Deborah Malloy v. Trileaf Corporation, et al.

Summary

The United States District Court for the Eastern District of Missouri directs defendants to file an amended verified statement of attorney’s fees incurred as sanctions for plaintiff’s discovery misconduct. The court finds the existing fee submission insufficient because it does not identify billing rates, personnel roles, or explain inconsistent billing entries. The order sets deadlines for defendants’ amended submission and plaintiff’s responses.

Holdings

1. The submitted declaration and fee statement were insufficient to permit the court to determine a reasonable attorney's fee because they did not adequately identify the timekeepers and their roles, state the applicable hourly rates, or explain discrepancies in the rates charged.
2. Defendants were required to file within seven days an amended verified statement containing sufficient, complete, and accurate information from which the court could calculate a reasonable attorney's fee; fees incurred preparing the amended statement could not be included in the fee request.

Questions Presented

1. Whether defendants' submitted declaration and fee statement provided sufficient information for the court to determine a reasonable attorney's-fee award imposed as a sanction.
2. What additional fee documentation defendants must submit before the court can calculate a reasonable sanctioned fee.

Disposition

other