The Bankruptcy Court for the Western District of Michigan has a three-tiered presumptive hourly rate for chapter 13 debtor’s attorneys. The first, at $175.00 per hour, is the lowest tier. The second, at $220.00 per hour, is for attorneys who have attended at least seven hours of CLE and certified attendance and chapter 13 expertise to the court. The third, at $250.00 per hour, is for attorneys who are certified by the American Board of Certification (ABC).
In this case the attorney sought the $250.00 per hour rate, even though he was not certified by the ABC. The Trustee objected.
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