EXHIBIT C

BUDGET AND STAFFING PLAN

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 1 of 13
1

EXHIBIT C-1

BUDGET

Period Covered: February 1, 2023 through February 28, 2023

1

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

B110 Case Administration 10

B112 General Creditor Inquiries 0

B113 Pleadings Review 80

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay / Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 15

B155 Court Hearings 25

B160 Employment / Fee Applications 5

B161 Budgeting (Case) 3

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions 0

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 45

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, 

and handling of adversary proceedings)

77

B195 Non-Working Travel24

1 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will require discovery 

and trial preparation; and (iv) all adversary proceedings in which the Committee has intervened and/or sought to 

intervene will only involve briefing and hearings on motions to dismiss. In addition, it is impossible to predict how 

many hours will be required to prosecute the Committee’s anticipated challenge to certain GO bond claims, including 

because it is impossible to predict the number and extent of objections filed in response thereto. Thus, this proposed 

budget may be materially different from the work actually performed. For instance, discovery disputes may lead to 

extensive litigation. Similarly, the Committee may need to respond to motions that are not and cannot be anticipated. 

At this time, the proposed budget is speculative. 

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

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 2 of 13
2

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations (including Renewed Rule 2004) 0

B310 Claims Administration and Objections 5

B320 Plan and Disclosure Statement 25

B420 Restructurings 10

TOTAL HOURS 306

TOTAL ESTIMATED FEE $78,0303

3 The Total Estimated Fees are calculated based on a $255 blended hourly rate for the CST Law attorneys who are 

expected to work on this matter during the period from February 1, 2023 through February 28, 2023.

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 3 of 13
3

Period Covered: March 1, 2023 through March 31, 20234

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

B110 Case Administration 10

B112 General Creditor Inquiries 0

B113 Pleadings Review 70

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay / Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 10

B155 Court Hearings 10

B160 Employment / Fee Applications 18

B161 Budgeting (Case) 2

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions 0

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 35

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, and 

handling of adversary proceedings) 65

B195 Non-Working Travel5

5

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

4 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will require discovery 

and trial preparation; and (iv) all adversary proceedings in which the Committee has intervened and/or sought to 

intervene will only involve briefing and hearings on motions to dismiss. In addition, it is impossible to predict how 

many hours will be required to prosecute the Committee’s anticipated challenge to certain GO bond claims, including 

because it is impossible to predict the number and extent of objections filed in response thereto. Thus, this proposed 

budget may be materially different from the work actually performed. For instance, discovery disputes may lead to 

extensive litigation. Similarly, the Committee may need to respond to motions that are not and cannot be anticipated. 

At this time, the proposed budget is speculative. 

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

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 4 of 13
4

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations 0

B310 Claims Administration and Objections 10

B320 Plan and Disclosure Statement 40

B420 Restructurings 10

TOTAL HOURS 287

TOTAL ESTIMATED FEE $73,1856

6 The Total Estimated Fees are calculated based on a $255 blended hourly rate for the CST Law attorneys who are 

expected to work on this matter during the period from March 1, 2023 through March 31, 2023.

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 5 of 13
5

Period Covered: April 1, 2023 through April 30, 20237

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

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 65

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay / Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 10

B155 Court Hearings 20

B160 Employment / Fee Applications 3

B161 Budgeting (Case) 2

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions 0

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 35

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, and 

handling of adversary proceedings) 65

B195 Non-Working Travel8

5

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

7 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) the Commonwealth-COFINA litigation is the only adversary proceeding that will require discovery 

and trial preparation; and (iv) all adversary proceedings in which the Committee has intervened and/or sought to 

intervene will only involve briefing and hearings on motions to dismiss. In addition, it is impossible to predict how 

many hours will be required to prosecute the Committee’s anticipated challenge to certain GO bond claims, including 

because it is impossible to predict the number and extent of objections filed in response thereto. Thus, this proposed 

budget may be materially different from the work actually performed. For instance, discovery disputes may lead to 

extensive litigation. Similarly, the Committee may need to respond to motions that are not and cannot be anticipated. 

At this time, the proposed budget is speculative. 

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

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 6 of 13
6

B230 Financing / Cash Collections 0

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations (including Renewed Rule 2004) 0

B310 Claims Administration and Objections 10

B320 Plan and Disclosure Statement 48

B420 Restructurings 10

TOTAL HOURS 280

TOTAL ESTIMATED FEE $71,4009

9 The Total Estimated Fees are calculated based on a $255 blended hourly rate for the CST Law attorneys who are 

expected to work on this matter during the period from April 1, 2023 through April 30, 2023.

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 7 of 13
7

Period Covered: May 1, 2023 through May 31, 202310

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

B110 Case Administration 5

B112 General Creditor Inquiries 0

B113 Pleadings Review 65

B120 Asset Analysis and Recovery 0

B130 Asset Disposition 0

B140 Relief from Stay / Adequate Protection Proceedings 0

B150 Meetings of Creditors’ Committee and Communications with 

Creditors 10

B155 Court Hearings 20

B160 Employment / Fee Applications 3

B161 Budgeting (Case) 2

B165 Fee and Employment Applications of Other Professionals 0

B170 Fee and Employment Objections 2

B180 Avoidance Actions 0

B185 Assumption / Rejection of Leases and Contracts 0

B190 Other Contested Matters 35

B191 General Litigation (including litigations re: Commonwealth GO 

bonds, PBA bonds, ERS bonds, HTA bonds, mediation process, and 

handling of adversary proceedings) 75

B195 Non-Working Travel11 5

B210 Debtors’ Financial Information and Operations/Fiscal Plan 0

B220 Employee Benefits/Pensions 0

B230 Financing / Cash Collections 0

10 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all adversary 

proceedings in which the Committee has intervened and/or sought to intervene will only involve briefing and hearings 

on motions to dismiss. In addition, it is impossible to predict how many hours will be required to prosecute the 

Committee’s challenges to certain GO and ERS bond claims, including because it is impossible to predict the number 

and extent of objections filed in response thereto. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee 

may need to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is speculative.

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

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 8 of 13
8

B231 Security Document Analysis 0

B260 Meetings of and Communications with Debtors/Oversight Board 

and its Special Claims Committee 0

B261 Investigations (including Renewed Rule 2004) 0

B310 Claims Administration and Objections 10

B320 Plan and Disclosure Statement 50

B420 Restructurings 10

TOTAL HOURS 292

TOTAL ESTIMATED FEE $74,46012

12 The Total Estimated Fees are calculated based on a $255 blended hourly rate for the CST Law attorneys who are 

expected to work on this matter during the period from May 1, 2023 through May 31, 2023.

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 9 of 13
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EXHIBIT C-2

STAFFING PLAN

Period Covered: February 1, 2023 through February 28, 202313

Category of timekeeper

(using categories 

maintained by the firm)

Number of timekeepers 

expected to work on the 

matter during the 

budget period

Average hourly rate

Partner 3 $270

Member 2 $270

Counsel 2 $260

Junior Partner 4 $240

Senior Associate 1 $200

Associate 1 $170

Paraprofessionals 1 $95

13 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all adversary 

proceedings in which the Committee has intervened and/or sought to intervene will only involve briefing and hearings 

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee 

may need to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is speculative. 

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 10 of 13
10

Period Covered: March 1, 2023 through March 31, 202314

Category of timekeeper

(using categories 

maintained by the firm)

Number of timekeepers 

expected to work on the 

matter during the 

budget period

Average hourly rate

Partner 3 $270

Member 2 $270

Counsel 2 $260

Junior Partner 4 $240

Senior Associate 1 $200

Associate 1 $170

Paraprofessionals 1 $95

14 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all adversary 

proceedings in which the Committee has intervened and/or sought to intervene will only involve briefing and hearings 

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee 

may need to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is speculative. 

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 11 of 13
11

Period Covered: April 1, 2023 through April 30, 2023

15

Category of timekeeper

(using categories 

maintained by the firm)

Number of timekeepers 

expected to work on the 

matter during the 

budget period

Average hourly rate

Partner 3 $270

Member 2 $270

Counsel 2 $260

Junior Partner 4 $240

Senior Associate 1 $200

Associate 1 $170

Paraprofessionals 1 $95

15 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all adversary 

proceedings in which the Committee has intervened and/or sought to intervene will only involve briefing and hearings 

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee 

may need to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is speculative. 

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 12 of 13
12

Period Covered: May 1, 2023 through May 31, 2023

16

Category of timekeeper

(using categories 

maintained by the firm)

Number of timekeepers 

expected to work on the 

matter during the 

budget period

Average hourly rate

Partner 3 $270

Member 2 $270

Counsel 2 $260

Junior Partner 4 $240

Senior Associate 1 $200

Associate 2 $170

Paraprofessionals 1 $95

16 The proposed budget set forth herein is based on the following assumptions: (i) no additional title III cases or 

adversary proceedings will be commenced during the budget period; (ii) no plan of adjustment will be filed during the 

budget period; (iii) no adversary proceedings will require discovery and trial preparation; and (iv) all adversary 

proceedings in which the Committee has intervened and/or sought to intervene will only involve briefing and hearings 

on motions to dismiss and/or pretrial proceedings. Thus, this proposed budget may be materially different from the 

work actually performed. For instance, discovery disputes may lead to extensive litigation. Similarly, the Committee 

may need to respond to motions that are not and cannot be anticipated. At this time, the proposed budget is speculative. 

Case:17-03283-LTS Doc#:24754-5 Filed:07/14/23 Entered:07/14/23 19:53:36 Desc:

Exhibit C Page 13 of 13