Local Rule RULE 2016-2: Attorney Fees Paid Through Chapter 13 Plans.
Bankr. D. Mont. — General rule
RULE 2016-2. Attorney Fees Paid Through Chapter 13 Plans.
Except for prepetition retainers, all debtor's attorney's fees and costs shall be paid through the Chapter 13 Plan unless otherwise ordered. Debtor's attorney may not receive the payment of fees or the reimbursement of expenses directly from debtor or another party on behalf of debtor, other than the prepetition retainer, without Court authorization. Court authorization shall also be required in all Chapter 13 cases that are dismissed or converted to another chapter, either before or after plan confirmation, when the total fees and costs exceed those presumed to be reasonable under Mont. LBR 2016-1(b). (See also Mont. LBR 2016-1(d) regarding dismissed Chapter 13 cases).