D. Arizona cuts commercial fee award 3.7% over clerical work | LegalTime AI

D. Arizona cuts commercial fee award 3.7% over clerical work

CPUS Mockingbird LP v. Langer, No. 2:25-cv-00282. District Court, D. Arizona, Judge Michael T Liburdi. Decided . Read the opinion

Requested
$9,966.47
Awarded
$9,596.47
Cut
3.7%$370

Commercial · Figures include costs

What happened

CPUS Mockingbird LP sought $9,966.47 in fees and costs, covering 25.9 hours, in a commercial case. The court awarded $9,596.47, a reduction of $370, or 3.7%. The court excluded 2.6 hours billed by a paralegal and a legal assistant because the work was clerical. The figures include costs. Judge Michael T Liburdi issued the order.

What the court said

Clerical work billed as legal work
CPUS may not recover as to 1.1 hours billed by CPUS’ paralegal and 1.5 hours billed by its legal assistant since those hours were spent on clerical work.

Why it matters

The ruling shows that courts separate clerical tasks from legal work when reviewing time records, and that hours billed by paralegals and legal assistants for clerical tasks can be excluded from a fee award even when the overall reduction is small.

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

CPUS Mockingbird LP v. Langer, No. 2:25-cv-00282 (D. Ariz. July 24, 2026)

See hourly rates the D. Arizona approves and attorney fee motions in Arizona 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.

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