-150 Budget

L-160 Mediation

L-200 Litigation/Adversary Proceeding

B-160 Fee Application and Retention

Professional Services

Date Timekeeper Description Hours Amount

05-01-2018 NN Read email from O'Melvany (P. Friedman) re tax reporting of

payments to PROMESA attorneys

0.10 37.50

05-01-2018 NN Confer with J. Casillas re email from O'Melvany (P. Friedman) re

tax reporting of payments to PROMESA Title III attorneys

0.10 37.50

05-04-2018 NN Work on April fee statement 0.40 150.00

05-04-2018 RR Work on April fee statement 0.90 112.50

05-14-2018 NN Correspond with counsel for Commonwealth and KJ Weiss re

unpaid portion of March Fee Statement

0.30 112.50

05-15-2018 NN Read email from S. Pearson re April Fee Statement 0.10 37.50

05-22-2018 NN Analyze letter from Fee Examiner re Second Interim Fee

Application

0.20 75.00

05-24-2018 NN Draft letter in response to Fee Examiner's letter re Second

Interim Fee Application

0.30 112.50

05-30-2018 NN Analyze Fee Examiner's second report on Professional Fees and

Expenses

0.40 150.00

Total Fees 825.00

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Time Summary

Timekeeper Hours Rate Amount

NN 1.90 375.00 712.50

RR 0.90 125.00 112.50

Total Fees 825.00

E-100 Expenses

Expenses

Date Description Price Qty Amount

05-08-2018 Air fare from Puerto Rico to NY for hearing 388.40 1 388.40

05-08-2018 Transportation fee from JFK Airport to Hotel 59.16 1 59.16

05-08-2018 Hotel stay from May 8, 2018 to May 9, 2018 (actual cost $865.28) 500.00 1 500.00

05-08-2018 Meal purchase (lunch) 13.65 1 13.65

05-08-2018 Meal purchase (dinner) 40.00 1 40.00

05-09-2018 Meal purchase (breakfast) 40.00 1 40.00

05-09-2018 Meal purchase (lunch) 40.00 1 40.00

05-09-2018 Transportation fee from Hotel to JFK Airport 75.19 1 75.19

05-09-2018 Air fare from NY to Puerto Rico 232.40 1 232.40

Total Expenses 1,388.80

L-150 Budget

Professional Services

Date Timekeeper Description Hours Amount

05-14-2018 RR Work on estimated budget for June 2018 0.80 100.00

05-14-2018 NN Work on budget for June 2018 0.40 150.00

05-14-2018 NN Correspond with B.Whyte re budget for June 2018 0.10 37.50

Total Fees 287.50

Time Summary

Timekeeper Hours Rate Amount

NN 0.50 375.00 187.50

RR 0.80 125.00 100.00

Total Fees 287.50

L-160 Mediation

Professional Services

Date Timekeeper Description Hours Amount

05-01-2018 NN Correspond with D. Bussel re mediation 0.10 37.50

05-01-2018 NN Confer with D. Bussel re new developments with mediation and

upcoming hearing

0.50 187.50

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Date Timekeeper Description Hours Amount

05-10-2018 NN Read report sent by WF&G re MBIA/National's comments as to

new certified Fiscal Plans

0.10 37.50

05-10-2018 NN Read report sent by WF&G re GO Report re Commonwealth debt 0.10 37.50

05-14-2018 NN Analyze various reports sent by B. Whyte and co-counsel re

Bondholder's offer to settle COFINA-GO dispute and

Commonwealth's response

0.50 187.50

05-14-2018 NN Correspond with co-counsel and B. Whyte re CommonwealthCOFINA Dispute Proposed Settlement and draft of press release

re same

0.30 112.50

05-14-2018 NN Review B. Whyte's draft of press release as to COFINA Agent

response to May 11 Press Release re mediation proposal

0.10 37.50

05-15-2018 NN Correspond with B. Whyte and co-counsel re FOMB's response

to proposed agreement

0.20 75.00

05-16-2018 NN Read analysis re PR Government's liquidity sent by B. Whyte 0.10 37.50

05-16-2018 NN Confer with D. Bussel re new developments with mediation 0.10 37.50

05-16-2018 NN Read report on April Tax haul in PR sent by WF&G 0.10 37.50

05-16-2018 NN Read analysis sent by WF&G re Commonwealth-PROMESA

Board Budget, Fiscal Plan talks

0.10 37.50

05-23-2018 NN Weekly conference call with B. Whyte and co-counsel re status

of mediation and upcoming events

0.30 112.50

05-23-2018 NN Review Assured's Complaint seeking Judgment declaring that

the Revised Fiscal Plan is unlawful and unconstitional

0.30 112.50

Total Fees 1,087.50

Time Summary

Timekeeper Hours Rate Amount

NN 2.90 375.00 1,087.50

Total Fees 1,087.50

L-200 Litigation/Adversary Proceeding

Professional Services

Date Timekeeper Description Hours Amount

05-02-2018 NN Correspond with A. Yanez re certification hearing 0.30 112.50

05-02-2018 NN Review Court Order re certification hearing 0.10 37.50

05-02-2018 NN Read standing Order re bringing electronic devices to the Court

room and form to be completed

0.20 75.00

05-02-2018 NN Correspond with C. Koenig re certification hearing 0.10 37.50

05-04-2018 NN Review to approve for filing Informative Motion re certification

hearing on motions to certify questions to PR Supreme Court

0.10 37.50

05-04-2018 NN Correspond with co-counsel re Informative Motion re certification

hearing

0.10 37.50

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Date Timekeeper Description Hours Amount

05-04-2018 NN Confer with A. Ambeault (WF&G) re Informative Motion re

certification hearing

0.10 37.50

05-04-2018 NN Read Informative Motion of Commonwealth Agent re hearing on

motions to certify questions to PR Supreme Court

0.10 37.50

05-04-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.30 112.50

05-04-2018 NN Read Ambac's Motion in AP against B. Whyte re certification

hearing

0.10 37.50

05-04-2018 NN Read Commonwealth Agent's in Motion in AP against B. Whyte

re certification hearing

0.10 37.50

05-04-2018 NN Read Ad Hoc Group of Go Bondholders' Informative Motion re

hearing

0.10 37.50

05-04-2018 NN Read Informative Motion of the COFINA Senior Bondholders' re

hearing

0.10 37.50

05-04-2018 NN Read the Puerto Rico Funds' Informative Motion re hearing 0.10 37.50

05-04-2018 NN Read Informative Motion of the Official Committee of Retired

Employees re hearing

0.10 37.50

05-04-2018 NN Read Joint Informative Motion submitting status report 0.10 37.50

05-04-2018 NN Correspond with A. Yanez re certification hearing 0.20 75.00

05-04-2018 NN Read Mutual Fund's Informative Motion re certification hearing 0.10 37.50

05-04-2018 NN Read National's Informative Motion re certification hearing 0.10 37.50

05-04-2018 NN Read FOMB's Informative Motion re certification hearing 0.10 37.50

05-07-2018 NN Legal research as to new cases certified to Supreme Court for

certification hearing

0.60 225.00

05-07-2018 NN Review Court docket to identify new filings relevant to COFINA

Agent

0.20 75.00

05-07-2018 NN Commence analyzing relevant briefs in preparation for

certification hearing and for meeting with co-counsel

1.80 675.00

05-07-2018 NN Read amended Motion filed by Commonwealth Agent re

certification hearing

0.10 37.50

05-08-2018 NN Travel from San Juan to New York and preparation for meeting

and hearing: Trip to SJ airport and waiting time in airport

reviewing briefs in preparation for meeting and hearing (2.6 hrs.);

Flight from SJ to NY reviewing case law in preparation of

meeting and hearing and analyzing USDC of PR opinion re

PROMESA in case of Centro de Periodismo Investigativo and

other relevant case law (4 hrs.); Travel from JFK airport to

WF&G for meeting (1.5 hrs)

8.10 3,037.50

05-08-2018 NN Correspond with A. Yanez re meeting in preparation for

certification hearing

0.10 37.50

05-08-2018 NN Meeting with A. Yanez and S. Hussein in preparation for 1.00 375.00

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Date Timekeeper Description Hours Amount

certification hearing

05-08-2018 NN Read Motion of Fee Examiner to amend Fee Examiner's draft

Order

0.20 75.00

05-08-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.10 37.50

05-09-2018 NN Preparation for hearing re certification to Supreme Court of PR 1.40 525.00

05-09-2018 NN Appear at hearing re certification to PR Supreme Court 1.50 562.50

05-09-2018 NN Confer with K. Klee re hearing and strategy 0.90 337.50

05-09-2018 NN Weekly conference call with B. Whyte and co-counsel re hearing

and strategy

0.30 112.50

05-09-2018 NN Travel from NY to SJ: Trip to NYC to JFK (rush hour 1.7 hrs.);

Waiting time in airport, flight delayed (3.6 hrs.); Flight to SJ (4.1

hrs.)

9.70 3,637.50

05-09-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.20 75.00

05-10-2018 NN Study report sent by WF&G re certification hearing 0.20 75.00

05-10-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.10 37.50

05-11-2018 NN Read GO's Motion re May 21 hearing 0.10 37.50

05-11-2018 NN Read Notice of correspondence received by the court 0.10 37.50

05-11-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.10 37.50

05-14-2018 NN Correspond with S. Hussein re translation of court cases to

submit to court

0.20 75.00

05-14-2018 NN Review translated opinion sent by S. Hussein to respond to

email re same

0.10 37.50

05-14-2018 NN Read Ambac's Informative Motion re May 21 hearing 0.10 37.50

05-14-2018 NN Read Informative Motion re National's appearance at May 21

hearing

0.10 37.50

05-14-2018 NN Read Informative Motion of Official Committee of Unsecured

Creditors re May 21 hearing

0.10 37.50

05-14-2018 NN Read Mutual Fund's Motion re May 21 hearing 0.10 37.50

05-14-2018 NN Read Informative Motion of the Ad Hoc Group of PREPA

Bondholders re May 21 hearing

0.10 37.50

05-14-2018 NN Read PREPA's Informative Motion re hearing 0.10 37.50

05-14-2018 NN Read Assured's Informative Motion re hearing 0.10 37.50

05-14-2018 NN Read FOMB's Informative Motion re hearing 0.10 37.50

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Date Timekeeper Description Hours Amount

05-14-2018 NN Read AAFAF's Informative Motion re hearing 0.10 37.50

05-14-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.30 112.50

05-14-2018 NN Read Reply in further support of Joinder to Motion to compel

compliance with Order

0.20 75.00

05-14-2018 NN Review Joint Report in response to the Court's Order 0.10 37.50

05-15-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.20 75.00

05-15-2018 NN Read Judge Dein's order 0.10 37.50

05-15-2018 NN Review Motion of Creditors' Committee for Order under

authorizing discovery with respect to causes of Puerto Rico

Financial crisis

0.20 75.00

05-16-2018 NN Analyze update sent by WF&G re UCC Motion seeking to

intervene in Cooperativas lawsuit against Commonwealth and

FOMB

0.20 75.00

05-16-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.20 75.00

05-16-2018 NN Read Order referring matters to Judge Dein 0.10 37.50

05-17-2018 NN Read Court Order re Omnibus hearing 0.10 37.50

05-17-2018 NN Analyze Motion by AFL-CIO (AFSCME) to Compel compliance

with the August 10, 2017 Stipulation and propose Order

0.20 75.00

05-17-2018 NN Correspond with D. Bussel re AFL-CIO Motion to Compel 0.10 37.50

05-17-2018 NN Read report sent by WF&G re AFSCME's Motion to Compel 0.10 37.50

05-17-2018 NN Read Fourth Supplemental Joint Status Report re Joint Motion

for entry of an Order authorizing discovery

0.10 37.50

05-17-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.30 112.50

05-17-2018 NN Read Urgent Motion for extension of deadlines in connections

with the Fourth Amended Notice, Case Management and

Administrative Procedures

0.10 37.50

05-18-2018 NN Read draft of letter to S. Levine re draft response to the AFl-CIO

Motion

0.10 37.50

05-18-2018 NN Review and approve for filing draft of response to the AFL-CIO

Motion

0.10 37.50

05-18-2018 NN Correspond with co-counsel and B .Whyte re letter to S. Levine

and draft of response to the AFL-CIO Motion

0.50 187.50

05-18-2018 NN Review and approve for filing Motion submitting translation 0.10 37.50

05-18-2018 NN Correspond with C. Koenig re Motion submitting translation 0.10 37.50

05-18-2018 NN Read final version as filed of B. Whyte's response to AFL-CIO

Motion

0.10 37.50

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Date Timekeeper Description Hours Amount

05-18-2018 NN Read report sent by WF&G re COFINA Agent's Motion 0.10 37.50

05-19-2018 NN Read FOMB's response to Motion of AFSCME to compel

compliance with the August 10, 2017 Stipulation and Order

0.10 37.50

05-19-2018 NN Correspond with co-counsel and B. Whyte re FOMB's response

to Motion of AFSCME to compel compliance

0.10 37.50

05-19-2018 NN Read as filed Joint Informative Motion submitting official

translations

0.10 37.50

05-19-2018 NN Read order granting Urgent Motion for extension of deadlines in

connection with the Fourth Amended Notice, Case Management

and Administrative procedures

0.10 37.50

05-21-2018 NN Read report sent by WF&G re FOMB's response to Motion 0.10 37.50

05-21-2018 NN Read Order setting briefing schedule for Motion to Compel 0.10 37.50

05-21-2018 NN Correspond with co-counsel re Order setting briefing schedule

for Motion to Compel

0.20 75.00

05-21-2018 NN Read Order granting Urgent Motion for extension of deadlines 0.10 37.50

05-21-2018 NN Read statement of Official Committee of Unsecured Creditors re

representation of PREPA Retirees

0.10 37.50

05-22-2018 NN Read FOMB's response to Motion of Official Committee of

Retired Employees re representation of PREPA Retirees

0.10 37.50

05-22-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.20 75.00

05-22-2018 NN Read response to Creditor's Committee Motion seeking entry of

Order authorizing discovery

0.10 37.50

05-22-2018 NN Read Judge Dein's discovery Orders 0.10 37.50

05-22-2018 NN Read Certification re Revised Proposed First Amended Fee

Examiner Order with revised proposed Order

0.10 37.50

05-22-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.30 112.50

05-22-2018 NN Read response of AAFAF to Motion of AFL-CIO to compel

compliance with Stipulation and Order

0.10 37.50

05-23-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.30 112.50

05-23-2018 NN Read response of AAFAF to Motion of AFL-CIO to compel

compliance with stipulation and Order

0.10 37.50

05-23-2018 NN Read Order rescheduling briefing 0.10 37.50

05-23-2018 NN Analyze Urgent Motion under Case Management Order 0.20 75.00

05-23-2018 NN Analyze Joint Motion entry for and Order further amending

interim compensation with proposed order

0.10 37.50

05-24-2018 NN Read Statement of Official Committee of Unsecured Creditors in 0.10 37.50

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Date Timekeeper Description Hours Amount

response to Motion by AFL-CIO to compel compliance

stipulation and Order

05-24-2018 NN Revise for approval for filing draft of objection of the COFINA

Agent to AFSCME's Motion to Compel compliance with

stipulation

0.10 37.50

05-24-2018 NN Correspond with co-counsel and B. Whyte re draft of objection fo

the COFINA Agent to AFSCME's Motion to Compel compliance

with stipulation

0.30 112.50

05-24-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.20 75.00

05-24-2018 NN Read Order granting the Urgent Joint Motion under case

management procedures

0.10 37.50

05-24-2018 NN Read Minutes of proceedings before Judge Dein 0.10 37.50

05-24-2018 NN Read as filed Objection of the COFINA Agent to Motion by AFLCIO to compel0.10 37.50

05-24-2018 NN Read report sent by WF&G re Court Order denying certification

to PR Supreme Court

0.10 37.50

05-24-2018 NN Analyze Court Memorandum Order denying certification PR

Supreme Court

0.30 112.50

05-24-2018 NN Read Assured's response to Motion to Compel compliance with

stipulation and Order

0.10 37.50

05-24-2018 NN Read response of the Ad Hoc Group of GO Bondholders to the

Motion to Compel compliance with stipulation and Order

0.10 37.50

05-24-2018 NN Correspond with co-counsel and B. Whyte re multiple responses

to the AFL-CIO Motion to Compel

0.20 75.00

05-29-2018 NN Correspond with B. Whyte and co-counsel re Omnibus hearing

to be held in PR

0.30 112.50

05-29-2018 NN Review Court dockets to identify new filings relevant to COFINA

Agent

0.30 112.50

05-29-2018 NN Analyze Reply in support of AFSCME's Motion to Compel

compliance with the stipulation and Order

0.20 75.00

05-29-2018 NN Read order extending deadlines 0.10 37.50

05-30-2018 NN Read report sent by WF&G re Motion filed by AAFAF 0.10 37.50

05-30-2018 NN Read for approval for filing draft of Motion for hearing 0.10 37.50

05-30-2018 NN Correspond with co-counsel draft of Motion for hearing 0.10 37.50

05-30-2018 NN Read report sent by WF&G re Court Order denying Motion to

Compel Compliance with Stipulation Governing CommonwealthCOFINA Dispute

0.10 37.50

05-30-2018 NN Read Order denying Motion to Compel Compliance with

Stipulation Governing Commonwealth-COFINA Dispute

0.10 37.50

05-30-2018 NN Review Court dockets to identify new filings relevant to COFINA 0.20 75.00

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Date Timekeeper Description Hours Amount

Agent

05-30-2018 NN Read Informative Motion of Official Committee of Retired

Employees re Omnibus hearing

0.10 37.50

05-30-2018 NN Read Order denying AFSCME Motion to Compel 0.10 37.50

05-30-2018 NN Read Informative Motion of Financial Guaranty Insurance

Company re Omnibus hearing

0.10 37.50

05-31-2018 NN Read GO Informative Motion re Omnibus hearing 0.10 37.50

05-31-2018 NN Read Ambac's Informative Motion re Omnibus hearing 0.10 37.50

Total Fees 15,375.00

Time Summary

Timekeeper Hours Rate Amount

NN 41.00 375.00 15,375.00

Total Fees 15,375.00

Total for this Invoice 18,963.80

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Exhibit B 

(Itemized expenses for the period of May 1, 2018 through May 31, 2018) 

Date Expense Amount Description

5/8/18 Out of town travel $ 388.40 Air fare from Puerto Rico to New York

5/8/18 Transportation $ 59.16 Transportation fee from New York airport to 

Hotel

5/8/18 Hotel $ 500.00 Hotel stay from May 8, 2018 to May 9, 2018

5/8/18 Meal $ 13.65 Meal purchase (lunch)

5/8/18 Meal $ 40.00 Meal purchase (dinner)

5/9/18 Meal $ 40.00 Meal purchase (breakfast)

5/9/18 Meal $ 40.00 Meal purchase (lunch)

5/9/18 Transportation $ 75.19 Transportation fee from Hotel to New York 

airport

5/8/18 Out of town travel $ 232.40 Air fare from New York to Puerto Rico

TOTAL $ 1388.80

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Download to calendar

Your flights

San Juan, PR (SJU)

Tue May 8 2018, 10:34 AM

New York-Kennedy, NY (JFK)

Tue May 8 2018, 2:30 PM

Flight 1404

JetBlue

Fare: Blue Refundable

Nonstop 

A321 

Fare breakdown

Passenger Type Base Fare

per person

Taxes & fees

per person

Total Fare

per person

Number of

travelers

Total Fare

Adult $360.00 $28.40 $388.40 x 1 $388.40 USD

Total fare: $388.40 USD

Extras

Total Extras: $55.00 USD

Itinerary confirmation

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Confirmation code: PFRJHZ MANAGE BOOKING

SJU JFK

2D

Travelers

Flight Ticket number 2792100163253

Frequent Flyer JetBlue - TrueBlue - 2115989395

Seat

Checked bags included 0 bags

Mrs. Nilda M Navarro 

SJU - JFK: Blue Refundable details

Seats

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Not charged in invoice

-------------

Case:17-03283-LTS Doc#:3545 Filed:07/16/18 Entered:07/16/18 16:31:25 Desc: Main

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Charged to American Express ending in 1001 $443.40 USD

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complimentary on these routes.

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JetBlue Cardmembers only. You may be permitted to have more than one JetBlue Card account; however, you are only eligible to earn one welcome bonus. Bonus ID 3530.

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Economy pricing may not be available at all times, during the day or during certain weather conditions. Advertised rates only apply or bookings made online at limos.jetblue.com or by calling 

1-888-478-8190.

6. If you find the same hotel and dates of stay at a lower rate, Hotels.com will, at its choice, either match the lower rate or cancel the reservation without a cancellation fee. See

http://hotels.jetblue.com/index.jsp?pageName=guarantee.

7. Hotels.com does not charge a change or cancel fee; but each property has independent penalties for changes/cancellations. See hotel details.

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Notice of Increased Government Tax or Fee

JetBlue reserves the right to collect additional payment after a fare has been paid in full and tickets issued for any additional government taxes or fees assessed or imposed. 

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Your booking is complete. Payment will be taken by this hotel as per the details of the booking.

Your Hotels.com confirmation number: 8144172446801. Thank you for booking with Hotels.com

Summary & Room Charges

* Please note: Room preferences and Special requests cannot be guaranteed. Special requests are subject to availability upon check-in and may incur additional charges.

Payment Information

Checking in:

Extra-person charges may apply and vary depending on property policy. 

Government-issued photo identification and a credit card or cash deposit are required at check-in for incidental charges. 

Special requests are subject to availability upon check-in and may incur additional charges. Special requests cannot be guaranteed. 

• The name on the credit card used at check-in to pay for incidentals must be the primary name on the guestroom reservation. 

Please note that cultural norms and guest policies may differ by country and by property. The policies listed are provided by the property.

Booking details

The London NYC 

151 W 54th St

New York, NY

10019

US

+12123075000

Check in:

Check out:

Duration:

Room type:

Total rooms:

Tuesday, May 8, 2018

Wednesday, May 9, 2018

1 night

London Suite One King Bed

1

FREE WIFI

Room 1

Number of nights:

Number of guests: 

Preferences*: 

London Suite One King Bed 

1 night

Nilda Navarro , 1 adult 

Non Smoking, King Bed 

Make changes to room reservation.

Cancel this room

$0.00

$865.28

Service fees: 

Price per room per night: 

You won’t be charged until you check in or check out of the hotel

Billing Name:

Card type:

Card number:

Billing address:

Nilda Navarro

AmericanExpress

XXXXXXXXXXX1001

00926

US

Additional hotel information

Book online or call

866-593-0039 

Amount charged in invoice $500.00

--------

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EXHIBIT 5

COMPARABLE COMPENSATION DISCLOSURES

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Category of Timekeeper

(Using categories already 

maintained by the Firm)

Blended Hourly Rate

Billed*

Firm for Preceding Year

Billed 

In this Application

Partners $275.00 $375.00

Counsel/Associates $240.00 $250.00

Paralegal $125.00 $125.00

Aggregated $265.00 $337.36

*The stated blended rate reflects actual rates charged by Navarro-Cabrer during 2017 on matters that are 

not comparable to the Title III cases in terms of their demands, complexity and importance. The hourly 

rates of Navarro-Cabrer in the Title III Cases are commensurate with the complexity, importance, and 

nature of the problems, issues, and tasks addressed in these cases, and with the demands imposed by the 

expedited nature and extraordinary environment—legal and practical—of these proceedings. NavarroCabrer’s hourly rates in this matter are comparable to the hourly rates charged in the Title III Cases by 

comparably-skilled local counsel and substantially lower than those fees charged in the competitive 

national legal market. In addition, the small size of Navarro-Cabrer Law Offices guarantees efficiency 

and precludes duplication of effort or overlapping billing by multiple attorneys. 

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EXHIBIT 6

BUDGET AND STAFFING PLAN

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Nilda M. Navarro-Cabrer

d/b/a Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from February 1, 2018 through and including February 28, 2018

This Budget and Staffing Plan is an estimate based on currently available information. The amount of 

Navarro-Cabrer’s actual fees may vary materially from the Budget based on future developments and 

tasks delegated to Navarro-Cabrer by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent

Budget 

Project Category Budgeted Hours Budgeted Fees

0001 – Litigation/Adversary Proceedings 60.00 $20,000.00

0002 – Case Administration 0 -

0003 – Meetings/Creditor Communications 5.00 $1,875.00

0004 – Mediation/Negotiations 20.00 $7,500.00

0005 – Fee Application and Retention 4.00 $1,000.00

0006 – Fee Application and Retention Objections 3.00 $625.00

0007 – Budget 3.00 $625.00

0008 – Discovery/Fact Analysis 30.00 $8,750.00

0009 – Non-Working Travel 0.00 -

Total: 125 $40,375.00

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

Total: 2

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Nilda M. Navarro-Cabrer

d/b/a Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from March 1, 2018 through and including March 31, 2018

This Budget and Staffing Plan is an estimate based on currently available information. The amount of 

Navarro-Cabrer’s actual fees may vary materially from the Budget based on future developments and 

tasks delegated to Navarro-Cabrer by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent

Budget 

Project Category Budgeted Hours Budgeted Fees

L-200 Litigation/Adversary Proceedings 60.00 $20,000.00

L-100 Case Administration 0 -

B-150 Meetings/Creditor Communications 5.00 $1,875.00

L-160 Mediation/Negotiations 15.00 $5,625.00

B-160 Fee Application and Retention

(including preparation of Interim Fee Application)

20.00 $6,250.00

B-170 Fee Application and Retention Objections 3.00 $625.00

L-150 Budget 3.00 $625.00

L-300 Discovery/Fact Analysis 15.00 $4,956.00

Total: 121 $39,956.00

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

Total: 2

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Nilda M. Navarro-Cabrer

d/b/a Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from April 1, 2018 through April 30, 2018

This Budget and Staffing Plan is an estimate based on currently available information. The amount of 

Navarro-Cabrer’s actual fees may vary materially from the Budget based on future developments and 

tasks delegated to Navarro-Cabrer by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent

Budget 

Project Category Budgeted Hours Budgeted Fees

L200 – Litigation/Adversary Proceedings 90.00 $31,250.00

B150– Meetings/Creditor Communications 5.00 $1,875.00

L160– Mediation/Negotiations 15.00 $5,625.00

B160 – Fee Application and Retention 7.00 $1,625.00

B170 – Fee Application and Retention Objections 3.00 $625.00

L150 – Budget 3.00 $625.00

L300 – Discovery/Fact Analysis 5.00 $1,875.00

Total: 128 $43,500.00

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

Total: 2

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The Commonwealth of Puerto Rico, et al., Case No. 17 BK 3283-LTS 

Budget and Staffing Plan for Nilda M. Navarro-Cabrer

d/b/a Navarro-Cabrer Law Offices, 

Local Counsel for the COFINA Agent

For the Period from May 1, 2018 through May 31, 2018

This Budget and Staffing Plan is an estimate based on currently available information. The amount of 

Navarro-Cabrer’s actual fees may vary materially from the Budget based on future developments and 

tasks delegated to Navarro-Cabrer by the lead counsel and the special municipal bankruptcy counsel to 

the COFINA Agent

Budget 

Project Category Budgeted Hours Budgeted Fees

L200 – Litigation/Adversary Proceedings 75.00 $26,875.00

B150– Meetings/Creditor Communications 3.00 $1,125.00

L160– Mediation/Negotiations 15.00 $5,625.00

B160 – Fee Application and Retention 5.00 $1,250.00

B170 – Fee Application and Retention Objections 3.00 $625.00

L150 – Budget 3.00 $625.00

Total: 104 $36,125.00

Staffing Plan

Category of Timekeeper

Number of Primary 

Timekeepers 

Expected to Work on 

the Matter During 

the Budget Period

Average Hourly 

Rate

Partners 1 $375.00

Counsel/Associates 0 N/A

Paralegals 1 $125.00

Law Clerk 0 N/A

Total: 2

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EXHIBIT 7

ENGAGEMENT LETTER

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