D. New Jersey cuts fee award 60%, including for block billing

What happened

The fee applicant sought $121,186 in sanctions fees for 153.4 hours. Judge Rukhsanah L. Singh awarded $48,540, a reduction of $72,646 or 60%. The court set reasonable hourly rates for each timekeeper. It cut 3.0 hours because Mr. Quaratino block-billed a December 16, 2024 entry, making recoverable work impossible to separate. It also reduced time for entries tied to confusion over the Clerk's Office's electronic filing settings, for excessive hours, and for other excessive time.

What the court said

Because Mr. Quaratino block-billed the December 16, 2024 entry, the Court cannot parse out how much of the 2.5 hours was for recoverable work and how much was not.

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

Why it matters

The ruling shows that a block-billed entry can cost the applicant the whole entry when the court cannot separate recoverable from nonrecoverable work. It also shows courts will set their own hourly rates and trim hours they find excessive, so the requested lodestar is only a starting point.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the D. New Jersey approves and attorney fee motions in New Jersey federal courts.

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