Capital Pure Assets, Ltd. v. CC Technology Corporation, 2:24-cv-00680

CC Technology Corporation (Defendant/Counterclaimant) moved for calculation of sanctions after previously obtaining an order enforcing settlement and awarding sanctions against Capital Pure Assets, Ltd. and associated individuals (Plaintiffs/Counter-Defendants).
The core dispute arose from Counter-Defendants’ refusal to make an initial $14,000 payment as required under the settlement agreement, which the Court had already found constituted a violation.
The motion at issue sought the specific calculation of attorneys’ fees and costs attributable to the motion to enforce settlement.
Plaintiffs objected primarily to the scope of recoverable hours and certain redacted billing entries, as well as to legal research costs that predated the motion.
The Court limited fee recovery to hours and expenses directly caused by the misconduct (the refusal to pay), excluding unrelated or insufficiently supported fees and costs.
The Court awarded $8,682.60 in attorneys’ fees and $845.29 in costs to Defendant, less than the total sought.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriate scope of fee recovery	Fees should be limited to work tied to enforcing the settlement; pre-motion hours shouldn’t qualify.	Fees for efforts to obtain settlement signatures should be recoverable.	Fees limited to work directly resulting from the misconduct (refusal to pay).
Recovery of redacted billing entries	Entries are too vague/redacted to substantiate; should be reduced.	Redactions are privilege-preserving; can submit for in camera review.	Court applied a 20% reduction to these entries due to lack of detail.
Reasonableness of hourly rates	No challenge.	Rates are reasonable for attorneys’ quality and work.	Rates accepted as reasonable under applicable standards.
Recovery of legal research costs	Entries include unrelated pre-motion research; much should be excluded.	Costs should be recoverable as billed.	Court excluded 60% of first entry and 100% of second, awarding only directly related costs.

Mangold v. Cal. Public Utilities Com’n, 67 F.3d 1470 (9th Cir. 1995) (Federal courts in diversity apply state law to attorneys’ fees calculations)
Shuette v. Beazer Homes Holdings Corp., 124 P.3d 530 (Nev. 2005) (Court discretion governs method of reasonable fee determination)
Herbst v. Humana Health Ins. of Nevada, 781 P.2d 762 (Nev. 1989) (Lodestar method is a presumptively reasonable fee calculation)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (Insufficiently supported fee requests may be reduced)
Hornwood v. Smith’s Food King No. 1, 807 P.2d 208 (Nev. 1991) (Factors in fee awards include advocate qualities, work, and outcome)