Bankr. M.D. Pennsylvania cuts bankruptcy fee award 40.4%, including for clerical work

What happened

The fee applicant sought $28,263.75 for 104.7 hours in the Torri Lyn Martir bankruptcy matter. Judge Mark J. Conway awarded $16,834.80, a reduction of $11,428.95 or 40.4%. The court reduced pre-filing fees, cutting about 22.4 hours to 15. It also reduced 3.3 hours and 1.5 hours of administrative tasks to zero, and cut expense work from 10.7 to 6.5 hours, hearing work from 13.5 to 8.1 hours, and briefing from 28.4 to 15 hours.

What the court said

a reduction of the inappropriately billed administrative tasks billed from 3.3 hours to 0 hours

1.5 hours on administrative tasks reduced to 0 hours

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

Why it matters

The ruling shows that courts will separate clerical tasks from legal work and reduce hours billed for them, and will also trim categories of work found excessive. Fee applicants should expect line-item scrutiny of both the nature of tasks and the time devoted to them.

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

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.