Berliner v. Pappalardo (In re Sullivan), 674 F.3d 65, 69–70 (1st Cir. 2012) (Selya, Souter, Lipez)

$3,684 is reasonable fee for “relatively uncomplicated” Chapter 13 case. “[W]e have recognized that the lodestar method is an appropriate measuring device for attorneys’ fees in bankruptcy cases. . . . [N]otwithstanding the need for a means test calculation, the debtors’ case was not complex. . . . [L]awyers have an obligation to keep hand-holding within reasonable limits.”

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