E.D. New York cuts commercial fee award, including for missing contemporaneous records
JTH Tax LLC v. Kukla et al, No. 2:22-cv-01542. District Court, E.D. New York, Judge Joanna Seybert. Decided . Read the opinion
The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.
Commercial · Fee applicant's counsel: Gordon Rees Scully Mansukhani, LLP
What happened
Gordon Rees Scully Mansukhani, LLP sought attorney fees in a commercial case. The court declined to award fees for the default judgment motion and deducted 50% of the hours sought from those entries, a $7,435.03 reduction. It then reduced the total fee by 15% for partner-heavy staffing and by another 15% because the records did not itemize how many cumulative hours each attorney billed, which the court said hindered its reasonable hours analysis. The court did not state total amounts.
What the court said
failure to itemize how many cumulative hours each respective attorney billed stymied the Court’s “reasonable hours” analysis.
The court also reduced the award for: unrelated claims, duplicative staffing.
Why it matters
The ruling shows that a fee petition can be cut even when the requested totals are not stated, and that a lack of attorney-by-attorney hour detail can independently reduce the award. Courts treat missing contemporaneous records as a distinct basis for reduction, separate from staffing or claim-related issues.
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
JTH Tax LLC v. Kukla, No. 2:22-cv-01542 (E.D.N.Y. Oct. 28, 2025) 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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