E.D. California cuts commercial fee award 71.4%, including for block billing | LegalTime AI

E.D. California cuts commercial fee award 71.4%, including for block billing

Vlad Malenko (USA) LLC v. Shvartsman et al, No. 2:24-cv-00121. District Court, E.D. California, Judge Dale A. Drozd. Decided . Read the opinion

Requested
$25,555
Awarded
$7,312
Cut
71.4%$18,243

Commercial

What happened

The fee applicant sought $25,555 in fees. The court awarded $7,312, a reduction of $18,243. It cut one timekeeper's requested 45.2 hours by 70% as excessive for a straightforward default judgment motion, applied a 20% reduction to that timekeeper for block billing, and reduced the hourly rates for Mr. Brooks and Ms. Kostoreva.

What the court said

Block billing · 20% reduction
Counsel in this case provided a block bill, warranting a 20% reduction.

The court also reduced the award for: excessive hours, hourly rate reduced.

Why it matters

The ruling shows that courts will reduce hours billed on a straightforward motion and will apply a separate percentage cut when time entries are block billed, even where the overall award is already reduced for other reasons.

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

Vlad Malenko (USA) LLC v. Shvartsman, No. 2:24-cv-00121 (E.D. Cal. Jan. 21, 2025)

See hourly rates the E.D. California approves and attorney fee motions in California 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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