Little, 484 B.R. 506

Debtors Littles hired attorney Stone for a fixed $2,500 retainer for preparing and filing their petition, schedules, statements, and plan, with other services billed hourly.
Littles, above median income, disclosed questionable expenses which were amended in subsequent schedules.
Initial plan proposed $35/month for 60 months with 1% dividend to unsecureds; $900 in additional fees to be paid through the plan; trustee objected for insufficient projected disposable income.
First amended plan increased payments to $860/month for 60 months with larger unsecured dividend; M&T Bank objected to cramdown; Littles filed a second amended plan identical to the first amended plan but resolved the bank objection.
Second amended plan was confirmed and contemplated Stone’s fees (estimated $6,000) paid through the plan; Stone later sought $9,102.10 in fees and costs.
Bankruptcy court reduced Stone’s fee award to $3,982.10 initially, noting excessive and merit-less work; on appeal, the district affirmed a further reduction to $8,982.10 total ($3,500 fees, $482.10 expenses).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the fee reduction was an abuse of discretion	Stone asserts fees were justified by extensive communications and plan work.	Bankruptcy court properly reduced fees due to unnecessary, duplicative, and merit-less work.	No abuse; reduction upheld.
Appropriateness of the lodestar method and adjustments	Stone relies on standard lodestar approach to compute reasonable fees.	Court correctly applied lodestar and adjusted downward for excessive or unnecessary hours.	lodestar framework applied; adjustments affirmed.
Whether the court properly identified and eliminated unreasonably spent time	Some hours were necessary given client circumstances.	Hours were duplicative or unnecessary; discount warranted.	Yes; court did not abuse in cutting hours.

In re Sullivan, 674 F.3d 65 (1st Cir. 2012) (lodestar method; deference to bankruptcy court on fee awards)
In re Torres Lopez, 405 B.R. 24 (1st Cir. BAP 2009) (lodestar calculation; flexibility in reducing/adjusting fees)
In re Claudio, 459 B.R. 500 (Bankr. D. Mass. 2011) (multiplying hours by reasonable rate; adjustment possible)
In re Narragansett Clothing Co., 210 B.R. 493 (1st Cir. BAP 1997) (burden on claimant to prove value of compensation)
In re LaFrance, 311 B.R. 1 (Bankr. D. Mass. 2004) (basis for considering time exclusions in fee awards)