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§ 503(b)(3)(B)

In re Engler

Sep
30
2013
Ruling
Creditor's administrative expense claim for attorneys' fees limited to period through date of order for relief.
Issue(s)
Were creditors are entitled to an administrative expense claim for the pre-petition fees they incurred investigating debtors' Ponzi scheme, as well as the post-petition fees incurred recovering property for the benefit of the estate.

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Consumer opinion summary, case decided on September 30, 2013 , LexisNexis #1013-080
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In re Beale

Oct
16
2006
Ruling
Creditor was not entitled to administrative expense claim for legal fees incurred in recovery of assets conducted without court approval.
Procedural posture

In an involuntary chapter 7 proceeding, the court denied a motion by the chapter 7 trustee to employ a certain law firm as special counsel. This law firm was creditor's counsel and had investigated debtor's finances prior to the petition date. The creditor incurred substantial legal fees and expenses. The creditor moved for allowance of an administrative expense claim under 11 U.S.C. § 503(b)(3)(B). The U.S. Trustee filed an objection.

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opinion summary, case decided on October 16, 2006 , LexisNexis #1106-057
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