D. Colorado cuts fee award 36.1%, including for vague entries

What happened

LaszloLaw sought $36,949.50 in fees. The magistrate judge recommended awarding $23,623.50, a $13,326 reduction. The court deducted $2,883 for 6.2 hours spent drafting the reply, $1,501.50 for 3.9 hours on the fee motion, and $2,464.50 for Attorney M. Laszlo's entries from March 30 through April 12, 2024, except two on April 8. It also deducted $9,162.50 for 24.6 hours labeled Receive/Review Docket Entry, finding the entries vague and unexplained.

What the court said

Because Mr. Zavodnick’s briefing fails to explain what the “Receive/Review Docket Entry” line-items are for, and because the billing entries are so vague, the Court finds that all time labeled as “Receive/Review Docket Entry” should be deducted.

The court also reduced the award for: fees on fees, fees on fees, fees on fees.

Why it matters

The ruling shows that time records must describe the work performed, not just the task category. Entries labeled only as reviewing docket activity were disallowed in full, and time spent litigating the fee request itself was also 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 D. Colorado approves and attorney fee motions in Colorado federal courts.

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