S.D. California cuts fee award 64.5%, including for vague entries

What happened

3D Systems sought $432,269.07 in sanctions fees, including costs, for 588.4 hours. The court awarded $153,680.50, a reduction of $278,588.57 or 64.5%. It declined fees for vague entries describing document analysis and strategizing, for duplicative staffing on a deposition outline, and for excessive hours on motion revision, reply drafting, argument preparation, and the fee petition. It also reduced the hourly rate for one attorney.

What the court said

The Court declines to award fees for time spent by Mr. Borja “analyzing” documents and “strategizing” in connection with the motion, as those descriptions do not adequately describe the nature of his work

The court also reduced the award for: duplicative staffing, excessive hours, excessive hours, excessive hours, excessive hours, excessive hours, excessive hours, hourly rate reduced.

Why it matters

The ruling shows that courts will reduce fee awards when time entries do not describe the work with enough specificity, and when staffing and hours are not shown to be reasonable. It also shows that a reduced hourly rate can further lower the total even after hours are cut.

How to keep this out of your fee petition

• Name the task, the document or person involved, and the purpose.
• Avoid stock phrases that could describe any day in any matter.
• Keep privileged detail general, but specific enough to show the work.

Cite this ruling

See hourly rates the S.D. California approves and attorney fee motions in California federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.