Unknown Case Title - Adversary Proceeding

CourtUnited States Bankruptcy Court, D. Idaho
DecidedApril 27, 2022
Docket21-00712
StatusUnknown

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Unknown Case Title - Adversary Proceeding, (Idaho 2022).

Opinion

UNITED STATES BANKRUPTCY COURT

DISTRICT OF IDAHO

IN RE: Case No. 21-00712-NGH

BLUE CIRCLE INVESTMENTS,

LLC,

Chapter 11 Debtor.

MEMORANDUM OF DECISION

Before the Court is petitioning creditor Earthcraft Construction’s (“Earthcraft”) Application for Administrative Expenses (the “Application”). Doc. No. 21. After a hearing on March 28, 2022, the Court took the matter under advisement. Having reviewed the record, arguments of the parties, and applicable law, the following constitutes the Court’s ruling on the matter. BACKGROUND On December 8, 2021, a chapter 7 involuntary petition was filed against Blue Circle Investments, Inc. (“Debtor”) by Earthcraft, Falcon Framers, LLC, Thorpe Fire Sprinkler Systems Inc., and Idaho Premier Stucco, LLC.1 Doc. No. 1. Debtor filed a motion to convert the case to chapter 11, which the Court granted on February 25, 2022. Doc. Nos. 15 & 40.

1 Unless otherwise indicated, all chapter and section references are to the Bankruptcy Code, 11 U.S.C. §§ 101–1532, all rule references are to the Federal Rules of Bankruptcy Procedure, Rules 1001–9037, and all “Civil Rule” references are to the Federal Rules of Civil Procedure. Prior to conversion, Earthcraft filed the Application, which seeks administrative expenses pursuant to § 503(b)(3)(A) and (4) in the amount of $7,590.00 for attorney fees

and $455.60 for costs associated with the filing of the involuntary petition. Doc. Nos. 21, 22, & 36. Debtor does not object to administrative expenses in the amount of $1,290.00 for attorney fees or to $455.60 for costs. Doc. Nos. 32 & 50. However, Debtor objected to the remaining fees, asserting they were either unrelated to the involuntary process, unnecessary, or “lumped.” Doc. Nos. 32 & 50. Going line by line, Debtor objects to 24 separate time entries for attorney fees. Doc. No. 50. In replying to Debtor’s objections,

Earthcraft provided additional explanation for its counsel’s time entries and associated fees. Doc. No. 58. Because Debtor has not objected and the Court finds the uncontested attorney fees and costs to be actual, necessary, and reasonable under § 503(b)(3)(A) and (b)(4), the Court will focus only on the request for attorney fees to which Debtor objects.2 ANALYSIS

A. Earthcraft’s Application for Administrative Expenses 1. Legal Standards Administrative expenses permitted under § 503(b) are given priority under § 507(a)(2). For legal fees and costs to be considered an administrative expense, they must be “actual, necessary, allowed under §§ 503(b)(3)(A)–(E), and in addition, the amounts must be reasonable under § 503(b)(4).” In re Treasure Valley Marine, Inc.,

2020 WL 6821789, at *5 (Bankr. D. Idaho October 15, 2020). Section 503(b)(3)(A)

2 Attached to the Decision as Exhibit A is a chart of Earthcraft’s requested fees, noting whether such fees are allowed, and if disallowed, a summary of the Court’s reasoning why. permits a creditor that has filed a petition under § 303 to have an administrative claim for actual, necessary expenses involved. The claimant bears the burden of establishing by a

preponderance of the evidence that “the expenses were incurred in an endeavor that ‘provides tangible benefits to the bankruptcy estate and other unsecured creditors.’” In re Treasure Valley Marine, 2020 WL 6821789, at *5 (quoting In re Sedona Inst., 21 F. App’x 723, 729 (9th Cir. 2001)). Section 503(b)(3)(A) encompasses legal fees associated with both the filing of the involuntary petition under § 303 and also the adjudication of the involuntary bankruptcy.

Id. at *7. “Attorney’s fees may be recovered under §§ 503(b)(3)(A) and 503(b)(4) for preparing and filing the involuntary petition, contacting other creditors to join in the petition, legal and factual research regarding the grounds for the filing of the case, and litigating whether an order for relief should be entered.” In re Key Auto Liquidation Ctr., Inc., 384 B.R. 599, 605–06 (Bankr. N.D Fla. 2008) (citing In re Westek Georgia, LLC,

317 B.R. 567, 570 (Bankr. M.D. Ga. 2004)). However, services not directly related to the involuntary petition are not compensable, including time spent on “attempting an unsuccessful pre-bankruptcy workout,” conferring with non-petitioning creditors, and pursuing other actions within the bankruptcy case not related to the prosecution of the involuntary. Id. See also In re Crazy Eddie, 120 B.R. 273, 277–78 (Bankr. S.D.N.Y.

1990); In re Stoecker, 128 B.R. 205, 212 (Bankr. N.D. Ill. 1991). Further, administrative expenses under § 503(b)(3)(A) cannot be collected for services performed after an order for relief has been entered. In re Key Auto Liquidation Ctr., 384 B.R. at 606. In addition to being an actual, necessary expense related to the filing and prosecution of an involuntary petition, the fees must also be reasonable under

§ 503(b)(4). When determining whether to allow attorney fees as an administrative expense, the Court “must disallow those fees claimed if the Court cannot determine whether the amount charged for services was reasonable because the time entries in the lawyers’ accounting are ‘lumped.’” In re Treasure Valley Marine, 2020 WL 6821789, at *5. Lumping occurs where multiple services are included in the same time entry, making it difficult to discern how much time was spent on each task and whether that time was

reasonable. See id. 2. Section 503(b)(3)(A) - Actual and Necessary Expenses First, Debtor objected to expenses as unrelated or unnecessary for the filing or adjudication of the involuntary petition. Debtor objected to two time entries on October 29, 2021, for being vague as to whether the services performed related to the involuntary

or a separate lawsuit. Doc. No. 50 at 5. Earthcraft has since clarified the involuntary petition was the only litigation at the time and no other lawsuits were pending between the parties. As such, the Court is satisfied the second time entry for October 29, 2021, was actual and necessary to the involuntary petition. However, Earthcraft requested administrative expenses for services that are not

compensable under § 503(b)(3)(A), including the first time entry dated October 29, 2021. As noted previously, pre-filing negotiations to try and avoid bankruptcy, as well as discussions with non-petitioning creditors, are not sufficiently related to the involuntary process to warrant an administrative expense under § 503(b)(3)(A). The first time entry for October 29 relates to counsel’s contacts with “J. Leonard re expired deadline to respond to demand.” Doc. No. 36 at 5. While counsel has asserted the only litigation at

the time was the involuntary petition, without additional information, the Court cannot determine whether the “demand” relates to the involuntary petition, or an attempt by Earthcraft to collect payment and avoid the bankruptcy. Additionally, in Earthcraft’s reply to Debtor’s objection, counsel justifies its expense for “review letter from J. Leonard declining to pay and refusing contract” on November 11, 2021, as “activity of the petitioning creditor to try and avoid the bankruptcy.” Doc. No. 58 at 3. Further,

Earthcraft’s counsel has sought administrative expenses for discussions with non- petitioning creditor Mobile Modular.3 Because these services are not sufficiently related to the involuntary petition filing or adjudication, they will not be allowed as administrative expenses. Further, certain activities were unnecessary for the filing of the involuntary

petition.

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Related

In Re Key Auto Liquidation Center, Inc.
384 B.R. 599 (N.D. Florida, 2008)
In Re Westek Georgia, LLC.
317 B.R. 567 (M.D. Georgia, 2004)
In Re Crazy Eddie, Inc.
120 B.R. 273 (S.D. New York, 1990)
In Re Stoecker
128 B.R. 205 (N.D. Illinois, 1991)

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