E.D. Pennsylvania cuts commercial fee award over missing contemporaneous records

What happened

The fee applicant sought fees for 13 hours of work in a commercial case. The court reviewed the invoice and found it substantiated only 5 hours: one hour on October 24, three hours on November 12, and one hour on December 7. It therefore reduced the request by 8 hours, awarding fees for 5 hours. The court did not state dollar totals, and the figures do not include costs.

What the court said

But the invoice provided only substantiates five hours – one hour on October 24, three hours on November 12, and one hour on December 7.

Why it matters

The ruling shows that a fee petition must be supported by records that tie each claimed hour to specific work on specific dates. Where the invoice substantiated only part of the time, the court awarded only that part, leaving the applicant to bear the consequence of the unsupported hours.

How to keep this out of your fee petition

• Record time the same day the work happens.
• Keep the original records, not only a cleaned-up summary.
• Be able to show when each entry was created.

Cite this ruling

See hourly rates the E.D. Pennsylvania approves and attorney fee motions in Pennsylvania federal courts.

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