E.D. New York cuts commercial fee award 40%, including for vague entries
Studio Six Productions, Ltd. v. Sargsyan, No. 1:19-cv-02685. District Court, E.D. New York, Magistrate Judge Marcia M. Henry. Decided . Read the opinion
- Requested
- $69,825
- Recommended
- $41,895
- Cut
- 40%$27,930
Commercial · Contract fee clause
What happened
The fee applicant sought $69,825 for 199.5 hours under a contract fee clause. The magistrate judge recommended awarding $41,895, a reduction of $27,930 or 40%. The court applied a 40% reduction to total hours, citing repetitive and vague time descriptions, excessive hours (including 24 hours for what was likely a short court proceeding), and block billing. The court noted block billing was not the most problematic issue and not the sole basis for the 40% cut.
What the court said
These repetitive and vague descriptions warrant a reduction in hours expended.
However, this practice is not the most problematic aspect of counsel's billing records and is not the sole basis for a 40% reduction in hours.
The court also reduced the award for: excessive hours.
Why it matters
The ruling shows that courts will reduce fee awards when time entries are vague or repetitive, even if block billing alone might not justify the full cut. It also confirms that excessive hours for simple tasks can support a percentage reduction applied to the total request.
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
Studio Six Productions, Ltd. v. Sargsyan, No. 1:19-cv-02685 (E.D.N.Y. Sept. 26, 2024) 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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