On August 26, 2022, Justice Crane of the New York County Commercial Division issued a decision in Seibel v. Ramsay, 2022 NY Slip Op. 32904(U), cutting an attorneys’ fee award because counsel used block billing, explaining:
Finally, the court agrees with plaintiff that a further reduction to the award is warranted as a result of defendants’ block billing entries. Block billing is the practice of lumping multiple charges into a single billing entry. Courts generally disfavor block billing entries because it is difficult to determine whether those entries are reasonable. While block billing does not render the requested attorneys’ fees unreasonable per se, the court imposes a further across-the-board reduction of 10% to the requested fees as an appropriate remedy. Thus, the award is reduced by $444,930.77.
(Internal quotations and citations omitted).