Bankr. C.D. California cuts bankruptcy fee award, including for clerical work
IN Holdings, Inc and 5310 Holdings, LLC, No. 1:24-bk-11323. United States Bankruptcy Court, C.D. California. Decided . Read the opinion
The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.
Bankruptcy · Contract fee clause · Fee applicant's counsel: Buchalter LLP
What happened
Buchalter LLP sought attorneys' fees from the reorganized debtor under a contract fee clause. The court did not state totals. It excluded $7,192.50 in aggregate charges, $2,865.50 for 5.0 duplicative hours, $1,027.50 for 1.5 hours of timesheet review and redaction, and $137 for 0.2 hours of secretarial tasks. It found the time spent on one task excessive and reduced the fees billed for it. It disallowed duplicative staffing of $1,764, $1,862 and $1,275. It reduced fees on block-billed entries, including $10,155.90 and $510, and applied a 50% reduction to other entries, reducing $3,136. It also deducted $4,635 for a vacated hearing.
What the court said
Ms. Djang billed 1.5 hours for reviewing/revising timesheets and redacting them. The Court will exclude from its award the corresponding $1,027.50 in attorneys' fees incurred for this work.
Ms. Djang billed 0.2 (for a total of $137) for noncompensable secretarial tasks. The Court will not award these fees to STS.
the Court will award 80% of the fees billed for these time entries of Ms. Parks. The results in a reduction of $10,155.90 in fees payable to STS.
The Court will award STS 50% of the fees billed for these services of Ms. Cabo. This results in a reduction of $3,136.00 in attorneys' fees payable to STS.
The Court will award STS 80% of the fees billed for these services. The results in a reduction of $510.00 in fees payable to STS.
The Court will exclude from its award the services Ms. Djang provided between August 1 and August 5, 2026 related to her review, redaction and revision of timesheets (e.g., 3.5 hours of the 5.5 hours requested)
The court also reduced the award for: other, duplicative staffing, excessive hours, duplicative staffing, duplicative staffing, duplicative staffing, duplicative staffing, other, other.
Why it matters
The ruling shows courts will separate clerical and administrative entries from legal work and reduce block-billed entries by a percentage when the records do not tie tasks to time. It also shows that duplicative staffing and time for hearings that did not occur are removed before an award is calculated.
How to keep this out of your fee petition
- Leave purely clerical work off the fee petition.
- Describe paralegal tasks so the substantive work is clear.
- Split mixed entries into their substantive and clerical parts.
Cite this ruling
IN Holdings, Inc and 5310 Holdings, LLC, No. 1:24-bk-11323 (Bankr. C.D. Cal. Sept. 9, 2026) See hourly rates the Bankr. C.D. California approves.
Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.
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