Bankr. S.D. New York cuts bankruptcy fee award 51.9%, including for block billing
Reeves v. Reeves et al, No. 1:23-ap-01028. United States Bankruptcy Court, S.D. New York, Judge Martin Glenn. Decided . Read the opinion
- Requested
- $95,028.36
- Awarded
- $45,691.70
- Cut
- 51.9%$49,336.66
Bankruptcy · Sanctions · Fee applicant's counsel: Pryor Cashman LLP
What happened
Pryor Cashman LLP sought $95,028.36 in sanctions fees for 143.9 hours in Reeves v. Reeves. The court excluded time entries that did not sufficiently relate to Count 3, then applied a 50% reduction to the total fee for block billing and failure to apportion time. The court awarded $45,691.70, a reduction of $49,336.66, or 51.9% of the amount requested. The figures do not include costs.
What the court said
Here, the Court concludes that a 50% reduction in fees is appropriate to account for PCLLP's block billing and failure to apportion time.
The court also reduced the award for: unrelated claims, unrelated claims.
Why it matters
The ruling shows that a bankruptcy court will exclude entries tied to unrelated claims and then apply a further percentage cut when block billing prevents it from separating compensable work from noncompensable work. The combined reductions left the applicant with less than half of the fees sought.
How to keep this out of your fee petition
- Record one task per entry, each with its own time.
- Write the entry when the work happens, not at the end of the week.
- If a task really is one unit of work, say what it was and what it produced.
Cite this ruling
Reeves v. Reeves, No. 1:23-ap-01028 (Bankr. S.D.N.Y. Apr. 8, 2024) 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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