Seaport Global Holdings LLC v. Petaquilla Minerals Ltd.
- Edgardo Ramos
- 1:19-cv-09347-ER
- U.S. District Court · Southern District of New York
- 4
In Seaport Global Holdings v. Petaquilla Minerals, Judge Ramos granted Seaport’s motions for arbitration-award interest and $5,010.35 in attorney’s fees and costs.
Seaport Global Holdings LLC received the requested prejudgment interest and $5,010.35 in attorney’s fees and costs after obtaining confirmation of its arbitration award against Petaquilla Minerals Ltd. The billing records supporting the fee request were sealed.
What happened
Seaport Global Holdings LLC asked the court to add interest and attorney’s fees and costs after the court confirmed its arbitration award against Petaquilla Minerals Ltd. The court had previously denied those requests without prejudice and asked Seaport for more documentation.
Seaport requested interest at 9% per year from April 22, 2019, when the final arbitration award was transmitted, through May 27, 2020, when the award was confirmed. It also requested $5,010.35 for attorney’s fees and costs. The court found the requested interest rate and the documented fees and costs reasonable.
Judge Ramos granted Seaport’s renewed motions, directed the clerk to calculate the interest and add the $5,010.35 in fees and costs, granted Seaport’s motion to seal its billing records, and closed the case.
The detailed version
- Seaport Global Holdings LLC v. Petaquilla Minerals Ltd. · No. 1:19-cv-09347-ER
- Edgardo Ramos
- June 23, 2020
Background
Seaport Global Holdings LLC petitioned to confirm an arbitration award against Petaquilla Minerals Ltd. under the Federal Arbitration Act and the New York Convention. Seaport also sought prejudgment interest—interest intended to account for the time value of money—and attorney’s fees and costs related to confirming the award.
On May 27, 2020, the Court confirmed the arbitration award but denied without prejudice Seaport’s requests for prejudgment interest and attorney’s fees and costs. The Court directed Seaport to provide additional documentation. Seaport then filed renewed motions seeking $293,943.98 in prejudgment interest and $5,010.35 in attorney’s fees and costs. Seaport also moved to seal the attorney billing records supporting its request.
Prejudgment Interest
The Court explained that prejudgment interest is generally presumed in the Second Circuit and that courts in the district commonly use a 9% annual rate from the date of an arbitration award through the date the award is confirmed. Seaport requested that rate from April 22, 2019, when the final award was transmitted, through May 27, 2020, when the Court confirmed the award.
The Court found the requested rate consistent with rates regularly awarded in the district and granted Seaport’s request. The Court directed the Clerk to calculate the interest on the final award at 9% per year for that period.
Attorney’s Fees and Costs
The Court had previously found that an award of attorney’s fees was warranted. After reviewing records for 25.3 hours of attorney work at hourly rates ranging from $110 to $325, along with supporting expense records, the Court found the requested fees and costs reasonable. It awarded Seaport $5,010.35 in attorney’s fees and costs.
Disposition
The Court granted Seaport’s renewed motion for prejudgment interest and motion for attorney’s fees and costs. The Court also granted Seaport’s motion to seal the attorney billing records. It directed the Clerk to terminate the motions, add the $5,010.35 award to the calculated interest, and close the case.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.