Citigroup Inc. v. Seade
- John Cronan
- 1:21-cv-10413
- U.S. District Court · Southern District of New York
- 4
In Citigroup v. Seade, Judge Cronan approved $29,270.47 in contempt-related fees and costs but denied a conference request.
Citigroup received approval to recover $29,270.47 in attorneys’ fees and costs under the prior contempt order. Luis Sebastian Sayeg Seade was the respondent subject to that reimbursement obligation, and Citigroup was required to file a status letter and serve this order.
What happened
In Citigroup Inc. v. Seade, the court considered Citigroup’s request for reimbursement after previously finding Luis Sebastian Sayeg Seade in contempt for violating a preliminary injunction. Citigroup requested $29,560.47 in attorneys’ fees and costs.
The court approved the lawyers’ hourly rates and the 48.2 hours billed, but reduced the paralegal rate to $150 per hour. It approved $28,875 in fees and $395.47 in costs, for a total of $29,270.47. The court also denied Citigroup’s request for a conference about possible additional contempt sanctions.
Judge Cronan ordered Citigroup to file a status letter by April 1, 2022, addressing the Mexican case, compliance with the court’s orders, and whether Citigroup would seek additional sanctions. Citigroup also had to serve the order on Sayeg and file proof of service.
The detailed version
- Citigroup Inc. v. Seade · No. 1:21-cv-10413
- John Cronan
- Mar. 15, 2022
Background
On February 28, 2022, the Court held Respondent Luis Sebastian Sayeg Seade in contempt for violating a preliminary injunction. The contempt order required him to reimburse Citigroup for reasonable attorneys’ fees and costs incurred in bringing the contempt motion. It also required Citigroup to submit documentation supporting the requested amount.
Citigroup submitted documentation seeking $29,560.47: $29,165.00 in attorneys’ fees and $395.47 in costs.
Fee Analysis
The Court calculated the presumptively reasonable fee by multiplying reasonable hourly rates by reasonably expended hours. It approved Pillsbury Winthrop Shaw Pittman LLP’s requested rates of $840 per hour for partner Robert L. Sills and $480 per hour for associate Ryan R. Adelsperger. The Court found those rates reasonable in light of comparable rates in the Southern District of New York and the discounted rates Citigroup agreed to pay.
The Court found that the requested $250 hourly rate for paralegal work was too high, particularly because Citigroup provided no background information about the paralegal’s credentials and experience. The Court reduced that rate to $150 per hour.
The Court found the hours billed reasonable. It approved Pillsbury’s 48.2 total hours spent investigating and pursuing the contempt motion, noting that the firm used two lawyers, assigned many tasks to an associate, and submitted a detailed memorandum and supporting affidavit.
Ruling
After reducing the paralegal rate, the Court approved $28,875 in attorneys’ fees. It also approved $395.47 in costs for computer research and Federal Express charges for court-ordered service. The total approved amount was $29,270.47.
Citigroup also requested a conference to discuss another application for contempt sanctions or an order allowing it to seek additional sanctions. The Court denied that request because the contempt order contemplated that Citigroup would wait only a few weeks, until April 2, before seeking additional sanctions.
The Court ordered Citigroup to file a status letter by April 1, 2022, describing the status of the Mexican Action, whether Sayeg had complied with the Court’s orders, and, if not, whether Citigroup intended to seek additional contempt sanctions. Citigroup had to serve the order on Sayeg by March 18, 2022, and file proof of service by March 21, 2022.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.