E.D. New York cuts consumer protection fee award 20%, including for vague entries
Honigman vs. Kimberly-Clark, No. 2:15-cv-02910. District Court, E.D. New York, Judge Pamela K. Chen. Decided . Read the opinion
- Requested
- $3,961,668.77
- Awarded
- $3,169,335.02
- Cut
- 20%$792,333.75
Consumer protection · Fee applicant's counsel: Robbins Geller Rudman & Dowd LLP
What happened
Robbins Geller Rudman & Dowd LLP, as class counsel, requested $3,961,668.77 in fees for 5,662.88 hours. The court awarded $3,169,335.02, a reduction of $792,333.75. It cited unjustifiably inflated hourly rates, partner-heavy billing, excessive hours, billing of a summer associate, vague entries lacking specificity, and block billing. The court then applied an across-the-board 20% reduction to the fee application.
What the court said
Class Counsel’s billing records contain vague entries that “lack sufficient specificity to enable a court to assess what tasks were completed.”
Class Counsel often engaged in block billing by combining several tasks into a single entry.
The court also reduced the award for: hourly rate reduced, excessive hours, other.
Why it matters
The ruling shows that courts will reduce fee awards when time records lack specificity or combine tasks, and that such recordkeeping problems can support a global percentage cut rather than an entry-by-entry adjustment.
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
Honigman vs. Kimberly-Clark, No. 2:15-cv-02910 (E.D.N.Y. Jan. 17, 2024) 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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