EXHIBIT C

BUDGET AND STAFFING PLAN

Case:17-03283-LTS Doc#:2735-5 Filed:03/19/18 Entered:03/19/18 18:13:44 Desc:

Exhibit C Page 1 of 4
EXHIBIT C-1

BUDGET 

Period Covered: January 1, 2018 through January 31, 2018

1

 

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

Period January 1,

2018 through 

January 31, 2018

B110 Case Administration 350

B112 General Creditor Inquiries 5

B113 Pleadings Review 130

B120 Asset Analysis and Recovery 5

B140 Relief from Stay / Adequate Protection Proceedings 5

B150 Meetings of Creditors’ Committee and 

Communications with Creditors 125

B155 Court Hearings (including Preparation for Court 

Hearings) 50

B160 Employment / Fee Applications (Paul Hastings and 

Other Professionals) 40

B161 Budgeting (Case) 5

B180 Avoidance Action Analysis 25

B185 Assumption / Rejection of Leases and Contracts 10

B190 Other Contested Matters 135

B191 General Litigation 1,250

B195 Non-Working Travel2

10

 

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. Thus, this proposed budget may be materially different 

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

At this time, the proposed budget is speculative, including, without limitation, because the full impact 

of Hurricane Maria on the Puerto Rico economy and the title III cases remains uncertain at this time. 

Case:17-03283-LTS Doc#:2735-5 Filed:03/19/18 Entered:03/19/18 18:13:44 Desc:

Exhibit C Page 2 of 4
-2-

B210 Debtors’ Financial Information and Operations/Fiscal

Plan 50

B220 Employee Benefits / Pensions 5

B230 Financing / Cash Collections 10

B231 Security Document Analysis 40

B260 Meetings of and Communications with 

Debtors/Oversight Board 25

B261 Investigations 125

B310 Claims Administration and Objections 25

B320 Plan and Disclosure Statement 50

TOTAL HOURS 2,470

TOTAL ESTIMATED FEES $2,237,8203

MINUS 20% DISCOUNT4($447,564)

TOTAL ESTIMATED FEES (NET OF DISCOUNT) $1,790,256

 

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

3 The Total Estimated Fees are calculated based on a $906 blended hourly rate for the Paul Hastings 

attorneys who are expected to work on this matter during the period from January 1, 2018 through 

January 31, 2018. The impact of the agreed-upon 20% end of the case write-off on the blended hourly 

rate cannot be calculated at this time. However, for illustrative purposes only, the blended hourly rate, 

after accounting for the 20% discount, would be approximately $725.

4

For illustrative purposes only. Indeed, pursuant to the order authorizing the Committee’s retention of 

Paul Hastings LLP [Docket No. 999], Paul Hastings can designate the precise fees to be waived to 

attain the 20% overall reduction in its total fees in connection with the final fee application process. In 

other words, Paul Hastings may designate its entire final fee application as the source of this reduction 

or a combination of reductions across other fee application.

Case:17-03283-LTS Doc#:2735-5 Filed:03/19/18 Entered:03/19/18 18:13:44 Desc:

Exhibit C Page 3 of 4
EXHIBIT C-2

STAFFING PLAN 

Period Covered: January 1, 2018 through January 31, 2018

1

Category of 

timekeeper

(using categories 

maintained by 

the firm)

Number of 

timekeepers 

expected to work on 

the matter during 

the budget period

Average hourly rate 

for period January 1, 

2018 through 

January 31, 2018

Average hourly rate 

for period January 1, 

2018 through 

January 31, 2018 

(net of 20% 

discount)2

Partner 10 $1,146 $917

Counsel 6 $1,084 $867

Associate 18 $737 $590

Paraprofessionals 10 $344 $275

 

1 The proposed staffing plan set forth herein is based on the following assumptions: (i) no additional title 

III cases or adversary proceedings will be commenced during the budget period; (ii) no plan of 

adjustment will be filed during the budget period; (iii) the Commonwealth-COFINA litigation is the 

only adversary proceeding that will require discovery and trial preparation; 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. Thus, this proposed staffing plan may be materially 

different from the work actually performed. For instance, discovery disputes may lead to extensive 

litigation. At this time, the proposed staffing plan is speculative, including, without limitation, because 

the full impact of Hurricane Maria on the Puerto Rico economy and the title III cases remains 

uncertain at this time. 

2 The impact of the agreed-upon 20% end-of-the-case write-off on the average hourly rate cannot be 

calculated at this time. However, for illustrative purposes only, we have provided the average hourly 

rate, after accounting for the 20% discount.

Case:17-03283-LTS Doc#:2735-5 Filed:03/19/18 Entered:03/19/18 18:13:44 Desc:

Exhibit C Page 4 of 4