E.D. New York cuts employment fee award 49.7%, including for clerical work | LegalTime AI

E.D. New York cuts employment fee award 49.7%, including for clerical work

Figueroa v. Mayflower International Hotel Group, Inc et al, No. 1:23-cv-04729. District Court, E.D. New York, Judge Ramón E. Reyes, Jr.. Decided . Read the opinion

Requested
$66,004.33
Awarded
$33,205.25
Cut
49.7%$32,799.08

Employment · Fee applicant's counsel: Troy Law, PLLC

What happened

Troy Law, PLLC sought $66,004.33 in attorney fees in an employment case. The court reduced the hourly rates for partner-level, paralegal-level, and associate-level work. It also cut 10% of total hours because Tiffany Troy billed clerical tasks, including scanning and verifying a client ID and setting up and downloading video call recordings, at her full hourly rate. The court awarded $33,205.25, a reduction of $32,799.08.

What the court said

Clerical work billed as legal work · 10% reduction
Tiffany Troy engaged in several tasks more appropriate for a paralegal, including scanning and verifying a client ID, and charging her full hourly rate for setting up and downloading recordings of video calls

The court also reduced the award for: hourly rate reduced.

Why it matters

The ruling shows courts will reduce rates and hours when time records mix clerical tasks with legal work and when billing entries do not distinguish between the two. It also confirms that fee awards are calculated using rates the court finds reasonable, not the rates requested.

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

Figueroa v. Mayflower International Hotel Group, Inc, No. 1:23-cv-04729 (E.D.N.Y. May 27, 2026)

See hourly rates the E.D. New York approves and attorney fee motions in New York 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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