Gregory Paul Palkowski and Deborah Lee Palkowski

UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION
In re:
Gregory Paul Palkowski
Deborah Lee Palkowski,
Debtors.
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Case No. 23-31324
Chapter 13
Judge Crist
ORDER GRANTING, IN PART, APPLICATIONS FOR ITEMIZED
ATTORNEY’S FEES SUBSEQUENT TO PLAN CONFIRMATION
AND REIMBURSEMENT OF EXPENSES (DOCS. 76 and 77)
This matter is before the Court on two applications for attorney fees and reimbursement of
expenses, filed in the span of two weeks, which are as follows:
1. 	Application for Attorney’s Fees Subsequent to Plan Confirmation (Doc. 76) (the
“Third Application”) filed by Debtors’ counsel pursuant to LBR 2016-1(b)(2)(C)
on August 13, 2025; and
2. 	Application for Attorney’s Fees Subsequent to Plan Confirmation (Doc. 77) (the
“Fourth Application” and together with the Third Application, the “Applications”)
filed by Debtors’ counsel pursuant to LBR 2016-1(b)(2)(C) on August 27, 2025.
For the reasons set forth below, the Court will grant the Third Application, given the
voluntary reduction in fees given by Debtors’ counsel – from $1,040 down to $600 – and that the
This document has been electronically entered in the records of the United
States Bankruptcy Court for the Southern District of Ohio.
IT IS SO ORDERED.
Dated: November 16, 2025
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total amount of fees sought therein, as reduced, are reasonable for the legal services provided;
namely, the Motion to Retain (Doc. 63) and the Amended Motion to Retain (Doc. 63) (Doc. 75),
filed on June 5, 2025, and July 21, 2025, respectively. Notably, Debtors’ counsel charged .4 hours
of time to prepare the Third Application, which ultimately involved a total of 2.6 hours of work.
Although this is higher than the percentage typically allowed for preparation of fee applications in
other contexts, it is still under the one hour often permitted for preparation of fee applications in
chapter 13 cases (and counsel took an overall reduction of fees equating to writing off 1.1 hours
of time at counsel’s rate of $400 an hour).
The Fourth Application is less straight-forward. The first issue is the overall amount of
time spent and fees incurred for the legal services provided. Namely, the Motion for Authority to
Sell Real Property and to Retain a Portion of the Sale Proceeds, which was filed twice on June 2,
2025 (Docs. 58 and 61), the second time with a Substitute Motion for Authority to Sell Real
Property and to Retain a Portion of the Sale Proceeds attached (Doc. 61-1), which did not appear
to have any changes (or was not explained to have any changes), followed by a separately filed
Substitute Motion for Authority to Sell Real Property and to Retain a Portion of the Sale Proceeds
(Doc. 62). Then, in response to a status conference scheduled by the Court that was held on July
15, 2025, Debtors’ counsel filed a Supplement to Motion for Authority to Sell Real Property and
to Retain a Portion of the Sale Proceeds (Doc. 62) (Doc. 69) on July 16, 2025. The amount sought
in the Fourth Application, $5,000, far exceeds the amount of fees the Court has seen charged in
other chapter 13 cases for sales of real estate.
The total amount of time spent by Debtors’ counsel on the second sale, 28.1 hours, all
billed at the highest rate charged in this market ($400 an hour), would result in a fee of $11,240,1
which is 2.5 times as much as the “no-look fee” for an entire chapter 13 case in this District. See
LBR 2016-1(b)(2)(A); Gen. Order No. 50-1 (Bankr. S.D. Ohio Feb. 24, 2021). And Debtors’
counsel was already awarded $15,000 for the pre-confirmation part of this chapter 13 case, which
had been voluntarily reduced from $19,325. See Order on Appl. for Award of Att’y Fees (Docket
No. 47) (Doc. 50), Apr. 23, 2024 (the “Pre-Confirmation Fee Order”) (awarding $15,000 in
attorney fees and $404.90 in expenses). Thus, if billed out without the voluntary fee reductions,
1 This number is somewhat inflated, however, because Debtors’ counsel did not charge any of their time in either of
the Applications at the administrative, or hypothetical paralegal, rate of $150 an hour.
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this is a $30,000+ chapter 13 case. And, as noted above, even the reduced amount of fees sought
in the Fourth Application are far in excess of what is typically seen for work by a debtor’s counsel
to sell real estate in a chapter 13 case, which is commonly around $1,000.2 Second, Debtors’
counsel charged 2.5 hours for preparation of the Fourth Application, which exceeds the typical
amount of time charged for fee application preparation in chapter 13 cases, and which the Court
will reduce pursuant to 11 U.S.C. § 330(a)(2) by one hour, for the reasons discussed more fully
below. The Court will address each of these issues, in turn.
I. 	Jurisdiction
This Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. § 1334(b)
and Amended General Order No. 05-02 of the District Court for the Southern District of Ohio
(Amended Standing Order of Reference).
II. 	Background
Mr. Novick and Ms. Chinault (together, “Debtors’ counsel”), who represent Mr. and Ms.
Palkowski (together, the “Debtors”) in this chapter 13 case, disclosed at the outset of this case that
they had agreed to accept $15,000 for legal services to be provided to the Debtors in this case,3
$9,667 of which had been paid prior to filing for bankruptcy relief.4 See Disclosure of Comp. of
Att’y for Debtor and Appl. for Allowance of Fees in Chp. 13 Case (Doc. 1 at 48). The second
amended Chapter 13 Plan (Doc. 34) (the “Second Amended Plan”) was confirmed on March 5,
2024. See Order Confirming Chp. 13 Plan (Doc. 34) and Awarding Att’y Fees (Doc. 43).5 On
2 This is not based on an exhaustive survey of attorney fees charged for motions to sell real estate but is consistent
with recent motions filed with this Court.
3 This Court has previously addressed the concern of whether to allow compensation in excess of the amount included
in the Disclosure Form, pursuant to 11 U.S.C. § 329 and Bankruptcy Rules 2016(b) and 2017, and does not revisit
that topic at this time, except to note that “the court’s authority to disallow fees in excess of the amounts identified in
a disclosure of compensation pursuant to § 329 and Rule 2016 is clear.” See In re Vaughn, 660 B.R. at 841 n.6, 848
(Humphrey, J.) (collecting prior rulings in this district). When applicable, Debtor counsel should explicitly indicate
that the amount listed is an estimated amount, as the Debtor’s now-confirmed plan did. See Doc. 34 at 5, ¶ 5.1.7.
4 Debtors’ Statement of Financial Affairs (“SOFA”) (Doc. 1 at 44) discloses a payment to Debtors’ counsel for $10,000
(of which $313 was the filing fee, $10 was for credit counseling, and $10 was for debtor education, leaving $9,667)
on August 20, 2023, within the year before filing bankruptcy about seeking bankruptcy or preparing a bankruptcy
petition.
5 This is the local form of confirmation order and does not govern the award of attorney fees in this case given that
counsel has opted out of the “no-look fee.”
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March 26, 2024, Debtors’ counsel filed the pre-confirmation Application for Attorney’s Fees (Doc.
47) (the “Application”), seeking allowance of $15,000 as attorney fees and $404.90 in expenses
for postage and service under the no-look fee opt out provision in LBR 2016-1(b)(2)(C); however,
that amount was “intentionally reduced” from the amount of fees that Debtors’ counsel would have
charged based on multiplying the number of hours worked by their hourly rates of $400 an hour
for attorney time and $150 an hour for administrative time – a total of $19,325. Doc. 47 at 2. That
Application revealed Debtors’ counsel had spent a total of 55.5 hours on this case through
confirmation, although 11.5 hours were billed at the hypothetical administrative rate of $150 an
hour. No objections were filed, and the Court entered its Pre-Confirmation Fee Order on April 22,
2024.
Since entry of the Pre-Confirmation Fee Order, and prior to filing the Applications now
before the Court, Debtors’ counsel has applied for additional, post-confirmation attorney fees
twice, pursuant to LBR 2016-1(b)(3). Inclusive of the Pre-Confirmation Fee Order, the Court has
awarded a total of $15,350 in fees to Debtors’ counsel, to date, listed as follows:
1. 	Pre-Confirmation Fees (Docs. 47, 50): 	$15,000
2. 	1st Post-Confirmation Fees (Docs. 54, 56): 	$150
3. 	2nd Post-Confirmation Fees (Docs. 59, 65): 	$200
$15,350
If awarded, the present Applications for $600 and $5,000, respectively, would put the total fees
awarded in this chapter 13 case, to date, at $20,950.
III. 	Analysis
A. 	Attorney Fees Sought in the Third and Fourth Applications6
This Court has previously written about a pre-confirmation no-look fee opt out application
by Debtors’ counsel in another case. See Order Granting Appl. for Itemized Att’y’s Fees and Den.
Reimbursement of Expenses (Doc. 27), In re Mooers, No. 25-30015, 2025 Bankr. LEXIS 1771
(Bankr. S.D. Ohio July 21, 2025) (Doc. 29) (the “Mooers Order”). Both Applications now before
the Court are consistent with the application resulting in the Mooers Order, in that Debtors’ counsel
took a substantial voluntary reduction of fees, apparently “to compensate for both professionals
6 The Court refers to these Applications as the Third and Fourth because Debtors’ counsel filed two prior applications
for post-confirmation fees.
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charging $400 per hour, which appears to be at the top end of the range for chapter 13 practitioners
in the Dayton area.” Id. at 4. As noted therein, this results in a phenomenon, which appears to be
somewhat unique to Debtors’ counsel, in which “the amount of the reductions are not quantified
or explained, and therefore the fees charged are not directly based upon the normal hourly rates
and time spent – the lodestar approach.” Id. (citing In re Edmondson, No. 22-23059, 2025 WL
510981, at *4 n.60, 2025 Bankr. LEXIS 350, at *10, n.60 (Bankr. W.D. Tenn. Feb. 14, 2025)
(discussing opinions by the United States Court of Appeals for the Sixth Circuit on the lodestar
framework and the two-part analysis).7 Long story short, as with the Mooers Order, this approach
makes for “a more involved process in assessing the reasonableness of the attorney’s fees sought
by counsel within the framework established by the Sixth Circuit.” Id.
As before, the Court will look at the effective hourly rate of Debtor’s counsel, which was
$235.11 in the Mooers case. See Id. at 3-4. In this case, the number of hours worked is 2.6 hours
in the Third Application, and 28.1 hours in the Fourth Application – a total of 30.7 hours. Dividing
the total amount of fees sought in the Applications ($600 + $5,000 = $5,600) results in an overall
effective hourly rate of $182.41. However, notwithstanding the voluntary reduction already given
by Debtors’ counsel, and notwithstanding the absence of any objections, the Court has an
independent duty to review the Applications for reasonableness, “[i]n order to guard the public
interest and integrity of the bankruptcy system.” Id. at 1-2 (citing In re Vaughn, 660 B.R. 827,
843-44 (Bankr. S.D. Ohio 2024) (Humphrey, J.) (citing In re Henson, 637 B.R. 13, 15 (Bankr.
S.D. Ohio 2022) (citing In re Spear, 636 B.R. 765, 769 (Bankr. S.D. Ohio 2022) (internal citations
omitted)); citing also Dery v. Cumberland Cas. & Sur. Co. (In re 5900 Assocs.), 468 F.3d 326,
329-30 (6th Cir. 2006) (citation omitted) (“In a bankruptcy case fees are not a matter for private
agreement. There is an inherent public interest that must be considered in awarding fees.”)). In this
instance, the reduction of fees is explained in the application, wherein Debtors’ counsel states that
the fees were “intentionally reduced to $5,000.00 because that is the estimated amount counsel
advised client it would cost for the work performed.” Fourth Appl. at 1.
7 See In re Boddy, 950 F.2d 334, 337 (6th Cir. 1991) (adopting the loadstar approach in fee calculations); In re Vill.
Apothecary, Inc., 45 F.4th 940, 952-53 (6th Cir. 2022) (court can consider “results obtained” in reviewing bankruptcy
fees pursuant to 11 U.S.C. § 330(a)(3)); In re Vaughn, 660 B.R. at 849 (holding that Village Apothecary applies to
Chapter 13 proceedings).
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Starting with the fees that Debtors’ counsel asks this Court to allow, the Court will review
the factors under § 330(a)(3)(A)-(B) for any further reduction “in excess of the voluntary reduction
already taken by counsel.” Mooers Order at 6. Ticking through the enumerated factors:
(A) 	The time spent on such services: 	It appears that this was an unusual case in which
there were two efforts to sell the commercial real estate, the first of which ended
without a sale due an apparent inspection failure, and as described below, the
voluntarily reduced fee is less than the time spent on just the second sale effort,
which was successful. On this point, however, it does appear that Debtors’ counsel
might spend more time on these matters than in other cases. Giving the benefit of
the doubt in this instance that it is due to the unique circumstances of this case, the
Court will not further reduce the time, this time.
(B) 	The rates charged for such services: 	Debtor’s counsel inconsistently employ
differing rates for administrative paralegal work and actual attorney work. This is
an on-going issue with Debtors’ counsel’s fee applications, as well as applications
from other consumer practitioners who do not employ associates, paralegals, or
assistants. And it did not help that in the Fourth Application Debtors’ counsel did
not put any of their time in the $150 an hour administrative category. They both
charge $400 an hour, which is at the top end of the scale for chapter 13 consumer
attorneys in Dayton; however, in this case the effective rate for the fees actually
sought in both Applications is much lower, only $182.41 an hour.
(C) 	Whether the services were necessary: 	There is some question as to whether the
services for the first, failed effort to sell the real estate were necessary; however,
because Debtors’ counsel is charging for less than the time spent on just the second,
successful sale, the time appears to be necessary and beneficial, and has resulted in
an increase in the dividend to non-priority unsecured creditors.
(D) 	Whether the services were performed within a reasonable amount of time: 	Some
of the time entries could be viewed as being on the high side, but again, Debtors’
counsel is voluntarily taking a significant reduction. However, as discussed below,
the Court does find the time spent to prepare the Fourth Application, 2.5 hours,
excessive in this particular circumstance and will reduce that entry by one hour.
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(E) 	Whether the attorneys are board certified or otherwise have demonstrated skill and
experience in the bankruptcy field: 	This is not a concern, particularly now that
Debtors’ counsel have provided short biographies.
(F) 	Whether the compensation is reasonable based on the customary compensation
charged by comparably skilled practitioners in cases other than cases under this
title: 	Given that Debtors’ counsel are effectively charging $182.41 an hour for
their services in these Applications, this is not a concern.
Turning to other particular items, with respect to preparation of the Third Application,
Debtors’ counsel includes a time entry for 0.4 hours, which is approximately 15% of the total hours
charged (2.6). Doc. 76 at 1. For the Fourth Application,8 Debtors’ counsel includes a time entry
for 2.5 hours, which is approximately 8.9% of the total hours charged. Doc. 77 at 8. As analyzed
in the Edmondson case cited in the Mooers Order, “[t]he Code permits the Court to award
compensation to professionals for preparing a fee application.” In re Edmondson, 2025 Bankr.
LEXIS, at *15 & n.75 (citing 11 U.S.C. § 330(a)(6) (2025)). But “[u]sually, courts allow attorneys
to charge up to one hour to prepare a fee application in chapter 13 cases.” Id. & n.77. At the same
time, the Edmondson opinion allowed 2.9 hours for several reasons. Id. at *16. Because two of
those reasons do not apply in this District, given that it is common for chapter 13 debtor attorneys
to file post-confirmation applications for additional fees (and, in fact, the Edmondson opinion
actually cites this District’s Local Bankruptcy Rule 2016-1), and considering that Debtors’ counsel
appear to frequently opt out of the “no-look fee,” only the third reason potentially applies, which
is that through the Mooers Order this Court had given Debtors’ counsel guidance on how to submit
future fee applications. Thus, Debtors’ counsel included short biographies for the attorneys
providing the legal services. Doc. 77 at 5. However, Debtors’ counsel did not include any
explanation within the Fourth Application about why they worked 28.1 hours on this sale of
property in a chapter 13 case, which they should have done when they spent 2.5 hours to prepare
the Fourth Application, and which may have helped to fill in some of the gaps left by the sometimes
cryptic time entries, e.g., “Email from Gina with current Chapter 13 payoff – wpn – 09.26.24 –
8 The time entries included in the Third Application do not include preparation time.
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0.3.”9 Doc. 77 at 6. The cryptic natures also makes it hard to determine at which rate the services
provided should invoiced. Therefore, given Debtors’ counsel’s familiarity with and frequent
submission of itemized fee applications,10 that the Fourth Application included no explanation of
the complexity of the issues or justification for accruing fees nearly five times as much as typically
seen, that Debtors’ counsel did not take the time to bill any of their time at the administrative rate,
and that had just billed 0.4 hours for preparing the Third Application, the Court reduces this entry
by one hour.11
Reviewing the docket for this case, no motion to sell was filed until June 2, 2025; thus, the
first group of time entries in the Fourth Application, dating from September 23, 2024, to October
11, 2024, describe an effort to sell the commercial property at 1654 Mardon Drive (not the Debtors’
residence) that was ultimately unsuccessful, apparently due to a failed inspection. See Order at 1
(Doc. 71); Fourth Appl. at 6 (Doc. 77). But it is not the Court’s burden to provide this explanation;
that burden falls upon the applicant, who always carries the burden of establishing its entitlement
to attorney’s fees. Mooers Order at 2 (citing In re Spurlock, 642 B.R. 269, 285 (Bankr. S.D. Ohio)
(Humphrey, J.) (“The applicant seeking attorney fees always carries the burden of proof to
establish that the fees are warranted and should be approved.”) (citations omitted); see also In re
Thomas v. Robinson (In re Robinson), 189 F. App’x 371, 374 (6th Cir. 2006) (similar); Vaughn,
660 B.R. at 844 (similar)). Thus, some further explanation within the Applications of what was
done and why it took so much time to do it (maintaining privilege, of course), in addition to the
time entries provided, would be very helpful. This is particularly so with respect to the Fourth
Application that includes an unusual level of services to sell real estate in a chapter 13 case.
Also regarding the Fourth Application, there is a second group of time entries, dating from
April 21, 2025, to July 26, 2025, not including the time entry on August 10, 2025 for preparation
of the Fourth Application. This group of entries, spanning about a page and a half, concerns a
9 What did Debtors’ counsel do with the email from Gina? Presumably they were reviewing it, but why did it take 18
minutes to review? And how did that benefit the Debtors? We can only guess.
10 Notably, in the Application for Attorney’s Fees (Case No. 25-30015, Doc. 27) that Debtors’ counsel filed in the
Mooers chapter 13 case, Debtors’ counsel identified time entries to charge at the administrative rate of $150 and did
not charge any time for preparing that fee application.
11 Another issue presented by the approach of routinely taking large voluntary reductions is that the only
straightforward approach to award less than the fees sought is to reduce specific entries, notwithstanding the
broadbrush reduction taken.
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second effort to sell the investment property, which resulted in Debtors’ counsel filing the Motion
and Substitute Motions to Sell Real Property (Docs. 58, 61, and 62), and the Supplement (Doc.
69). However, given that this was the second time trying to sell the real estate, some of the time
entries seem like they could potentially be duplicative of prior services, such as “Reviewed court
records, proof of claim, state records on taxes, certificate of Judgments and Debt balances – wpn
– 04.21.25 – 1.5,” and some of the time entries should have been billed, if at all, at the hypothetical
paralegal or administrative assistant rates of $150 or $75, respectively, such as “Review of signed
motion and affidavit, Filed and served motion – emc – 6.2.2025 – 0.4.” Fourth Appl. at 6-7.
Nevertheless, because the time entries did add up to 28.1 hours; because there is enough
description in the majority of time entries, coupled with the Court’s docket entries, status
conference on the sale, and filings, to understand what was done, by whom, for how long, and at
what rate; because the amount of fees for which Debtors’ counsel actually seeks approval is far
less than what they would charge if all the work on the first failed sale effort were written off (6.4
hours) and equates to an hourly effective rate of $182.41, which is just $32.41 over the hypothetical
administrative (paralegal) rate and represents an approximate 54% voluntary reduction in fees;12
and because Debtors’ counsel was ultimately successful in obtaining approval of their clients’
requested relief which also increased the dividend to unsecured creditors,13 the Court, in this case,
which appears to be a very unusual case, will approve the Applications, together, except as to the
one hour of time spent preparing the Fourth Application, pursuant to LBR 2016-1(b)(2)(C) and 11
U.S.C. § 330(a) in the total amount of $5,200 for the period of time covered in the Applications.
See In re Vill. Apothecary, Inc., 45 F.4th at 952-53.
As a word of caution, however, counsel should not expect this to be the norm, and just
because fees of this amount were approved in this case does not mean that they will be approved
in another case, absent well-explained unusual circumstances. The fees in this case have far
exceeded what is typical or anticipated in most, if not every other, chapter 13 case the Court has
12 The voluntary fee reduction taken by Debtors’ counsel in the Mooers case was approximately 36.5%. Mooers Order
at 4. As noted in the Mooers Order, specifically with respect to fee applications filed by Debtors’ counsel, “the issue
this raises is that from application to application, the reduction percentages are not necessarily (or observed to be)
consistent, the amount of the reductions are not quantified or explained, and therefore the fees charged are not directly
based upon the normal hourly rates and time spent – the lodestar approach. Id.
13 Following the status conference held by the Court on July 15, 2025, an Agreed Order Increasing Dividend to
Unsecured Creditors (Doc. 72), was entered into by the Chapter 13 Trustee and Debtors’ counsel, which was entered
on July 18, 2025.
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reviewed to date. Moreover, as noted before, Debtors’ counsel’s approach toward charging all time
at the highest possible rate in the market of $400 an hour, not utilizing the administrative rate for
any entries, and then taking steep discounts makes for a more involved process in assessing the
reasonableness of the attorney’s fees sought within the framework established by the Sixth Circuit.
And when counsel is consistently taking significant voluntary fee reductions, it begs the question
of whether their hourly rate and billing arrangements should be reviewed and adjusted.
It is notable that Debtors’ counsel appear to be the only firm in this market that effectively
have two partner-level attorneys billing time on the same chapter 13 cases at the highest hourly
rates. Attorneys should have work done at appropriate rates for the tasks, pushing down less
challenging or administrative work. And, if they do not have other professionals to push work to,
to still charge those time entries at rates that are appropriate for the level of work. It is concerning
that Debtors’ counsel did not do this within the Fourth Application. Absent the significant
discount, the Court would reduce the hourly rates permitted for work that should be performed at
associate, paralegal, or administrative assistant rates.
B. 	Expenses Sought in the Third and Fourth Applications
With respect to the expenses of $98.02 and $307.80 sought in the Third and Fourth
Applications, respectively, Debtors’ counsel did include itemizations for printing costs and postage
this time. The printing is charged at $0.19 per page, while the postage is charged at $0.74 for the
1 oz. rate mailings and $0.97 for the 2 oz. rate mailings, which appear to be slightly less than
currently advertised postage rates. It appears that Debtors’ counsel only charged for printing and
mailing one set of the Motions to Sell, based on dividing the total number of pages, 720, by the
number of mailings, 60, which results in 12 double-sided pages, matching up with the 24 pages of
the Motion for Authority to Sell (Doc. 58) or the 24 pages of the Substitute Motion for Authority
to Sell (Doc. 62), but not both. Had Debtors’ counsel charged for both sets the Court might not
have approved the full expense. Moreover, both the Third and Fourth Applications are consistent
in there having been 58 mailings for the Motion to Retain (Doc. 63)14 and 60 mailings for both the
14 The Label Matrix attached to the Motion to Retain (Doc. 63) reflects that there were 58 mailable recipients.
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Motion to Sell15 and Supplement to Motion to Sell.16 The only issue is with the amount Debtors’
counsel is charging for printing. But given that there is a surprising lack of guidance on the topic
and the amount charged by Debtors’ counsel appears to fit within the standards set in some other
courts, the Court will approve those as well, subject to revisiting this issue when reviewing future
fee applications. See, e.g., LBR D. Conn., Appendix D, ¶ D.2. (“Photocopies shall be reimbursable
at the lesser of $0.20 per page or cost.”).
IV. 	Conclusion
For the foregoing reasons, the Court GRANTS the Applications by Debtors’ counsel for
attorney fees in the total amount of $5,200 and allows reimbursement for expenses of printing and
postage in the total amount of $405.82 – an aggregate total of $5,605.82 for all attorney fees and
expenses sought in the Third and Fourth Applications (Docs. 76 & 77).
IT IS SO ORDERED.
Copies to:
Default List
15 The Label Matrix attached to the Motion to Sell (Doc. 58) reflects that there were 58 mailable recipients, but
Debtors’ counsel also served the realtor and title company.
16 The Label Matrix attached to the Supplement to Motion to Sell (Doc. 69) reflects that there were 58 mailable
recipients, but Debtors’ counsel also served the realtor and title company.
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