Cohen v. Brown University

2003 DNH 112
CourtDistrict Court, D. New Hampshire
DecidedJune 27, 2003
DocketCV-99-485-B
StatusPublished
Cited by1 cases

This text of 2003 DNH 112 (Cohen v. Brown University) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cohen v. Brown University, 2003 DNH 112 (D.N.H. 2003).

Opinion

Cohen v . Brown University CV-99-485-B 06/27/03

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Amy Cohen, et a l .

v. Civil N o . 99-485-B Opinion N o . 2003 DNH 112 Brown University, et a l .

MEMORANDUM AND ORDER

Pending before me is defendants’ objection to the April 2 ,

2003 Report and Recommendation of Magistrate Judge David L .

Martin (“Report and Recommendation”) granting, in large part,

Plaintiffs’ Supplemental Motion for Attorneys’ Fees and Expenses.

See Cohen v . Brown Univ., N.H. Civ. Action N o . 99-485-B (Doc. N o .

2 3 ) , R.I. Civil Action N o . 92-197 (D.R.I. April 2 , 2003) (Doc.

No. 344). Plaintiffs prevailed in their underlying Title IX

litigation and received attorneys’ fees and expenses for

litigating the merits of their Title IX claim. See Report and

Recommendation, August 1 0 , 2001 (Martin, M . J . ) , accepted but modified in part by Memorandum and Order, December 5 , 2001

(Barbadoro, C . J . ) .

Pursuant to Fed. R. Civ. P. 72(b), I review the Magistrate

Judge’s Report and Recommendation de novo because I am required

to treat a motion for attorneys’ fees as I would a “dispositive

pretrial matter.” Fed. R. Civ. P. 54(d)(2)(D). I am free to

“accept, reject, or modify, the recommended decision, receive

further evidence, or recommit the matter to the magistrate judge

with instructions.” Fed. R. Civ. P. 72(b).

Defendants raise four objections to the Report and

Recommendation. They argue that the Magistrate Judge erred i n :

(1) concluding that the Supplemental Fee Motion was timely

pursuant to Fed. R. Civ. P. 54(d)(2); (2) granting fees to

special fee counsel despite finding their retention by plaintiffs

was not “reasonably necessary;” (3) granting fees relating to a

protective order and discovery of defendants’ billing records;

and (4) failing to adequately reduce fees for certain redundant

and unnecessary work.

-2- I. Timeliness of Supplemental Motion1

I agree with the Magistrate Judge that defendants’

timeliness objection is without merit. Defendants argue that the

Magistrate Judge misconstrued Fed. R. Civ. P. 54(d)(2)’s

timetable for filing a supplemental fee petition. Rule

54(d)(2)(B) provides that a motion for attorneys’ fees and

related expenses must be filed no later than 14 days after entry

of judgment. Relying on Tennessee Gas Pipeline v . 104 Acres of

Land, 32 F.3d 632 (1st Cir. 1994), however, defendants argue that

plaintiffs should have submitted their supplemental motion for

attorneys’ fees and expenses prior to the determination of the

motion for attorneys’ fees for the underlying litigation. In

Tennessee Gas, the First Circuit stated that there should be

“some time limit within which a party must file an application

for supplemental fees and. . . it is reasonable to require. . .

that where possible, such application be made before the court

acts on the principal fee application.” Id. at 635. The

defendants in Tennessee Gas submitted their application for

1 The background underlying plaintiffs’ motion is set forth in great detail in the Magistrate Judge’s Report & Recommendation.

-3- supplemental fees before the 1993 Amendment to Rule 54(d) created

a timetable for the submission of a claim for attorneys’ fees. I

agree with the Magistrate Judge that the First Circuit’s concern

in Tennessee Gas appears to be with the lack of a time limit for

the filing of a supplemental application. As the 1993 Amendment

to Fed. R. Civ. P. 54(d)(2) created exactly that, I find the

quoted language from Tennessee Gas unpersuasive on this point.

In addition, I do not see the efficiency or logic in requiring

prevailing plaintiffs to supplement their fee applications

requesting “fees on fees” before they know if they are successful

in their principal motion for attorneys’ fees.

I find, as did the Magistrate Judge, that the plaintiffs

filed their supplemental motion within the permissible time

period set forth in Rule 54(d). Plaintiffs filed their

supplemental motion on February 2 8 , 2002, prior to the March 2 5 ,

2002, final judgment on their underlying motion for merits fees.

(Doc. N o . 2 2 ) . In addition, defendants’ argument that they were

“unfair[ly] surprise[d] and prejudice[d]” relying on White v . New

Hampshire Dep’t of Employment Security, 455 U.S. 445, 454 (1982),

is unpersuasive. Defendants’ “surprise” is in the fee amount

sought and not in the actual filing of the supplemental motion.

-4- As the Magistrate Judge correctly found, that is not the kind of

surprise that warrants the label “unfair.” See Report and

Recommendation at 7-8.

11. Special Fee Counsel

Plaintiffs retained Steptoe & Johnson (“Steptoe”), a law

firm based in Washington D.C., as special fee counsel. The

Magistrate Judge rejected plaintiffs' argument that the retention

of special fee counsel was reasonable because of Defendant's

"multitude of challenges" and found that plaintiffs "failed to

demonstrate that it was reasonably necessary for them to engage

special fee counsel, especially out-of-state fee counsel whose

usual hourly rates greatly exceed the hourly rate of the lead

counsel in the underlying action." Report and Recommendation at

12. Despite this finding, the Magistrate Judge awarded

attorneys' fees to Steptoe at the Rhode Island rate reduced by

ten percent for redundancy and inefficiencies.

I agree with the Magistrate Judge’s conclusion that the

retention of special fee counsel was not “reasonably necessary.”

Moreover, after reviewing plaintiffs’ billing records, it is

clear that the addition of another set of attorneys into an

-5- already large group of merits attorneys created great

inefficiency. For example, Attorney Leslie A . Brueckner, for

whom the Magistrate Judge permitted 173.4 hours totaling over

$43,000 dollars, billed for reviewing and revising Steptoe’s

analysis and several telephone calls with Steptoe attorneys. The

same is true for Tracy L . Hilmer, an attorney for Steptoe.

Hilmer billed for numerous conference calls with merits counsel

and charged for the editing of merits counsel’s affidavits and

time records. Although I do not question the value of conference

calls amongst co-counsel, it is clear that the addition of

another set of attorneys to confer with and to edit one another’s

work product inevitably created an additional layer of

consultation and review that was entirely unnecessary.

In sum, I agree with the Magistrate Judge that the retention

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Frost et al v. Town of Hampton et al
2010 DNH 072 (D. New Hampshire, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
2003 DNH 112, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cohen-v-brown-university-nhd-2003.