Bankr. D. Maine cuts bankruptcy fee award, including for vague entries
Waylan Phillips, No. 1:23-bk-10094. United States Bankruptcy Court, D. Maine, Judge Michael A. Fagone. 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 · Fee applicant's counsel: Shankman & Associates
What happened
Shankman & Associates sought fees in the Waylan Phillips bankruptcy case. The court did not state totals. Judge Michael A. Fagone disallowed $430.00 in fees that the trustee objected to, finding the trustee's objection persuasive. The court disallowed a further $100.00 because the billing detail and context did not let the court determine whether certain services were necessary.
What the court said
disallowed a further $100.00 in fees because the Court cannot determine, from the information and context provided in the billing detail, whether certain services rendered were necessary
The court also reduced the award for: other.
Why it matters
The ruling shows that a fee applicant's billing detail must let the court see why each service was needed. Where the entries and context leave that unclear, the court can strike the charge even without a percentage or hours analysis, and a trustee's objection can carry the rest.
How to keep this out of your fee petition
- Name the task, the document or person involved, and the purpose.
- Avoid stock phrases that could describe any day in any matter.
- Keep privileged detail general, but specific enough to show the work.
Cite this ruling
Waylan Phillips, No. 1:23-bk-10094 (Bankr. D. Me. Jan. 5, 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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