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In re Bobbi Jo Quigley

Bankr. No.: 
Date of Decision: 
February 9, 2022
Whether an attorney's disclosure of compensation accurately reflected the bifurcated fee agreements between the attorney and the debtor, and whether the fee for the attorney's post-petition services was reasonable.
No, on both issues. Though no fees were required to be disgorged, the attorney's disclosures of compensation must be internally consistent and accurately reflect the attorney's fee agreements with a debtor. In addition, pre-petition services must be sufficient to fulfill the attorney's obligations under 11 U.S.C. ยง 707(b)(4)(C), Fed.R.Bankr.P. 9011(b), and all applicable rules of professional conduct, and any flat fee for post-petition services must reflect the actual work expected to be performed post-petition.
Full Bankruptcy Court Decision: