Judge Lawrence Kahn
Law firm Harris-Courage & Grady filed a Chapter 13 bankruptcy petition on the Harlanders' behalf in July 2010. The Harlanders had agreed to pay the firm a flat $,3700 fee. Their confirmed bankruptcy plan required payment of $290 monthly to the Chapter 13 trustee for 60 months. Despite accepting an amended plan reducing debtors' monthly payments, bankruptcy court's July 5, 2012, order denied—without explanation—the law firm's request for reimbursement of $99 in costs associated with the modification plan's filing. Denying reconsideration bankruptcy court deemed debtors' case—later converted to Chapter 7—a usual Chapter 13 case of the type contemplated by the Administrative Orders, such that there was no basis to award costs in addition to the approved flat fee. On appeal, district court affirmed the bankruptcy court's decision. Discussing Administrative Orders 09-07 and 13-02 district court found the law firm's mailing costs included in its flat fee. The mailing costs were included in the law firm's flat fee contemplated by the two administrative orders because those costs were ordinary and reasonable and incurred in connection with the service of a routine modification order.
