M.D. Tennessee cuts intellectual property fee award 12%, including for vague entries
Livingston v. Jay Livingston Music, Inc., et al., No. 3:22-cv-00532. District Court, M.D. Tennessee, Judge Waverly D. Crenshaw, Jr.. Decided . Read the opinion
- Requested
- $385,979.05
- Awarded
- $339,661.56
- Cut
- 12%$46,317.49
Intellectual property · Fee applicant's counsel: Loeb & Loeb LLP
What happened
Loeb & Loeb LLP, counsel for the fee applicant, requested $385,979.05 in attorney fees. The court awarded $339,661.56, a reduction of $46,317.49 or 12.0%. The court applied a single 12.0% reduction to the total fee for three reasons: some entries reflected extensive overlap in attorney review among attorneys from both firms; other entries were too vague for the court to assess; and the defendants' response did not establish the connection between prelawsuit estate work and this litigation or explain redacted and otherwise unclear charges.
What the court said
Other entries are too vague for the Court to assess.
The court also reduced the award for: duplicative staffing, other.
Why it matters
The ruling shows that a court may apply a single percentage cut to the total fee when time records contain vague entries, duplicative staffing, and unclear charges, rather than adjusting individual line items. It also shows that a fee applicant must explain how redacted or unclear charges relate to the litigation.
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
Livingston v. Jay Livingston Music, Inc., No. 3:22-cv-00532 (M.D. Tenn. Mar. 2, 2026) See hourly rates the M.D. Tennessee approves and attorney fee motions in Tennessee 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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