N.D. Texas cuts fee award 33%, including for vague entries
Joe Hand Promotions, Inc. v. Allure Jazz & Cigars, LLC et al, No. 3:22-cv-00514. District Court, N.D. Texas, Magistrate Judge Renée Harris Toliver. Decided . Read the opinion
- Requested
- $4,950
- Recommended
- $3,317.50
- Cut
- 33%$1,632.50
What happened
The fee applicant sought $4,950 for 19.8 hours. The magistrate judge recommended awarding $3,317.50 for 13.27 hours, a reduction of $1,632.50 or 33%. The court excluded 2.8 hours that duplicated earlier entries already compensated. It also found time entries too vague to apportion among defendants, citing descriptions such as email correspondence with counsel, review file, and prepare report, and reduced work done for additional defendants to reflect work for Allure alone.
What the court said
Ms. King's time entries include descriptions of work done such as "Email correspondence with counsel," "Review file," "Prepare report" and others that cannot be apportioned appropriately per defendant.
The court also reduced the award for: duplicative staffing, unrelated claims.
Why it matters
The ruling shows that a fee petition can be cut even at a modest size when entries do not identify the defendant or task with enough specificity to divide the work, and when billed time repeats earlier entries. Courts will reduce rather than guess at an appropriate allocation.
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
Joe Hand Promotions, Inc. v. Allure Jazz & Cigars, LLC, No. 3:22-cv-00514 (N.D. Tex. Aug. 23, 2024) See hourly rates the N.D. Texas approves and attorney fee motions in Texas 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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