Bankr. M.D. Pennsylvania cuts bankruptcy fee award 45.5%, including for clerical work | LegalTime AI

Bankr. M.D. Pennsylvania cuts bankruptcy fee award 45.5%, including for clerical work

Lonnie Dean Carpenter, No. 4:19-bk-03194. United States Bankruptcy Court, M.D. Pennsylvania, Judge Mjc. Decided . Read the opinion

Requested
$36,691.40
Awarded
$20,011.80
Cut
45.5%$16,679.60

Bankruptcy

What happened

Counsel sought $36,691.40 in fees. The court awarded $20,011.80, a reduction of $16,679.60, or 45.5%. The court marked time entries on the invoice to identify work that should have been delegated to a paralegal, non-billable or overhead time, excessive time with an appropriate deduction, and counsel error. The figures do not include costs.

What the court said

Clerical work billed as legal work
designated certain of Mr. Gurdin's time entries on the attached marked-up Invoice as work that should have been delegated to a paralegal as "P"

The court also reduced the award for: other, excessive hours, other.

Why it matters

The ruling shows that courts review each time entry and separate legal work from tasks that belong to paralegals or are overhead. It also shows that excessive hours and counsel error can draw deductions alongside recordkeeping problems, so the total cut reflects several grounds rather than one.

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

Lonnie Dean Carpenter, No. 4:19-bk-03194 (Bankr. M.D. Pa. Sept. 30, 2024)

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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