Shawn D. Privratsky v. Liberty Mutual Fire Insurance Company

District Court, D. Hawaii·Decided August 11, 2026·No. 1:21-cv-00390·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAI‘I SHAWN D. PRIVRATSKY, Case No. 21-cv-00390-DKW-RT

ORDER (1) GRANTING Plaintiff, DEFENDANT’S REQUEST TO PROCEED, (2) OVERRULING IN PART AND SUSTAINING IN PART v. PLAINTIFF’S OBJECTIONS TO AMENDED FINDINGS & RECOMMENDATION (F&R) OF LIBERTY MUTUAL FIRE U.S. MAGISTRATE JUDGE, (3) INSURANCE COMPANY, SUSTAINING DEFENDANT’S OBJECTION TO THE F&R, (4) ADOPTING IN PART AND Defendant. OVERRULING IN PART THE F&R, AND (5) GRANTING DEFENDANT’S MOTION FOR ATTORNEY’S FEES TO THE EXTENT SET FORTH HEREIN

The Court paused the proceedings in this long-running case that was tried to a jury verdict in June 2023. The Court did so—with Defendant Liberty Mutual Fire Insurance Company’s attorneys’ fees motion pending—to allow time for the parties to mediate their many disputes before the Mediation Office of the Court of Appeals for the Ninth Circuit. In early 2026, the hiatus appeared to have been warranted, with Liberty reporting a “settlement in principle” arising out of the Circuit’s mediation efforts.

The report though seems to have been premature. Privratsky denies any deal had been reached, resulting in the parties being “released” from the Ninth Circuit’s mediation program, and the appellate court directing merits briefing. Because the

basis for this Court’s pause—mediation—no longer exists, the Court VACATES its abeyance order and proceeds with consideration of Liberty’s fees motion. The parties dispute many things small and not-so-small concerning Liberty’s fees motion. Resolving three of these disputes, however, principally resolves the

parties’ disagreements, as explained more fully below. First, pursuant to Hawai‘i Revised Statutes (HRS) Section 607-14, this action was and is in the nature of assumpsit and, thus, Liberty is entitled to an award of attorneys’ fees as the jury’s

prevailing party. Second, pursuant to Section 607-14, Liberty is entitled to up to 25 percent of the “amount sued for”, an amount which here equals $1,470,099.67, resulting in a maximum possible fee award of $367,524.91. Third, the record evidence found persuasive by this Court reflects that Liberty incurred more than

$400,000 in litigating Count 1—a claim the Court has already found is in the nature of assumpsit—which is an amount in excess of the maximum possible fee award. When combined, these three findings mean that Liberty is entitled to a fee

2 award of $367,524.91. Liberty’s motion for attorney’s fees, Dkt. No. 385, therefore, is GRANTED to that extent.

RELEVANT PROCEDURAL BACKGROUND1 On April 25, 2024, the Court, inter alia, remanded Liberty’s motion for attorney’s fees (fees motion) to the assigned Magistrate Judge for further

consideration of certain issues (April 2024 Order). Dkt. No. 412. Specifically, the Court remanded the following two issues: (1) whether this case was in the nature of assumpsit, and (2) if so, whether Counts 1 and 2 of the Complaint were inextricably intertwined. Id. at 8-10. The Court also declined to address various

objections raised by both parties in the event they were altered by the remanded- issues mentioned above, but observed that they could be re-asserted, if appropriate. Id. at 7 n.5, 10.

On February 14, 2025, the Magistrate Judge entered an Amended Findings and Recommendation on the fees motion (F&R). Dkt. No. 414. In particular, the Magistrate Judge recommended granting and denying in part the fees motion to the extent of awarding Liberty a total of $308,358.25 in attorney’s fees. Id. at 2, 22.

The Magistrate Judge made the following relevant findings in that regard. First,

1Further relevant background can be found in the April 25, 2024 Order summarized below. Dkt. No. 412 at 2-5.

3 the Magistrate Judge found that Count 1 of the Complaint was in the nature of assumpsit. Id. at 9-12. Second, the Magistrate Judge found that certain fees

could be apportioned between assumpsit and non-assumpsit claims, with such fees for non-assumpsit claims being deducted from the amount to which Liberty was entitled. Id. at 13-18. This resulted in a total fees amount for Count 1, the

assumpsit claim, of $1,488,840.00. Id. at 18. Third, the Magistrate Judge found, after determining reasonable hourly rates for the numerous attorneys and paralegals engaged by Liberty, that the total fees incurred were $1,470,450.00. Id. at 18-20. Fourth, after making deductions for reasons such as duplicative billing

entries and block-billing, the Magistrate Judge reduced the total fees, or “lodestar”, amount to $955,498.41. Id. at 20-21. Fifth, the Magistrate Judge explained that, pursuant to HRS Section 607-14, Liberty was entitled to fees not exceeding 25

percent “of the amount sued for.” Id. at 7. In that regard, the Magistrate Judge found that Privratsky sought “$1,233,433.00 in policy benefits during trial[]”, with 25 percent of this amount being $308,358.25. Id. at 22. As a result, because the “statutory cap”—$308,358.25—was exceeded by the “lodestar” amount—

$955,498.41—the Magistrate Judge found that Liberty was entitled to the lower, former amount, and recommended granting the fees motion to that extent. Id.

4 Both Privratsky and Liberty filed objections to the F&R. Dkt. Nos. 416, 417. Privratsky objected on the following grounds. First, Privratsky argued this

action was not in the nature of assumpsit. Dkt. No. 416 at 2-11. Second, Privratsky argued that the Magistrate Judge erred in apportioning fees between assumpsit and non-assumpsit claims. Id. at 11-13. In particular, Privratsky

argued that, “at most,” $231,185.00 was “even arguably related” to Count 1. Id. at 12. Third, Privratsky argued that Liberty’s fees should have been reduced by 35 percent for “excessive and duplicative billing”, as opposed to the 10 percent reduction used in the F&R. Id. at 13-16. Fourth, even though the Magistrate

Judge recommended denying the fees motion to the extent “non-taxable costs” were sought, Privratsky objected to the extent that the Magistrate Judge made this recommendation solely due to the statutory cap. Id. at 16. Finally, Privratsky

objected to the Magistrate Judge not excluding time and fees incurred on “self- imposed” or “avoid[able]” matters. Id. at 17-18. Liberty objected to the F&R on one ground. Dkt. No. 417. Specifically, Liberty argued that, in calculating the “amount sued for” under Section 607-14, the

Magistrate Judge erred in failing to include $233,666.67 in “loss of use damages” allegedly sought in connection with Count 1. Dkt. No. 417-1 at 1. Liberty asserted that, with the inclusion of the above-mentioned amount, the “amount sued

5 for” should have been $1,470,099.67, with the “statutory cap”, therefore, being increased to $367,524.91, i.e., 25 percent of $1,470,099.67. Id. at 6.

On March 14, 2025, both parties responded to their opponent’s objections. Dkt. Nos. 418, 419. On March 25, 2025, the Court held in abeyance the fees motion, including related objections, after referring this action to the Mediation

Office of the Court of Appeals for the Ninth Circuit (Mediation Program). Dkt. Nos. 420, 421.2 The parties were also instructed to provide periodic updates to the Court regarding the above-described mediation. Dkt. No. 421. On August 20, 2025, the parties filed a joint status report, stating that the

parties had “reached a settlement in principle, which will resolve the pending Ninth Circuit appeals and the [fees motion].” Dkt. No. 424 at 2. The parties also stated that they were working “on a formal settlement agreement[]” and asked for the fees

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Shawn D. Privratsky v. Liberty Mutual Fire Insurance Company, (D. Haw. 2026).

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