Gardner-Alfred v. Federal Reserve Bank of New York
- Lewis Liman
- 1:22-cv-01585
- U.S. District Court · Southern District of New York
- 2
In Gardner-Alfred v. Federal Reserve Bank, Judge Liman granted the fee request in part and denied it in part, awarding $53,808.
The Federal Reserve Bank of New York, Lori Gardner-Alfred and Jeanette Diaz, and the plaintiffs’ counsel were affected by the fee ruling. The defendant received $53,808 in fees and costs, and plaintiffs’ counsel was ordered to pay $2,400 without offset to the plaintiffs.
What happened
In Gardner-Alfred v. Federal Reserve Bank of New York, the court considered the defendant’s request for $71,574 in attorneys’ fees and costs after an earlier sanctions order concerning discovery disputes.
The court reduced the hours billed for one sanctions motion by 30% because the defendant had billed more than 130 hours without detailed time records. It approved the rest of the request, including previously approved billing rates and other reasonable estimates.
Judge Liman granted the fee request in part and denied it in part. The defendant was entitled to $53,808 in fees and costs, including $2,400 to be paid by the plaintiffs’ counsel without reducing the plaintiffs’ obligation.
The detailed version
- Gardner-Alfred v. Federal Reserve Bank of New York · No. 1:22-cv-01585
- Lewis Liman
- July 13, 2023
Background
In an earlier order, the court granted in part and denied in part the Federal Reserve Bank of New York’s motion for sanctions. The court held that the defendant could recover reasonable expenses and attorneys’ fees connected with: (1) the April 19, 2023 motion for discovery sanctions; (2) calls and emails with opposing counsel from March 21 through the relevant period about the plaintiffs’ discovery deficiencies; and (3) the February 27, 2023 motion to compel. The court directed the defendant to submit a fee application.
Fee Application
The defendant submitted a declaration requesting $71,574 in attorneys’ fees and costs. The court found that the defendant had billed more than 130 hours for the April 19 sanctions motion. Because the defendant did not provide detailed time records for that motion, the court determined that the number of hours likely reflected inefficient billing and reduced those hours by 30 percent.
The court approved the remainder of the request. It noted that the defendant had already reduced attorney time for February 21 through February 27 by 30 percent, used attorney and paralegal rates previously approved by the court, and provided otherwise reasonable fee estimates.
Ruling
Judge Liman granted in part and denied in part the request for attorneys’ fees and costs. The Federal Reserve Bank of New York was entitled to $53,808 in attorneys’ fees and costs. Of that amount, $2,400 was to be paid by the plaintiffs’ counsel without offset to the plaintiffs.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.