In re: James M. Mooney

United States Bankruptcy Court, N.D. Illinois·Decided January 22, 2026·No. 25-14257·Unknown

Opinion

EASTERN DIVISION

) In re: ) Case No. 25bk14257

) James M. Mooney, ) Chapter 13

) Debtor. ) Judge Timothy A. Barnes

FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO GREGORY K. STERN, MONICA C. O’BRIEN, DENNIS E. QUAID AND RACHEL S. SANDLER, ATTORNEYS FOR DEBTOR, FOR ALLOWANCE AND PAYMENT OF FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES

TOTAL FEES REQUESTED: $ 11,705.00 TOTAL COSTS REQUESTED: $ 313.00 TOTAL FEES REDUCED: $ 3,233.75 TOTAL COSTS REDUCED: $ 0.00 TOTAL FEES ALLOWED: $ 8,471.25 TOTAL COSTS ALLOWED: $ 313.00

TOTAL FEES AND COSTS ALLOWED: $8,784.25

The court notes that the Debtor has objected to the application allowed in part herein. This order resolves that objection. In so doing, the court notes that the fees requested are disproportionately high for a chapter 13 case of no apparent complexity where counsel withdrew after a short period of time. In this District, the court allows a set fee of $5,500 per case for counsel who participate in the court’s Court Approved Retention Agreement process. As that does not dictate what is reasonable in any given case but rather effectuates an average across cases, counsel who believe the Court Approved Retention Agreement process will not accurately reflect their efforts in a given case are always free to apply for compensation by the process utilized by counsel here. It does, however, call into question what justifies fees that more than double that standard in a case of limited duration (at least as far as counsel’s involvement).

The court notes that counsel’s hourly rate is the main contributing factor to the amount of the fees. Counsel’s rates are nearly double the hourly rate of most debtor’s attorneys appearing in simple chapter 13 cases before the court. However, as the court is not generally in the role of protecting debtors from their bad business choices, the court will not reduce the hourly rate applicable here. Though high, the rate in question is not outside the range of reasonableness and by the documentation submitted to the court, it appears that counsel’s rate was disclosed to the Debtor in the retention agreement which was fully agreed to by the Debtor.

Here, while the court reduces the fees requested in accordance with its normal fee review process, it therefore makes no other reductions. As to those normal reductions, 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. The Court denies the allowance of compensation for work done prior to the authorization of retention. In re Spanjer Bros., Inc., 203 B.R. 85, 94 (Bankr. N.D. Ill. 1996) (Squires, J.) (“The Court will not retrospectively allow any of the time expended prior to the time of the authorized retention because to do so would be to reward any delay or tardiness in promptly seeking retention. To allow bootstrapping of objected to fees paid at the expense of unsecured creditors undermines the policy in favor of prompt application for retention by professionals who will be seeking compensation from the bankruptcy estate. See generally 11 U.S.C. § 327 (prerequisite to the allowance of any fees or expenses that professional be employed); In re Peoples Sav. Corp., 114 B.R. 151, 154 (Bankr. N.D. Ill. 1990) (‘In the absence of a court order approving the Applicant’s employment, there is no statutory basis upon which the Court can make a fee award.’)”).

(2) Lumping – TOTAL of disallowed amounts (10% of affected entries): $ 104.00

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: $ 2,019.75

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: $ 330.00 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)(a).. 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.); I” re Pettibone, 74 B.R. at 303; But see In re MEP Infrastructure Sols., Inc., 654 B.R. 922, 925 (Bankr. N.D. Ill.

Free access — add to your briefcase to read the full text and ask questions with AI

In re: James M. Mooney, (Ill. 2026).

In re: James M. Mooney (In re: James M. Mooney) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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 Peoples Savings Corp.
114 B.R. 151 (N.D. Illinois, 1990)
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)