Bankr. D. Alaska cuts bankruptcy fee award 64.8%, including for clerical work

What happened

Proskauer Rose LLP sought $636,995.50 in fees for 392.8 hours in the Aleksey N Kozlov bankruptcy matter. Judge Gary Spraker awarded $224,106.70, a reduction of $412,888.80. The court reduced the hourly rates for partners, associates, and paralegals. It disallowed 84.8 paralegal hours billed at $38,254 as clerical work, and reduced billed attorney hours by 10%, or 30.4 hours and $24,736.30, as excessive. Hours awarded totaled 277.6.

What the court said

The court shall disallow 84.8 hours of paralegal billings as previously identified in the tentative decision (ECF No. 301 at 24-25) in the original amount of $38,254.

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

Why it matters

The ruling shows that a fee award can fall well below the request when courts reset hourly rates and separate clerical tasks from legal work. It also shows courts will trim hours they find excessive even after adjusting rates, so the time records and task descriptions carry weight at each step of the analysis.

How to keep this out of your fee petition

• Leave purely clerical work off the fee petition.
• Describe paralegal tasks so the substantive work is clear.
• Split mixed entries into their substantive and clerical parts.

Cite this ruling

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.