D. Arizona cuts fee award 21.5%, including for clerical work
G&G Closed Circuit Events LLC v. Diaz et al, No. 2:22-cv-01837. District Court, D. Arizona, Judge Stephen M. McNamee. Decided . Read the opinion
- Requested
- $28,942.25
- Awarded
- $22,731.75
- Cut
- 21.5%$6,210.50
What happened
The fee applicant sought $28,942.25 in attorney fees. The court awarded $22,731.75, a reduction of $6,210.50 or 21.5%. It struck 1 hour from a 1.25-hour pro hac vice motion entry as excessive, and struck several entries for clerical work billed as legal work, including filing and calendar entries. It also struck time for unrelated claims, such as initial disclosures and discovery requests, and a 0.2-hour entry for reviewing an order on a motion to dismiss.
What the court said
The Court will strike lead counsel’s .2-hour, December 12, 2022, entry for the “Review and Filing of the Clerk’s Entry of Default as to Jose O. Diaz and Mariscos El Tiburon (ECF #11).”
The Court will strike lead counsel’s .2-hour entry for the “Preparation, Review, and Filing of the Court’s Agreement to Magistrate Judge Jurisdiction (ECF # 15).”
The Court will strike lead counsel’s .33-hour entry from March 31, 2023, for the “Review, Calendar Data Entry, and Filing of the Court’s Scheduling Order (ECF #26).”
The court also reduced the award for: excessive hours, unrelated claims, unrelated claims, unrelated claims, unrelated claims, other, unrelated claims, unrelated claims.
Why it matters
The ruling shows courts will reduce fee awards when time entries include clerical tasks, excessive hours, or work on unrelated claims. It underscores that fee petitions must separate legal work from administrative tasks and tie billed time to the claims on which the party prevailed.
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
G&G Closed Circuit Events LLC v. Diaz, No. 2:22-cv-01837 (D. Ariz. Feb. 28, 2025) 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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