Griffen Security, LLC v. Thompson
- Vernon Broderick
- 1:19-cv-03494
- U.S. District Court · Southern District of New York
- 1
In Griffen Security v. Citadel Car Alarms, Magistrate Judge Gorenstein gave Griffen more time to support its attorney-fee request.
Griffen Security, LLC must provide additional support for its attorney-fee request and serve the order on Citadel Car Alarms, LLC; Citadel may respond.
What happened
In Griffen Security, LLC v. Citadel Car Alarms, LLC, Griffen submitted a request for attorney fees supported by invoices and affidavits.
The court explained that fee requests must be supported by records made when the legal work was performed, or evidence that submitted invoices are based on those records. Griffen had not provided that evidence.
Magistrate Judge Gabriel W. Gorenstein gave Griffen until April 17, 2020, to provide the required records or supporting evidence. Citadel could respond by April 24, and Griffen had to serve the order and provide proof of service by April 17.
The detailed version
- Griffen Security, LLC v. Thompson · No. 1:19-cv-03494
- Vernon Broderick
- Apr. 10, 2020
Background
Griffen Security, LLC filed a statement of damages and affidavits supporting its request for attorney fees. It submitted invoices, but the court found that Griffen had not supplied evidence showing that the invoices were based on contemporaneous time records—records created as the legal work was performed.
Court’s reasoning
The court stated that an attorney-fee application must be supported by contemporaneous time records. It also explained that reconstructions or invoices based on those records can be acceptable, but Griffen had not shown that its invoices met that requirement. Without that evidence, the court stated that attorney fees could not be awarded.
Order
The court, acting on its own, granted Griffen until April 17, 2020, to provide either contemporaneous time records or evidence that the invoices already submitted were based on such records. Citadel could respond by April 24, 2020. Griffen was also ordered to serve a copy of the order on Citadel at its last known address and provide proof of service by April 17, 2020. The order did not award attorney fees at this stage.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.