Knight MPIC Ventures, LLC v. Higginson
- Lorna Schofield
- 1:18-cv-08126
- U.S. District Court · Southern District of New York
- 3
In Knight MPIC Ventures v. Higginson, Judge Schofield adopted a fee recommendation, granted the motion in part, and entered judgment for $3.5 million plus interest.
The plaintiffs received $385,953.45 in attorneys’ fees and a judgment for $3,500,000 plus federal statutory interest. The defendant was subject to that judgment.
What happened
In Knight MPIC Ventures, LLC v. Higginson, the court had already granted the plaintiffs’ summary-judgment motion and found the defendant liable for $3,500,000 in unpaid principal, with costs and fees to be decided later.
The plaintiffs requested $385,953.45 in attorneys’ fees and interest, and also sought to use the parties’ contractual interest rates. They later waived the contractual-interest request and asked for federal statutory interest instead. A magistrate judge recommended awarding the requested attorneys’ fees and denying the interest request as originally made.
Judge Lorna G. Schofield found no clear error, adopted the recommendation in its entirety, granted the plaintiffs’ fee motion in part, awarded $385,953.45 in attorneys’ fees, and ordered judgment for $3,500,000 plus federal statutory interest and those fees. The court directed the Clerk to enter judgment and close the case.
The detailed version
- Knight MPIC Ventures, LLC v. Higginson · No. 1:18-cv-08126
- Lorna Schofield
- Aug. 31, 2020
Background
On February 4, 2020, the court granted the plaintiffs’ motion for summary judgment under Rule 56 of the Federal Rules of Civil Procedure. The court found the defendant liable for $3,500,000 in unpaid principal and left the amount of reasonable costs and attorneys’ fees for later determination.
The plaintiffs then moved for $385,953.45 in attorneys’ fees and sought interest on the summary-judgment award at 13%. They also asked the court to apply the parties’ pre- and post-contractual interest rates instead of the federal statutory post-judgment interest rate. The opinion states that the plaintiffs had not raised the contractual-interest request in their summary-judgment motion.
The court later required the plaintiffs to explain the basis for seeking a nonfederal interest rate and why the request had not been waived. The court asked Magistrate Judge Fox to address the attorneys’ fee motion but exclude the request for additional interest. On August 12, 2020, Judge Fox recommended granting the fee motion in part and awarding $385,953.45 in attorneys’ fees. The recommendation denied the portion of the motion seeking interest. No timely objections were filed.
Ruling
A district judge may accept, reject, or modify a magistrate judge’s report and recommendation. When no timely objection is filed, the district judge reviews the recommendation for clear error on the face of the record. Judge Schofield found no clear error and adopted Judge Fox’s report and recommendation in its entirety.
The court ordered that the plaintiffs’ motion be granted in part and awarded them $385,953.45 in reasonable attorneys’ fees. The plaintiffs had agreed to waive their claim for the parties’ contractual interest rate and requested judgment for the $3,500,000 principal amount, federal statutory interest, and attorneys’ fees.
The court ordered entry of judgment for the plaintiffs in the amount of $3,500,000 plus federal statutory interest and $385,953.45 in attorneys’ fees. It directed the Clerk of Court to enter judgment and close the case.
Effect
The plaintiffs received the attorneys’ fee award and a judgment for the unpaid principal, federal statutory interest, and fees. The order did not award the contractual interest rate requested earlier; the plaintiffs had waived that claim. The opinion does not state that the fee motion or case was dismissed with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.