Hearing Date: June 6, 2018 at 9:30 a.m. (Atlantic Standard Time)

Objection Deadline: April 9, 2018 at 4:00 p.m. (Atlantic Standard Time)

UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et 

al.,

Debtors.1

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 1063, 1150, 1715

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”)

Debtor.

PROMESA

Title III

No. 17 BK 3567-LTS

SUMMARY OF SECOND INTERIM APPLICATION OF THE LAW OFFICES OF 

ANDRES W. LOPEZ, PSC FOR ALLOWANCE OF COMPENSATION FOR SERVICES 

RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE

PUERTO RICO FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY FOR 

THE PERIOD FROM OCTOBER 1, 2017 THROUGH DECEMBER 31, 2017

 

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). (Title III case numbers are listed as Bankruptcy Case numbers 

due to software limitations).

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Second Interim Fee Application (HTA) Page 1 of 24
- 2 -

Name of Applicant: The Law Offices of Andrés W. López, P.S.C. 

(“AWLLAW”)

Authorized to Provide Professional Services to: Puerto Rico Fiscal Agency and Financial Advisory 

Authority (“AAFAF”) as the entity authorized to act on 

behalf of the Commonwealth of Puerto Rico

Period for which compensation and reimbursement are 

sought:

October 1, 2017 through December 31, 2017

Amount of Compensation sought as actual, reasonable, 

and necessary:

$11,480.00

Amount of Expense Reimbursement sought as actual, 

reasonable, and necessary:

$0.00

This is a(n): __ monthly X interim final application

• Blended Rate in this application for attorneys: $350/hr

• Blended Rate in this application for all timekeepers: $350/hr

Prior Monthly Fee Statements Filed: 

Compensation Period Fees Requested Expenses Requested

May 3, 2017 – November 30, 2017 $30,485.00 $0.00

December 1 – December 31, 2017 $5,075.00 $0.00

• Both payments have been partially made, for 90% of the total amount.

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- 3 -

TABLE OF SCHEDULES AND EXHIBITS

Schedule A - List and Summary of Hours by Professional

Schedule B - Summary of Hours and Compensation by Matter Code

Schedule C - Expense Summary

Schedule D - Customary and Comparable Disclosures

Exhibit A - Attorney Certification

Exhibit B - Detailed Time and Expense Records

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- 4 -

Schedule A

LIST AND SUMMARY OF HOURS AND COMPENSATION BY PROFESSIONAL

Name Title or Position Hours Billed in this 

Application

Hourly Rate Billed in this 

Application

Total 

Compensation

Andrés W. López Partner 32.80 $350.00 $11,480.00

TOTAL 32.80 $11,480.00

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- 5 -

Schedule B

SUMMARY OF HOURS AND COMPENSATION BY MATTER CODE

Task Code Matter Description Total Billed

Hours

Total Fees

Requested

Commonwealth Title III Case

Litigation

This category includes analysis, 

preparation, and prosecution of adversary 

proceedings or other litigation. 

7.00 $2,450.00

Relief From 

Stay and 

Adequate 

Protection

This category includes all matters relating 

to creditor requests for relief from the 

automatic stay or for adequate protection, 

including assisting the Commonwealth 

respond, defend, and settle such requests. 

17.70 $6,195.00

Vendor and 

Other Creditor 

Issues

This category includes all meetings and 

communications with vendors and other 

trade creditors and utility providers. 

8.10 $2,835.00

Total 32.80 $11,480.00

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- 6 -

Schedule C

EXPENSE SUMMARY

Category Amount

No expenses are requested with this application. $0.00

TOTAL $0.00

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Schedule D

CUSTOMARY AND COMPARABLE DISCLOSURES

Category of Timekeeper Blended Hourly Rate

Billed for FY2017

Billed This Case During the 

Compensation Period

Partner N/A $350

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UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et 

al.,

Debtors.1

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 1063, 1150, 1715

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”)

Debtor.

PROMESA

Title III

No. 17 BK 3567-LTS

SECOND INTERIM APPLICATION OF THE LAW OFFICES OF ANDRES W. LOPEZ, 

P.S.C. FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND 

FOR REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE PUERTO RICO 

FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY FOR THE PERIOD 

FROM OCTOBER 1, 2017 THROUGH DECEMBER 31, 2017

 

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). (Title III case numbers are listed as Bankruptcy Case numbers 

due to software limitations).

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Second Interim Fee Application (HTA) Page 8 of 24
The Law Offices of Andrés W. López, P.S.C. (“AWLLAW”), as counsel to the Puerto Rico 

Fiscal Agency and Financial Advisory Authority (“AAFAF”) as the entity authorized to act on 

behalf of the Commonwealth of Puerto Rico, the Puerto Rico Sales Tax Financing Corporation, 

the Puerto Rico Highways and Transportation Authority, the Employees Retirement System of the 

Government of the Commonwealth of Puerto Rico, the Puerto Rico Electric Power Authority 

(collectively, the “Debtors”), and certain other public corporations and instrumentalities of the 

Government of Puerto Rico, pursuant to the authority granted to it under the Enabling Act of the 

Fiscal Agency and Financial Advisory Authority, Act 2-2017, makes its second interim application 

(this “Application”) for allowance of compensation, under sections 316 and 317 of PROMESA, 

of $11,480.00 for the period from October 1, 2017 through December 31, 2017 (the 

“Compensation Period”) in accordance with the First Amended Order Setting Procedures for 

Interim Compensation and Reimbursement of Expenses of Professionals, dated November 8, 2017 

[ECF No. 1715] (the “Interim Compensation Order”) and the Memorandum regarding Fee Review 

– Timeline and Process, dated November 10, 2017 (the “Fee Examiner Guidelines”). In support 

of this Application, AWLLAW respectfully states as follows:

BACKGROUND

1. 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.

2. On May 5, 2017, the Puerto Rico Sales Tax Financing Corporation (“COFINA”), 

by and through the Oversight Board, as COFINA’s representative pursuant to PROMESA section 

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

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3. On May 21, 2017, the Puerto Rico Highways and Transportation Authority 

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

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

4. 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 

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

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

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

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

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

PREPA Title III Cases (together, the “Title III Cases”) are jointly administered for procedural 

purposes only, pursuant to PROMESA section 304(g) and Bankruptcy Rule 1015 [ECF Nos. 242, 

537, 1417].

7. This application seeks allowance of compensation and reimbursement of expenses 

incurred by AWLLAW solely in connection with the COFINA related matters described below.

COMPENSATION REQUESTED

8. AAFAF has retained AWLLAW pursuant to an engagement letter dated July 31, 

2017 (the “Engagement Letter”). Pursuant to the Engagement Letter, payment of all fees and 

expenses detailed in this Application will be made exclusively by AAFAF.

9. AWLLAW’s hourly rates are set at a level designed to compensate AWLLAW

fairly for the work of its attorneys and are disclosed in detail in the Engagement Letter. 

10. AWLLAW’s rates are appropriate for complex corporate, securities, litigation, and 

restructuring matters, whether in court or otherwise. The rates and rate structure reflect that such 

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Second Interim Fee Application (HTA) Page 10 of 24
complex matters typically involve great complexity, high stakes, and intense time pressures. 

Further, there have not been any rate increases during the Compensation Period. AWLLAW

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

such services provided to AAFAF.

11. During the Compensation Period, AWLLAW did not receive any payments or 

promises of payment from any other source for services rendered or to be rendered in any capacity 

whatsoever in connection with the matters covered by this Application. There is no agreement or 

understanding between AWLLAW and any other person for sharing of compensation to be 

received for services rendered in these cases.

SUMMARY OF SERVICES

12. During the Interim Period, AWLLAW provided important professional services to 

the Debtors in connection with the Title III Cases. Detailed descriptions of the specific services 

provided and the time expended performing such services are attached as Exhibit B, and a 

summary of the services AWLLAW provided to the Debtors during the Compensation Period is 

set forth below.

13. In its fee applications, AWLLAW will use the subject matter categories (each, a 

“Matter Category”) used by its co-counsel law firm, O’Melveny & Myers LLP (“OMM”), for 

keeping time records of the work performed for the Debtors. The following is a summary, by 

Matter Category, of the professional services provided by AWLLAW during the Compensation 

Period.

a) Litigation – 7.00 hours – $2,450.00

14. This category includes analysis, preparation, and prosecution of adversary 

proceedings or other litigation. During the Compensation Period, AWLLAW worked with 

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OMM on various litigation matters and on motions filed pursuant to Rule 2004 seeking to 

conduct discovery of various issues relating to Puerto Rico’s fiscal matters.

b) Relief from Stay and Adequate Protection – 17.70 hours – $6,195.00

15. This category includes all matters relating to requests for relief from the automatic 

stay or for adequate protection, including assisting the Commonwealth to respond, defend, and 

settle such requests. During the Compensation Period, AWLLAW worked with OMM in 

analyzing and responding to requests to lift the Title III stay (either by motion or lift stay 

notice), and in implementing a lift stay protocol to streamline the process for seeking relief 

from the Title III stay.

c) Vendors and Other Creditor Issues – 8.10 hours -- $2,835.00

16. This category includes all meetings and communications with vendors and other 

trade creditors and utility providers. During the Compensation Period, AWLLAW worked with 

OMM in helping to analyze issues and payment disputes with various government vendors, and to 

resolve the issues and disputes as appropriate.

ATTORNEY CERTIFICATION

14. In accordance with Puerto Rico Local Bankruptcy Rule 2016-1(a)(4), the 

undersigned has reviewed the requirements of Puerto Rico Local Bankruptcy Rule 2016-1(a)(4)

and certifies to the best of his information, knowledge, and belief that this Application complies 

with Puerto Rico Local Bankruptcy Rule 2016-1(a)(4). In this regard, and incorporated herein by 

reference, the Certification of Andrés W. López in accordance with the U.S. Trustee Guidelines is 

attached hereto as Exhibit A.

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Second Interim Fee Application (HTA) Page 12 of 24
NO PRIOR APPLICATION

15. No prior application for the relief requested by this Application has been made to 

this or any other court.

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WHEREFORE, AWLLAW respectfully requests that the Court enter an order: (a) 

awarding AWLLAW compensation for professional services provided during the Compensation

Period in the amount of $11,480.00; and (b) granting such other relief as is appropriate under the 

circumstances.

Dated: March 20, 2018

San Juan, Puerto Rico

Respectfully submitted, 

/s/Andrés W. López

Andrés W. López

USDC No. 215311

THE LAW OFFICES OF 

ANDRÉS W. LÓPEZ, P.S.C.

902 Fernández Juncos Ave.

San Juan, PR 00907

Tel: (787) 294-9508

Fax: (787) 294-9519

Attorneys for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority 

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Second Interim Fee Application (HTA) Page 14 of 24
Exhibit A

ATTORNEY CERTIFICATION

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Second Interim Fee Application (HTA) Page 15 of 24
UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et 

al.,

Debtors.2

PROMESA

Title III

No. 17 BK 3283-LTS

Re: ECF No. 1063, 1150, 1715

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY (“HTA”)

Debtor.

PROMESA

Title III

No. 17 BK 3567-LTS

CERTIFICATION OF ANDRES W. LOPEZ PURSUANT TO PUERTO RICO LOCAL 

BANKRUPTCY RULE 2016-1(a)(4)

 

2 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). (Title III case numbers are listed as Bankruptcy Case numbers 

due to software limitations).

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Second Interim Fee Application (HTA) Page 16 of 24
Andrés W. López, under penalty of perjury, certifies as follows:

1. I am a partner with the law firm of The Law Offices of Andres W. López, P.S.C.

(“AWLLAW”). I make this certification in accordance with Rule 2016-1(a)(4) of the Local Rules 

of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of 

Puerto Rico (the “Local Rules”) regarding the contents of applications for compensation and 

expenses. 

2. I am familiar with the work performed by AWLLAW for the Puerto Rico Fiscal 

Agency and Financial Advisory Authority (“AAFAF”), acting for or on behalf of the Debtors.

3. I have read the Second Interim Application of The Law Offices of Andrés W. López, 

P.S.C. for Allowance of Compensation for Services Rendered and for Reimbursement of Expenses 

As Counsel to the Debtors for the Period From October 1, 2017 through December 31, 2017 (the 

“Application”), and the facts set forth therein are true and correct to the best of my knowledge, 

information, and belief. 

4. To the best of my knowledge, information, and belief, formed after reasonable 

inquiry, the fees and disbursements sought in the Application are permissible under PROMESA, 

the Bankruptcy Code, the Federal Rules of Bankruptcy Procedure, the Interim Compensation 

Order, the Guidelines for Reviewing Applications for Compensation and Reimbursement of 

Expenses by Attorneys in Larger Chapter 11 Cases, effective November 1, 2013 (the “Guidelines”), 

and the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court 

for the District of Puerto Rico.

Dated: March 19, 2018 /s/Andrés W. López

Andrés W. López

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Exhibit B

DETAILED TIME AND EXPENSE RECORDS

I. Litigation

Date Services Hours

10/2/17 Correspond w/J. Spina re motion to adjourn 0.40

October 4, 2017 hearing in Assured; review draft

motion re same.

10/3/17 Correspond w/A. Pavel re informative motion 0.40

regarding attendance at October 11, 2017 in

Assured; review draft motion re same.

10/6/17 Review memos from P. Friedman, Proskauer 0.20

team re proposed extension of time in Ambac

and Assured matters.

10/30/17 Telephone conference w/H. Bauer HTA motion to compel 0.80

and Siemens Rule 2004 motion (0.2); conference call 

w/GDB team re same (0.3); correspond w/I. Garau re 

same (0.3). 

10/30/17 Correspond w/A. Pavel re reply brief on motion to 0.40

dismiss in Ambac; review draft reply re same.

10/30/17 Correspond w/I. Garau re draft stipulation follow up 0.30

on meeting with opposing counsel re pending motion 

to assume or reject executory contracts.

10/31/17 Correspond w/G. Lopez, I. Garau re revised opposition 0.50

to Siemens Rule 2004 motion; review revised

opposition re same.

10/31/17 Correspond w/A. Pavel re revised supplemental reply 0.40

brief and joinder in Ambac; review draft re same.

11/8/17 Review memos from O. Ramos, M. Trelles (GDB’s counsel) 0.40

re informative motion re appearance at November 15, 2017 

on Siemens Rule 2004 motion; review draft motion re same.

11/16/17 Correspond w/A. Pavel re upcoming motions to be filed 0.70

in Ambac and Assured matters in advance of November 21, 

2017 hearing (0.3); review informative motions re same (0.2); 

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Second Interim Fee Application (HTA) Page 19 of 24
review memo from W. Burgos and revise motions re same (0.2).

11/17/17 Review Court Order granting in part and denying in part 0.10

Siemens’ Rule 2004 motion.

11/27/17 Review memo from P. Friedman re draft supplemental 0.50

briefs in Assured; review draft briefs re same.

12/8/17 Correspond w/P. Friedman re admission in First Circuit 0.20

and information re same.

12/11/17 Correspond w/G. Hoplamazian re: entry of appearance in 0.50

Peaje First Circuit appeal; enter appearance in Peaje. 

12/13/17 Review memo from J. Cardona re proposed draft stipulation 0.50

re motion to compel assumption or rejection of executory

contracts; review draft stipulation re same.

12/21/17 Memos to and from P. Friedman re filing an appearance 0.70

in Peaje matters in the First Circuit (0.2); prepare and file 

entries of appearance re same (0.5).

Total Hours: 7.00

Total Fees: $2,450.00

II. Relief From Stay and Adequate Protection

10/16/17 Review memo from J. Morales-Cordero 0.50

(counsel to HTA managerial employees)

re further enlargement of time to consider

and potentially negotiate pending cases; review

draft motion re same; correspond with D. Perez

re same.

10/19/17 Review memo from J. Morales-Cordero 0.50

(counsel to HTA managerial employees)

re revised motion to enlarge time to 

consider pending cases; correspond w/D. 

Perez re same; review revised motion re same.

10/21/17 Correspond w/J. Spina, J. Morales-Cordero 0.70

(counsel to HTA managerial employees) re

revised draft of stipulation extending deadlines (0.4);

review draft stipulation re same (0.3).

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Second Interim Fee Application (HTA) Page 20 of 24
10/23/17 Correspond w/D. Perez re lift stay notice re 0.50

Vega Baja and HTA; review background 

documents re same. 

10/24/17 Correspond w/J. Morales-Cordero 0.30

(counsel to HTA managerial employees) re

revised draft of stipulation extending deadlines.

10/24/17 Memo to J. Maldonado re lift stay notice re 0.20

Vega Baja and HTA.

11/1/17 Review memo from D. Perez re conference w/opposing 0.40

counsel re Rexach Hermanos case and their motion to 

lift stay, and potential stipulation re same; review 

attached reply re same.

11/2/17 Review memos re Siemens matter joint status report (0.2); 1.10

conference call with counsel re same (0.3); review draft joint 

status report (0.2); review memos from G. Lopez, C. Forbes, 

H. Bauer, M. Trelles re same (0.4).

11/13/17 Review memo from D. Perez re revised stipulation in 0.50

Rexach Hermanos lift stay notice matter; review revised 

stipulation re same; review memo from I. Garau re same.

11/14/17 Review Rexach Hermanos’ motion to withdraw their 0.10

previously-filed motion to lift stay.

11/18/17 Review new lift stay notice (R. Dieppa, counsel); correspond 0.40

with D. Perez, C. Juan, J. Maldonado re same.

11/27/17 Review memo from R. Dieppa (counsel to Mendez- 0.20

Colon) re lift stay notice; correspond w/R. Dieppa

re same.

11/28/17 Memo to J. Maldonado re Mendez-Colon lift stay notice. 0.10

12/1/17 Correspond w/J. Morales-Cordero (counsel to HTA 1.20

managerial employees) re tables describing all pending

cases and procedural posture of each case (0.2); review 

table re same (1.0).

12/4/17 Correspond w/D. Perez re status of HTA lift stay notices 0.50

and conversation w/J. Maldonado re same; correspond w/

J. Maldonado re same.

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Second Interim Fee Application (HTA) Page 21 of 24
12/12/17 Review lift stay notice from R. Garcia-Fontan; review 0.40

memo from H. Bauer re same.

12/13/17 Review memo from D. Perez and accompanying documents 2.00 

re outstanding HTA lift stay matters for discussion and 

resolution.

12/14/17 Review memo from R. Miranda (counsel to FDR 1500 Corp.) 0.50

re lift stay notice; review attached document re same.

12/15/17 Telephone conference w/I. Garau re lift stay notices and 0.30

conference w/Juan Maldonado re same.

12/15/17 Review memo from D. Perez re Castro Business lift stay notice 0.40

and scheduling conference call to discuss pending matters;

review lift stay notice re same.

12/15/17 Memo to and from D. Perez re procedure for handling 0.30

lift stay notices related to HTA.

12/17/17 Review memos re conference w/J. Maldonado to discuss 0.40

pending lift stay notices; memo to J. Maldonado re same.

12/19/17 Review memo from M. Vicens re lift stay notice (Finca 0.30

Matilde); review attached supporting document re same.

12/19/17 Memos to and from J. Maldonado re conference call to 0.20

discuss pending HTA-related lift stay notice matters. 

12/20/17 Memos to and from D. Perez re telephone conference w/J. 0.20

Maldonado to cover HTA-related lift stay notice matters.

12/20/17 Review memo from attorney M. Vicens re Finca Matilde 0.50

lift stay notice matter; review supporting documentation

re same; memo to D. Perez, J. Maldonado re same.

12/20/17 Memos to and from D. Perez re timing and outreach 0.70

to opposing counsel in Jimenez lift stay notice matter (0.2);

review background documents re same (0.5).

12/21/17 Memos to and from D. Perez re Jimenez lift stay notice 1.50

matter (0.2); telephone conferences w/counsel for Jimenez

(0.4); memos to and from D. Perez re same (0.2); review 

memo from D. Perez w/draft motion to extend HTA’s 

deadline to respond to motion requesting payment of 

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pre-petition claims (0.3); review memo from I. Garau re 

same (0.1); review draft motion re same (0.2); memo to 

D. Perez re same (0.1). 

12/21/17 Memos to and from J. Maldonado re telephone conference 0.20

to discuss pending HTA-related lift stay notice matters.

12/22/17 Memos to and from D. Perez re reaching out to plaintiffs’ 0.60

counsel in Jimenez lift stay notice matter (0.2); review draft 

motion to extend time (0.2); memos to and from J. Soto 

(plaintiff’s counsel) re draft motion to extend time to

file response to motion requesting payment of prepetition claims (0.2).

12/27/17 Conference w/attorney Y. Mafuz-Blanco re lift stay 1.90

notice matter (1.0); review documents related to lift 

stay notice (0.7); memo to D. Perez re same (0.2).

12/28/17 Review memo from J. Maldonado re attorney Y. 0.10

Mafuz-Blanco’s lift stay notice.

Total Hours: 17.70

Total Fees: $6,195.00

III. Vendor and Other Creditor Issues

10/10/17 Correspond w/J. Maldonado, R. Castellanos, H. Bauer, 0.40

D. Perez re meeting with opposing counsel re

motion to compel assumption or rejection of

executory contracts.

10/12/17 Review documents re motion to compel assumption 4.40

or rejection of executory contracts (2.5); conference 

w/H. Bauer, J. Maldonado, R. Castellanos, and

opposing counsel re same (1.7); correspond w/D. Perez

re same (0.2).

10/24/17 Review memo from H. Bauer re draft stipulation 0.50

following up on meeting with opposing counsel re 

pending motion to assume or reject executory 

contracts; review draft re same.

10/25/17 Correspond w/ J. Spina re draft stipulation following 0.50

up on meeting with opposing counsel re pending 

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motion to assume or reject executory contracts;

correspond w/D. Perez re same; memo to J. Maldonado

re same.

11/1/17 Correspond w/J. Spina, D. Perez, J. Maldonado re draft 0.50 

stipulation following up on meeting with opposing counsel 

re pending motion to assume or reject executory contracts. 

11/2/17 Review memos from J. Spina, D. Perez re draft stipulation 0.50

following up on meeting with opposing counsel re pending 

motion to assume or reject executory contracts.

11/6/17 Review memos to and from D. Perez, J. Maldonado re 0.40

stipulation to resolve pending motions seeking to compel 

assumption or rejection of executory contracts (Tamrio, 

Constructora Santiago, Ferrovial Agroman); review

documents re same. 

11/8/17 Review memo from H. Bauer re agreement with opposing 0.50

counsel (J. Cardona) to adjourn hearing on pending motions 

to compel until December omnibus hearing and reply memo 

from J. Cardona agreeing re same; review draft stipulation 

to potentially moot the pending motions to compel. 

12/8/17 Correspond w/D. Perez re recently-filed motion requesting 0.40

payment of funds; review motion; memo to J. Maldonado re 

same.

Total Hours: 8.10

Total Fees: $2,835.00

For Professional Services rendered: 

Hours Amount

Andrés W. López, Esq. 32.80 $11,480.00

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