StoneX Group Inc. v. shipman, 1:23-cv-00613

Plaintiffs StoneX Group Inc. and StoneX Financial Inc. ("Plaintiffs") sought attorney's fees after prevailing on a motion for spoliation sanctions against Defendant Howard Shipman, who proceeded pro se.
Plaintiffs alleged Shipman intentionally destroyed electronically stored information (ESI) to conceal the theft of proprietary source code, in violation of his preservation obligations.
The Court had previously granted Plaintiffs' motion for sanctions, entered default judgment against Shipman, and ordered fee-shifting for costs associated with litigating the sanctions motion.
Plaintiffs moved for $436,047.57 in attorney's fees for the sanctions motion, submitting detailed time records for hours billed by their counsel at Proskauer Rose LLP.
Shipman objected, arguing the requested fees were excessive, included work unrelated to the sanctions motion, involved block billing, and overstaffing.
The Magistrate Judge conducted a lodestar analysis and found hours and rates excessive in several respects, reducing the final award to $152,812.19.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonableness of Rates	Requested rates are discounted and reasonable for complex commercial litigation by a major NY firm	Did not object to rates but implicitly challenged through reasonableness of overall fee request	Court reduced rates for junior attorneys and paralegals to align with community standards
Hours Expended	Hours claimed are necessary due to complexity and Defendant's conduct; voluntary reductions already made	Claimed hours include unrelated, excessive, block-billed, and redundant work	Court found hours facially excessive, with redundant and unrelated tasks, warranting 65% reduction
Block Billing and Mixed Work	Voluntary reductions made to contested time entries; block billing justified in this context	Block billing obscures whether work relates to sanctions, leading to overbilling	Court found block billing and inclusion of unrelated tasks justified across-the-board reduction
Staffing Levels	Senior attorney involvement appropriate for case complexity and Plaintiff interests	Case overstaffed, with excessive senior attorney participation despite pro se defendant	Court agreed matter was overstaffed and this justified reduction in award

Arbor Hill Concerned Citizens Neighborhood Ass’n v. County of Albany, 493 F.3d 110 (2d Cir. 2007) (establishes lodestar method for attorney’s fee calculations)
Reiter v. MTA N.Y.C. Transit Auth., 457 F.3d 224 (2d Cir. 2006) (reasonable hourly rate tied to prevailing rates in the community)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (addresses the standard for determining reasonable attorney’s fees)
Lunday v. City of Albany, 42 F.3d 131 (2d Cir. 1994) (detailed scrutiny of hours expended required in fee assessments)
Kirsch v. Fleet St., Ltd., 148 F.3d 149 (2d Cir. 1998) (block billing and excessive hours justify across-the-board reductions)
Grant v. Martinez, 973 F.2d 96 (2d Cir. 1992) (guidance on determining excessive or redundant hours in fee shifting)