In Re Moran’s Empirical Analysis

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Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “$20 per hour is a reasonable hourly labor charge by petition preparers for their time spent meeting with clients, typing the documents, and reviewing the documents prior to signing, tasks which most courts have held are permitted by the statute. The Court also finds that petition preparers should be able to recover their overhead costs in conducting their petition preparation businesses. See Landry, 250 B.R. at 446 (acknowledging that labor and overhead may be factored into a petition preparer’s compensation if appropriate evidence is presented). Overhead costs would include such items as telephone service, photocopy machines, electricity, and employee benefits.... In the absence of any better evidence, the Court finds that fifty percent of a reasonable wage, or $10 per hour, is a reasonable amount for overhead. Accordingly, the Court holds that $30 per hour is a reasonable rate to be charged by a petition preparer. The Court notes that this amount may be subject to change upon receipt of more complete evidence on overhead costs or on account of inflation and other economic influences. See Guttierez, 248 B.R. at 299 n. 32. In addition, the Court believes that petition preparers should be able to perform their petition preparation services in a routine individual or joint consumer case in five hours or less. The Court takes into account the UST’s evidence that the petition, schedules, and statements can be typed in one and a half to two hours and the Court’s observation that a”

   1 later decision quote this exact passage
   e.g. In Re Pavlis

2. “[o]ther courts have declined to adopt a blanket rule regarding petition preparer fees,”

   1 later decision quote this exact passage
   e.g. In Re Landry

3. “monitor petition preparers' practices and fees . . . on a case by case basis.”

   1 later decision quote this exact passage
   e.g. In Re Landry