D. Puerto Rico cuts fee award 44.7%, including for vague entries

What happened

Defendants sought $10,830 in sanctions fees for 25.6 hours. The court awarded $5,987, a reduction of $4,843. It reduced a subset of entries by 30% because some hours were excessive or too generic or vague to assess. It reduced another subset by 50% because some hours involved secretarial tasks that should be reimbursed at a lower rate, comparable to paralegal rates in the District. The court also set hourly rates for three timekeepers.

What the court said

the Court concludes that some of the hours for which Defendants seek fees are excessive or are too generic or vague for the Court to assess whether the time billed was appropriate. The Court will reduce the following entries by 30 percent.

the Court concludes that some of the hours for which Defendants seek fees involve secretarial tasks that ought to be reimbursed at a lower rate, comparable to what paralegals are afforded in this District. The Court will reduce following entries by 50 percent.

The court also reduced the award for: hourly rate reduced.

Why it matters

The ruling shows that a fee petition can lose substantial value when entries are too generic to assess and when clerical tasks are billed at attorney rates. Courts will cut those entries by percentages rather than parse each one, so the specificity of time records directly affects the amount recovered.

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

See hourly rates the D. Puerto Rico approves.

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