Case Summary:
In a prior ruling the bankruptcy court disallowed 50 percent of BMO's fees for lack of specificity. Subsequently, BMO filed a supplemental claim asserting a claim for attorney's fees incurred post-confirmation for work done in connection with the debtor's objection to its first supplemental claim. Debtor objected that the claim was not specific, violated the creditor's obligation of good faith and fair dealing, and was not caused by debtor's default. The Court sustained Debtor’s objection and held that the fees were not reasonable because they resulted from creditor's prior insufficient itemization of attorney's fees. “The Debtor should not be penalized for BMO's failure to prepare its fee notice in compliance to these standards.”

Statute/Rule References:
11 U.S.C. § 506(b)
11 U.S.C. § 1322(e)

Key Terms:
Attorney Fees