paralegals with billing rates between $240 and $750 per hour, for a
total lodestar amount of $335,975.00. ECF No. 86-2 ¶ 7 (listing billing rates and hours
billed ... paralegal with billing rates between $250 and
$650 per hour, for a total lodestar amount of $574,325.00. ECF No. 86-3 ¶ 7. The firm also
reports litigation expenses ... with billing rates between $150
r67] and $1,100 per hour, for a total lodestar amount of $756,859.50. ECF No. 86-4 ¶ 7.
The firm also reports litigation expenses
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372146.pdf
paralegals with billing rates between $240 and $750 per hour, for a
total lodestar amount of $335,975.00. ECF No. 86-2 ¶ 7 (listing billing rates and hours
billed ... paralegal with billing rates between $250 and
$650 per hour, for a total lodestar amount of $574,325.00. ECF No. 86-3 ¶ 7. The firm also
reports litigation expenses ... with billing rates between $150
r67] and $1,100 per hour, for a total lodestar amount of $756,859.50. ECF No. 86-4 ¶ 7.
The firm also reports litigation expenses
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371371.pdf
EFTA01371375Set 10
2016-07-141p621w
Page 33
2016 U.S. Dist. LEXIS 97188, *
proposed lodestar and billable hour totals based on 96.5 hours 1/81 from W. Yanchunis at $900 per hour and 32.7 hours from ... Ponder at $150 per hour. for a firm lodestar of $91,755. See ECF No. 96-9 Ex. 2.
As discussed, the Court may apply a multiplier to the lodestar ... award," id., but courts "routinely find
in complex class action cases that a lodestar multiplier between one and four is fair and
reasonable." Saini, 2015 U.S. Dist. LEXIS
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371375.pdf
EFTA01416838Set 10
2017-06-19122p23,787w
Dist. LEXIS 9256
(D.N.J.,
2014)
CORE TERMS: settlement, attorneys' fees, repair, lodestar, timing chain,
notice, billing
rate, warranty, reimbursement, class action, settlement agreement, per hour,
tensioner,
class members, engine, documentation ... involves giving attorneys a portion
of the total
damages awarded to plaintiffs, and the lodestar method, which involves
multiplying the
number of hours reasonably worked on a case ... recovery method
is generally
favored in cases involving a common fund, while the lodestar method "is more
commonly
applied in statutory fee-shifting cases." Prudential, 148 F.3d
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01416838.pdf
ended and Defendants have processed
the claims. ECF No. 86 at 18.
2. The lodestar calculation supports an award of between $1,917,673.40 and
$2,320,000 in fees ... total amount of $2,320,000, which is
31.5 percent less than their lodestar calculation of $3,387,328.75. ECF No. 86 at 22.'
Defendants do not argue that Class ... Counsel is entitled to less than the lodestar amount,
but instead argue that Plaintiffs' $3,387,328.75 lodestar calculation is itself incorrect, based
on unreasonably high billing rates and insufficient
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372144.pdf
ended and Defendants have processed
the claims. ECF No. 86 at 18.
2. The lodestar calculation supports an award of between $1,917,673.40 and
$2,320,000 in fees ... total amount of $2,320,000, which is
31.5 percent less than their lodestar calculation of $3,387,328.75. ECF No. 86 at 22.'
Defendants do not argue that Class ... Counsel is entitled to less than the lodestar amount,
but instead argue that Plaintiffs' $3,387,328.75 lodestar calculation is itself incorrect, based
on unreasonably high billing rates and insufficient
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371370.pdf
involves giving attorneys a portion of the total
damages awarded to plaintiffs, and the lodestar method, which involves multiplying the
number of hours reasonably worked on a case ... recovery method is generally
favored in cases involving a common fund, while the lodestar method "is more commonly
applied in statutory fee-shifting cases." Prudential, 148 F.3d ... lodestar method
may also be applied "in cases where the nature of the recovery does not allow the
determination of the settlement's value necessary for application of the percentage
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372143.pdf
EFTA01371374Set 10
2010-02-091p633w
their proposed mean and top-quartile "General Liability"
rate adjustments would have on the lodestar. Using the Knapton Declaration's fee
schedule ... rates to the mean
and top-quartile rates proposed by Defendants would result in lodestars of $1,917,673.40
and $2,649,473.15, respectively. Id.
9 There are several discrepancies ... Class Counsel affidavits and the hours used by Mr.
Knapton to calculate Plaintiffs' lodestar of 3,387.328 75. Most notably. John A Yanchunis of Morgan & Morgan reports that he
billed
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371374.pdf
EFTA00786353Set 9
2018-09-0617p2,102w
Sender: Self
Participants: ), Self ( )
Who says lodestar. ? you know these people. Which one was close to moccasin
iMessage
[1] 2018-09-06 00:11:59 UTC
Sender: Self
Participants: ( ), Self ... says lodestar. ? you know these people. Which one was close to moccasin
iMessage
[2] 2018-09-06 00:12:12 (UTC)
Sender: Self
Participants: ), Self ( )
mccain
iMessage ... 56905dd5e4b0511db3declel
iMessage
2018-09-06 01:44:57 UTC) [1]
Sender:
Participants: ), Self ( )
Lodestar
iMessage
2018-09-06 01:44:57 UTC 2
Sender:
Participants: ( ), Self ( )
Lodestar
iMessage
https://www.justice.gov/epstein/files/DataSet%209/EFTA00786353.pdf
offers his expert opinion that
both the combined Class Counsel lodestar calculation of $3,387,328.75, and the combined
Class Counsel expense calculation of $133,358.39 are reasonable ... Although Mu Knapton builds this contingency multiplier into his lodestar calculation, ('71) see ECF No. 86-91150. the
"contingent nature or risk involved in a particular case' is a factor ... Court to consider in assessing the reasonability of a
multiplier after calculating the lodestar amount. Ins. Brokerage, 579 F.3d at 280.
Mr. Knapton reports that, of the 47 attorneys reporting
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371372.pdf
order to receive attorneys'
fees.
"After arriving at this lodestar figure, the district court may, in certain circumstances, adjust
the award upward or downward to reflect the particular circumstances ... these
calculations should be reduced to writing." Id. Courts frequently apply a "lodestar
multiplier," which "attempts to account for the contingent nature or risk involved in a
particular case ... quality of the attorneys' work" by increasing the attorneys' fee
awarded beyond the lodestar amount. Ins. Brokerage, 579 F.3d at 280 (quoting Rite Aid,
396 F.3d at 305-06). This
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372145.pdf
EFTA01372148Set 10
2010-02-091p633w
their proposed mean and top-quartile "General Liability"
rate adjustments would have on the lodestar. Using the Knapton Declaration's fee
schedule ... rates to the mean
and top-quartile rates proposed by Defendants would result in lodestars of $1,917,673.40
and $2,649,473.15, respectively. Id.
9 There are several discrepancies ... Class Counsel affidavits and the hours used by Mr.
Knapton to calculate Plaintiffs' lodestar of 3,387.328 75. Most notably. John A Yanchunis of Morgan & Morgan reports that he
billed
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372148.pdf
EFTA00422713Set 9
2011-12-087p4,677w
Court, would represent a
"multiplier" of approximately 2.5 times Lead Class Counsel's "lodestar." The lodestar is computed by taking the amount of
time spent working on this case, multiplied ... Class Counsel's hourly rates. Lead Class Counsel has informed the
Court that its lodestar is approximately $6.5 million, from the beginning of this case in 2003 through September
https://www.justice.gov/epstein/files/DataSet%209/EFTA00422713.pdf
attorneys working on similar matters in this community, the
potential application of a modest lodestar multiplier, and the difficulty of estimating an
accurate percentage-of-recovery calculation against which ... cross-check the Parties'
proposed lodestar calculations.
CONCLUSION
The Court finds that the proposed settlement between Plaintiffs and Defendants is fair,
adequate, and reasonable. Plaintiffs' motion for final approval
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372150.pdf
EFTA01371376Set 10
2013-03-221p563w
award sought by counsel and the lodestars
calculated under Defendants' proposed New York-Philadelphia mean and fourth-quartile
billing rates all fall within this range.
For the second factor ... sixth Gunter factor, the $2,230,000 award sought by Plaintiffs
and Defendants' proposed lodestar calculations are similar to awards approved in similar
cases. See, e.g, Henderson v. Volvo Cars
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371376.pdf
EFTA01372149Set 10
2013-03-221p563w
award sought by counsel and the lodestars
calculated under Defendants' proposed New York-Philadelphia mean and fourth-quartile
billing rates all fall within this range.
For the second factor ... sixth Gunter factor, the $2,230,000 award sought by Plaintiffs
and Defendants' proposed lodestar calculations are similar to awards approved in similar
cases. See, e.g, Henderson v. Volvo Cars
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372149.pdf
Seasons'-
- to reince, bannon,Jared
Hope , flynn
SB 12:07:21 am
Who says lodestar. ? you know these people. Which one was close to moccasin
12:11:59am
EFTA01615307
mccain ... 3542153C-0O38-4FFE-A50C-6C206696E758.pluginPayloadAttachment
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Type: image/vnd.microsoft.icon
01:32:00 am
t
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EFTA01615308
Steve Bannon
Lodestar
SB 01:44:57 am
im in paris tor with terje larsen for dinner
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01615306.pdf
EFTA01363861Set 10
2017-06-091p206w
Dist. LEXIS 9256 (D.N.J.,
2014)
CORE TERMS: settlement, attorneys' fees, repair, lodestar, timing chain, notice, billing
rate, warranty, reimbursement, class action, settlement agreement, per hour, tensioner,
class members, engine, documentation
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01363861.pdf