In re: Ani Roof LLC

United States Bankruptcy Court, N.D. Illinois·Decided September 9, 2026·No. 25-08670·Unknown

Opinion

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

) In re: ) Case No. 25bk08670

) Ani Roof LLC, ) Chapter 11

) Debtor(s). ) Judge Timothy A. Barnes

FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO TAFT STETTINIUS & HOLLISTER LLP, ATTORNEYS FOR THE DEBTOR, FOR ALLOWANCE AND PAYMENT OF FIRST AND FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES

TOTAL FEES REQUESTED: $ 224,094.23 TOTAL COSTS REQUESTED: $ 1,977.63 TOTAL FEES REDUCED: $ 11,525.17 TOTAL COSTS REDUCED: $ 0.00 TOTAL FEES ALLOWED: $ 212,569.06 TOTAL COSTS ALLOWED: $ 1,977.63

TOTAL FEES AND COSTS ALLOWED: $ 214,546.69

The attached time and expense entries have been underlined to reflect disallowance in whole or in part. The basis for each disallowance is reflected by numerical notations that appear on the left of each underlined entry. The numerical notations correspond to the enumerated paragraphs below.

(1) Insufficient Description – TOTAL of disallowed amounts: $ 4,182.48

The Court’s review of items marked (1) indicates that the majority of offending entries provide a description, but one that is insufficient in nature – either too general, failed to indicate who a party was meeting with, or failed to indicate the actual task performed. As a result, while the Court determines that entire disallowance of such time entries is not appropriate, in order to promulgate appropriate billing practices, a reduction is required. Thus, the Court will impose a 10% penalty on all of the entries marked (1).In re Pettibone, 74 B.R. 293, 301 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“A proper fee application must list each activity, its date, the attorney who performed the work, a description of the nature and substance of the work performed, and the time spent on the work. [Citation omitted] Records which give no explanation of the activities performed are not compensable.”); In re Wildman, 72 B.R. 700, 708-09 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (same).

(2) Lumping – TOTAL of disallowed amounts (10% of affected entries): $ 850.48

The Court may impose a ten percent penalty on entries that appear to be “lumping.” The Court will reduce each entry marked as such per the penalty. In re Wildman, 72 B.R. 700, 709 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“Applicants may not circumvent the minimum time requirement or any of the requirements of detail by “lumping” a bunch of activities into a single entry. [citation omitted]. Each type of service should be listed with the corresponding specific time allotment.”). (3) Unreasonable Time – TOTAL of disallowed amounts: $ 6,218.93

The Court denies the allowance in part of compensation for the indicated task(s) since the professional or paraprofessional expended an unreasonable amount of time on the task(s) in light of the nature of the task(s), the experience and knowledge of the professional performing the task(s), and the amount of time previously expended by the professional or another on the task(s). In re Pettibone, 74 B.R. 293, 306 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“The Court will determine what is the reasonable amount of time an attorney should have to spend on a given project... An attorney should not be rewarded for inefficiency. Similarly, attorneys will not be fully compensated for spending an unreasonable number of hours on activities of little benefit to the estate.”); In re Wildman, 72 B.R. 700, 713 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (same).

As to the time devoted to the preparation of the fee application itself, the Court denies the allowance of compensation that is disproportionate to the total hours in the main case. In re Wildman, 72 B.R. 700, 711 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“In the absence of unusual circumstances, the hours allowed by this Court for preparing and litigating the attorney fee application should not exceed three percent of the total hours in the main case.”); In re Spanjer Bros., Inc., 203 B.R. 85, 93 (Bankr. N.D. Ill. 1996) (Squires, J.) (compensation limited to 5%); see also In re Pettibone Corp., 74 B.R. 293, 304 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (citing Coulter v. State of Tennessee, 805 F.2d 146, 151 (6th Cir. 1986) (in nonbankruptcy cases, compensation for preparation and litigation of fee petitions limited to 3-5% of the hours of the main case)). However, for applications for compensation that request total fees of $10,000.00 or less, this Court will allow compensation for the time devoted to the preparation of the fee application itself in the following manner: For the first $5,000.00 of total compensation requested, this Court will limit time devoted to preparation of the fee application to 10% of total compensation requested and will allow 5% of additional total compensation requested for time devoted to preparation of the fee application.

(4) Duplication of Services – TOTAL of disallowed amounts: $ 273.28

The Court denies the allowance of compensation for services that duplicate those of another professional or paraprofessional. See 11 U.S.C. § 330(a)(4)(A)(i). Reduction in fees is warranted if multiple attorneys from the same firm appear in court on a motion or argument or for a conference, unless counsel adequately demonstrates that each attorney present contributed in some meaningful way. In re Pettibone, 74 B.R. 293, 307 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“A debtor’s estate should not bear the burden of duplication of services. If found in the record, such duplication shall be disallowed by the court as unnecessary.”). It is also an accepted principle that generally no more than one attorney may bill for time spent in an intra-office conference or meeting absent an adequate explanation. See In re Adventist Living Ctrs., Inc., 137 B.R. 701, 716 (Bankr. N.D. Ill. 1991) (Sonderby, J.); In re Pettibone, 74 B.R. at 303; But see In re MEP Infrastructure Sols., Inc., 654 B.R. 922, 925 (Bankr. N.D. Ill. 2023) (Goldgar, J.) (incorrectly citing In re Stainless Sales Corp., Case No. 17 B 3148, 2017 WL 2829675, at *2 (Bankr. N.D. Ill. June 27, 2017) (Barnes, J.) for the proposition that intra-office meetings between multiple lawyers are never compensable when Stainless cites to Pettibone for the foregoing—that an application must “adequately demonstrate[] that each attorney present contributed in some meaningful way” and thus satisfy 11 U.S.C. § 330(a)(3)(D) by demonstrating that the meeting is “necessary” or “beneficial” and must have taken a “reasonable amount of time.”). Dated: September 9, 2026 — : - Judge ‘Timothy A. Barnes United States Bankruptcy Court

Taft Stettinius & Hollister LLP Client/File #: 122539/00003 Invoice #: 7074598

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Related

Coulter v. State Of Tennessee
805 F.2d 146 (Sixth Circuit, 1986)
In Re Wildman
72 B.R. 700 (N.D. Illinois, 1987)
In Re Pettibone Corp.
74 B.R. 293 (N.D. Illinois, 1987)
In Re Adventist Living Centers, Inc.
137 B.R. 701 (N.D. Illinois, 1991)
In Re Spanjer Bros., Inc.
203 B.R. 85 (N.D. Illinois, 1996)