Full opinion text
MEMORANDUM OPINION ROYCE C. LAMBERTH, Chief Judge. Winston Churchill prescribed magnanimity in victory. See Winston S. Churchill, The Second World War, Volume I: The Gathering Storm xiii (1948). But Churchill, of course, spoke of war, not litigation. On August 10, 2007, relator emerged victorious in this False Claims Act (“FCA”) suit of epic duration when this Court entered judgment against six defendants for over $90 million. (See generally Judgment [883].) He now seeks another $20 million in attorneys’ fees and costs. Now before the Court are plaintiffs’ bills of costs [928, 929, 933] and relator’s motion for attorneys’ fees, costs, and expenses [930]. Pursuant to Federal Rule of Civil Procedure 54(d)(1) and Local Civil Rule 54.1, the United States asks the Court to tax its $54,437.87 in costs to defendants. Relator, in turn, requests reimbursement for $31,973.96 in costs. Separately, relator seeks $9,945,765.25 in attorneys’ fees and $511,723.06 in associated costs and expenses. Finally, he proposes a 100 percent enhancement of his attorneys’ fees based on exceptional quality of representation, thus raising his overall demand to $20,403,253.56. Defendants, naturally, oppose plaintiffs’ requests. This Opinion first considers Anderson’s argument that he shares liability only for the government’s costs. It then examines defendants’ challenges to plaintiffs’ bills of costs, to relator’s attorneys’ fees, and to his expenses. I. Anderson’s Liability Although the jury found for the government on its sole, live claim against Anderson, this Court dismissed relator’s claims against Anderson as time-barred. (See Verdict Form [858] at 4, 7, 11; Mem. Op. of June 14, 2007[872] at 29.) In opposing relator’s fee petition, Anderson contends the FCA permits only “prevailing parties” to recover fees and costs from a defendant, that relator is not a “prevailing party” as against him, and that accordingly, he is not liable to relator. (Anderson’s Opp’n at 2-7.) Relator, however, insists the FCA does not limit fee and cost recovery to prevailing parties, and that because the government prevailed on its claim against Anderson, Anderson is jointly and severally liable with the other defendants for relator’s fees and costs. (Reply to Anderson’s Opp’n at 1.) As the parties (at least, implicitly) concede, this issue is one of first impression. (See id. at 4; Anderson’s Opp’n at 5.) In incorporating a fee-shifting provision, the FCA is far from unique among federal statutes that create private, civil causes of action. Compare 31 U.S.C. § 3730(d)(1) (2008) (qui tam relator may recover “expenses ... necessarily incurred, plus reasonable attorneys’ fees and costs,” from the defendants), with 42 U.S.C. § 1988(b) (2008) (court has discretion to award “reasonable attorney’s fee as part of [ ] costs” to successful civil rights plaintiffs). Under many other fee-shifting schemes, a plaintiff may recover his attorneys’ fees and expenses from the defendant only when he is a “prevailing party.” See, e.g., Richlin Sec. Serv. Co. v. Chertoff, — U.S. —, 128 S.Ct. 2007, 2011, 170 L.Ed.2d 960 (2008) (Equal Access to Justice Act, 5 U.S.C. section 504(a)(1), “permits an eligible prevailing party to recover ‘fees and other expenses incurred by that party in connection with’ a proceeding before an administrative agency”); Winkelman v. Parma City Sch. Dist., — U.S. —, 127 S.Ct. 1994, 2002, 167 L.Ed.2d 904 (2007) (Individuals with Disabilities Education Act, 20 U.S.C. section 1315(i)(3)(B)(i)(I), “allow[s] an award [of attorney’s fees] ‘to a prevailing party who is the parent of a child with a disability’ ”); Farrar v. Hobby, 506 U.S. 103, 109, 113 S.Ct. 566, 121 L.Ed.2d 494 (1992) (“in order to qualify for attorney’s fees under [the Civil Rights Attorney’s Fees Awards Act, 42 U.S.C.] § 1988, a plaintiff must be a ‘prevailing party’ ”). Cf. Fed.R.Civ.P. 54.1(d) (providing for recovery of costs other than attorney’s fees by “the prevailing, party” in civil litigation). The FCA does not expressly limit fee recovery to “prevailing” relators, but its description of which relators may recoup their fees is not exactly a model of clarity: If the Government proceeds with an action brought by a [relator], such person shall ... receive at least 15 percent but not more than 25 percent of the proceeds of the action or settlement of the claim.... Where the action is one which the court finds to be based primarily on disclosures of specific information (other than information provided by the person bringing the action) relating to allegations or transactions [that have been publicly disclosed] the court may award ... no [ ] more than 10 percent of the proceeds.... Any payment to a person under the first or .second sentence shall be made from the proceeds. Any such person shall also receive an amount for reasonable expenses ... necessarily incurred, plus reasonable attorneys’ fees and costs. All such expenses, fees, and costs shall be awarded against the defendant. 31 U.S.C. § 3730(d)(1) (2008) (emphasis added). Cf. 42 U.S.C. § 1988(b) (2008) (court has discretion to award reasonable attorney’s fee to “prevailing party” in suits brought pursuant to certain civil rights statutes). To interpret the vague phrase “any such person,” the Court must look to its context. See Davis v. Mich. Dep’t of Treasury, 489 U.S. 803, 809, 109 S.Ct. 1500, 103 L.Ed.2d 891 (1989) (“It is a fundamental canon of statutory construction that the words of a statute must be read in their context and with a view to their place in the overall statutory scheme.”). In light of the immediately preceding sentence, “any such person” must mean any person who receives payment under the statute’s first or second sentences. See 31 U.S.C. § 3730(d)(1) (2008). Those two sentences merely establish the percentage bounty a relator should receive when the government intervenes in the action he has brought and ultimately secures payment for its damages. See id. The internal cross-reference thus suggests that whenev er the government intervenes and obtains relief, no matter the circumstances, the relator should receive both a share of the government’s proceeds and reasonable attorneys’ fees. This reading, however, would yield absurd results — at least some of which Congress clearly did not intend. For example, 31 U.S.C. section 3730(e) provides that no court shall have jurisdiction over certain actions, such as those “based upon the public disclosure of allegations or transactions ... unless ... the person bringing the action is an original source of the information” — that is, “an individual who has direct and independent knowledge of the information on which the allegations are based and [who] has voluntarily provided the information to the Government” before filing his qui tam complaint. See 31 U.S.C. § 3730(e)(4) (2008). Logically, having erected a jurisdictional bar to these relators’ claims, Congress could not have intended them to receive attorneys’ fees. See Fed. Recovery Servs., Inc., 72 F.3d at 449-50, 453 (affirming district court’s denial of attorneys’ fees to relator whose claims were dismissed as barred under section 3730(e)(4)). Cf. United States ex rel. Merena v. SmithKline Beecham Corp., 205 F.3d 97, 106 (3d Cir.2000) (Alito, J.) (reversing district court’s award of relator’s share to relator whose claims were subject to dismissal under section 3730(e)(4)). On the contrary, Congress has sought to prevent, not reward, “opportunistic suits by private persons who heard of fraud but played no part in exposing it.” Cooper v. Blue Cross & Blue Shield of Fla., Inc., 19 F.3d 562, 565 (11th Cir.1994) (emphasis added) (discussing comprehensive 1986 FCA amendments). The fee-shifting provision itself does not appear to draw this line — nor, for that matter, any other. Relator suggests the Court should interpret this inscrutable language in light of the FCA’s goals, which he argues support awarding attorneys’ fees to relators, like himself, whose claims are dismissed due to “procedural,” vice jurisdictional, defects. (See Reply to Anderson’s Opp’n at 4-5.) Courts rightly balk at engaging in this sort of arbitrary line-drawing. E.g., Colgrove v. Battin, 413 U.S. 149, 182, 93 S.Ct. 2448, 37 L.Ed.2d 522 (1973) (Marshall, J., dissenting) (“Normally, in our system we leave the inevitable process of arbitrary line drawing to the Legislative Branch, which is far better equipped to make ad hoc compromises.”). Happily, here, Congress left an additional, unambiguous clue to its intent in drafting the FCA attorneys’ fees provision. In its report accompanying the 1986 amendments, the Senate Judiciary Committee characterized the FCA’s fee-shifting scheme as applying to “prevailing qui tam relators.” S.Rep. No. 99-345, at 29 (1986), as reprinted in 1986 U.S.C.C.A.N. 5266, 5294 (emphasis added). As explained above, the qualifier “prevailing” appears in numerous other federal fee-shifting provisions, and its meaning is well-established. See, e.g., Farrar, 506 U.S. at 109-11, 113 S.Ct. 566. Its application here would harmonize the fee-shifting provision with the jurisdictional exclusions in subsection (e) and with more fundamental jurisdictional concerns. See Fed. Recovery Servs., Inc., 72 F.3d at 450, 452 (government’s intervention does not cure existing jurisdictional defect in relator’s complaint so as to permit dismissed relator to recover attorneys’ fees); United States ex rel. Taxpayers Against Fraud v. Gen. Elec. Co., 41 F.3d 1032, 1044 (6th Cir.1994) (despite government’s intervention and settlement with defendant, if district court on remand determined co-relator lacked standing, it could not recoup attorneys’ fees). As the Supreme Court has observed, “[rjespect for ordinary language requires that a plaintiff receive at least some relief on the merits of his claim before he can be said to prevail.” Hewitt v. Helms, 482 U.S. 755, 760, 107 S.Ct. 2672, 96 L.Ed.2d 654 (1987), overruled in part on other grounds by Sandin v. Conner, 515 U.S. 472, 115 S.Ct. 2293, 132 L.Ed.2d 418 (1995). The Senate Report’s “ordinary language” undercuts relator’s contention that Anderson, against whom his claims garnered no relief whatever, should share liability for his attorneys’ fees and costs. Furthermore, contrary to relator’s arguments, declining to assess relator’s attorneys’ fees against Anderson comports with the FCA’s underlying purposes. Relator insists Congress enacted the FCA “to encourage the filing of this very kind of lawsuit,” in which relator from the outset fingered Anderson as a ringleader in the fraud. (Reply to Anderson’s Opp’n at 3-4.) First, to answer relator’s implicit proposition most directly, this Court is confident that potential relators will not be discouraged from filing meritorious FCA claims by a holding that 31 U.S.C. section 3730(d)(1) does not permit attorneys’ fee awards against defendants who obtain judgment as a matter of law on the relator’s claims. Second, this Court has encapsulated the FCA’s purposes as follows: The False Claims Act seeks, first and foremost, to detect, punish, and deter the submission of false claims, while seeking to restore funds to the federal fisc. The qui tarn provisions enlist private individuals, often motivated largely by self-interest, to report and prosecute alleged false claims. Those provisions seek to strike a balance between the interests of the government and the self-interest of relators. United States ex rel. Pogue v. Diabetes Treatment Ctrs. of Am., 474 F.Supp.2d 75, 87 (D.D.C.2007) (Lamberth, J.). “The [FCA’s] statute of limitations,” this Court reasoned, “advances those governmental interests.” Id. Yet statutes of limitations, by their nature, also “facilitat[e] the administration of claims[ ] ... [and] promote] judicial efficiency.” John R. Sand & Gravel Co. v. United States, — U.S. —, 128 S.Ct. 750, 753, 169 L.Ed.2d 591 (2008) (citations omitted). Thus, Congress clearly did not seek “to encourage the filing of this very kind of lawsuit” at the expense of these governmental interests and prudential considerations. Denying attorneys’ fees to relators whose claims are time-barred strikes this balance. Accordingly, the Court concludes that because relator’s claims against Anderson were dismissed in their entirety, relator may not recover attorneys’ fees, costs, or expenses from Anderson under the FCA. Under Federal Rule of Civil Procedure 54(d)(1), only a “prevailing party” may recover costs, other than attorneys’ fees, from a private defendant. Fed.R.Civ.P. 54(d)(1). Because relator’s legal relationship to Anderson remains wholly unchanged, he may not recover costs from Anderson under this Rule. See Tex. State Teachers Ass’n, 489 U.S. at 792-93, 109 S.Ct. 1486; Graham, 473 U.S. at 168, 105 S.Ct. 3099. II. Plaintiffs’ Taxable Costs As stated above, Rule 54(d)(1) permits a “prevailing party” to recoup his costs, other than attorneys’ fees, from a private defendant. Fed.R.Civ.P. 54(d)(1). Cf. 31 U.S.C. § 3729(a) (U.S. may recover “the costs of a civil action” brought to recover FCA penalty or damages). While Rule 54(d)(1) affords the court some discretion in awarding costs, the Courts of Appeals have consistently treated the allowance as presumptive, holding “that a court may neither deny nor reduce a prevailing party’s request for costs without first articulating some good reason for doing so.” Baez v. U.S. Dep’t of Justice, 684 F.2d 999, 1004 (D.C.Cir.1982) (en banc) (per curiam). The unsuccessful party bears the burden of supplying this “good reason,” and “trial judges have rarely denied costs to a prevailing party whose conduct has not been vexatious when the losing party has been capable of paying such costs.” Id.; see, e.g., Bell v. Gonzales, No. 03-163, 2006 WL 6000485, **2-3, 2006 U.S. Dist. LEXIS 69415, at *7-8 (D.D.C. Sept. 27, 2006) (Bates, J.) (sharply reducing government’s “plainly inflated Bill of Costs,” where costs were “not well supported factually or legally” and comprised “a punitive effort ... against an unsuccessful discrimination plaintiff’). In particular, by statute, a prevailing party may recover “[f]ees of the court reporter for all or any part of the stenographic transcript necessarily obtained for use in the case.” 28 U.S.C. § 1920(2) (2008). This Court’s local rules refine this allowance: (6) the costs, at the reporter’s standard rate, of the original and one copy of any deposition noticed by the prevailing party, and of one copy of any deposition noticed by any other party, if the deposition was used on the record, at a hearing or trial; (7) the cost, at the reporter’s standard rate, of the original and one copy of the reporter’s transcript of a hearing or trial if the transcript: (i) is alleged by the prevailing party to have been necessary for the determination of an appeal within the meaning of Rule 39(e), Federal Rules of Appellate Procedure, or (ii) was required by the court to be transcribed!] Local Civ. R. 54.1(d). Defendants’ sole objection to plaintiffs’ bills of costs concerns allegedly duplicative charges for transcripts. Specifically, the United States and relator have each billed for an original and one copy of thirteen individuals’ deposition transcripts. In some of these cases, it is clear that plaintiffs wish defendants to pay for four copies of exactly the same document. Further, the United States and relator each seek reimbursement for an original and one copy of each afternoon’s trial transcript. (See Ex. 1 to U.S. Bill of Costs [928] at 3-4; Ex. 4 to Relator’s Bill of Costs [929] at 1-2.) Again, they repeatedly paid for four copies of the same document, at a premium for expedited preparation. Such expenditures hardly seem reasonable. The Court does not suggest that as co-plaintiffs, the United States and relator must necessarily have shared a single transcript, prepared according to the court reporter’s regular schedule. But for each plaintiff to bill for two copies of an expedited transcript strikes the Court as possibly excessive. Nevertheless, this practice does not fall outside the letter of Local Rule 54.1. The Rule refers to “[a] prevailing party,” and its choice of article (“a” rather than “the”) implies that any prevailing party, even if there is more than one, may invoke its provisions. Local Civ. R. 54.1(a). Further, the Rule specifically provides for reimbursement for an original and one copy of deposition and trial transcripts. Local Civ. R. 54.1(d). Defendants, who bear the burden of demonstrating a “good reason” for denying plaintiffs’ costs, offer no authority and little argument for deviating from this presumptive allowance. See Baez, 684 F.2d at 1004. Moreover, plaintiffs’ “conduct has not been vexatious,” and it appears defendants are “capable of paying [these] costs.” See id. Accordingly, the Court concludes defendants’ meager opposition does not overcome the strong presumption in plaintiffs’ favor. Plaintiffs’ bills of costs [928, 929] shall be granted in full. III. Relator’s Attorneys’ Fees Relator also seeks an award of “reasonable attorneys’ fees” against defendants under the FCA. “The initial estimate of a reasonable attorney’s fee is properly calculated by multiplying the number of hours reasonably expended on the litigation times a reasonable hourly rate.” Blum v. Stenson, 465 U.S. 886, 888, 104 S.Ct. 1541, 79 L.Ed.2d 891 (1984). A strong presumption exists that the product of these two variables — the “lodestar figure” — represents a “reasonable fee.” Pennsylvania v. Del. Valley Citizens’ Council for Clean Air, 478 U.S. 546, 565, 106 S.Ct. 3088, 92 L.Ed.2d 439 (1986). Upward adjustments of the lodestar are warranted only in “rare” and “exceptional” cases, where supported by “specific evidence” and detailed findings. Blum, 465 U.S. at 899-901, 104 S.Ct. 1541. In calculating relator’s fee award, the Court must thus make three separate determinations: (1) what constitutes a “reasonable hourly rate” for his counsel’s services; (2) which among his counsel’s claimed work hours were “reasonably expended on the litigation”; and (3) whether relator has offered “specific evidence” demonstrating this to be the “rare” case in which a lodestar enhancement is appropriate, and if so, in what amount. The Court considers each issue in turn. A. Reasonable Rate In calculating this component of the lodestar, the Court must resolve two contested issues: (1) which source(s) should supply the reasonable rate; and (2) whether current or historical rates should apply to work performed prior to 2007. 1. Established vs. Matrix-Derived Rates In this Circuit, “an attorney’s usual billing rate is presumptively the reasonable rate, provided that this rate is ‘in line with those prevailing in the community for similar services by lawyers of reasonably comparable skill, experience and reputation.’ ” Kattan by Thomas v. District of Columbia, 995 F.2d 274, 278 (D.C.Cir.1993) (quoting Blum, 465 U.S. at 896 n. 11, 104 S.Ct. 1541). [W]hen fixed market rates already exist, there is no good reason to tolerate the substantial costs of turning every attorneys fee case into a major ratemaking proceeding. In almost every case, the firms’ established billing rates will provide fair compensation. The established rates represent the opportunity cost of what the firm turned away in order to take the litigation; they represent the lawyers’ own assessment of the value of their time. Laffey v. Northwest Airlines, Inc., 746 F.2d 4, 24 (D.C.Cir.1984) (emphasis in original), overruled on other grounds by Save Our Cumberland Mountains, Inc. v. Hodel, 857 F.2d 1516 (D.C.Cir.1988). “[T]he burden is on the fee applicant to produce satisfactory evidence — in addition to the attorney’s own affidavits — that the requested rates” align with prevailing rates. Blum, 465 U.S. at 896 n. 11, 104 S.Ct. 1541. See also Covington v. District of Columbia, 57 F.3d 1101, 1107 (D.C.Cir.1995) (“a fee applicant’s burden in establishing a reasonable hourly rate entails a showing of at least three elements: the attorneys’ billing practices; the attorneys’ skill, experience, and reputation; and the prevailing market rates in the relevant community”). a. Wilmer Hale Relator asks that his attorneys be compensated at their standard billing rates, and he has submitted a declaration from his lead counsel, Robert Bell, that provides these standard rates for Wilmer Hale personnel. {See Bell Decl. ¶ 108, Ex. 2 to Mot. for Fees, Costs, and Expenses [930].) As one might expect, Bell avows that the requested rates are within the range of prevailing market rates charged by large law firms in the District of Columbia for lawyers and paralegals of similar experience and qualifications. {See id. ¶¶ 104, 109.) To supplement Bell’s own assertions, relator offers declarations from two local attorneys. The first, Stephen L. Braga, now a partner at Baker Botts — like Wilmer Hale, a large, international law firm— has practiced complex, civil litigation in the District since 1982. (Braga Decl. ¶ 1, Ex. 3 to [930].) Since 1993, Braga has also instructed law students on the subject of attorneys’ fees as an adjunct professor at the Georgetown University Law Center. {Id. ¶ 1(g).) Beyond arguing that “[u]nder basic economic principles,” Wilmer Hale’s standard rates must be considered competitive within the D.C. market, Braga compares rates for four Wilmer Hale partners with those charged by his own firm and other large, D.C. litigation firms for partners with similar backgrounds and litigation experience. {Id. ¶ 6.) He asserts that Robert Cultice, Jennifer O’Connor, and Jonathan Cedarbaum could command higher hourly rates, and that Robert Bell’s rate “appears to be set right where it should be in the Washington legal market.” (Id) Braga concludes that Wilmer Hale’s established rates “fall squarely within the prevailing market rates in the District of Columbia for experienced counsel to handle complex civil litigation.” (Id) The second attorney declarant, Steven K. Davidson, currently a partner at Step-toe & Johnson — another large, international law firm — has practiced commercial litigation in the District since 1985. (Davidson Decl. ¶ 2, Ex. 5 to [930].) As a member of his firm’s Executive Committee, he has assisted with setting professionals’ billing rates. (Id ¶¶ 2, 16.) Davidson offers an opinion based not only on anecdotal knowledge of his and competitor firms’ standard billing rates but also on two external sources. (Id ¶¶ 19-21.) First, The National Law Journal’s 2006 annual survey of billing rates indicates that Wilmer Hale’s rates are comparable to those reported by other large firms with D.C. offices. (Id ¶ 19; see id. Ex. A.) Second, Wilmer Hale’s rates also align with those delineated in the Laffey matrix, as updated by relator’s economist using the nationwide legal services component of the Consumer Price Index, a methodology approved in Salazar v. District of Columbia, 123 F.Supp.2d 8 (D.D.C.2000) (Kessler, J.). (Id ¶ 20; see also Kavanaugh Decl. ¶¶ 9-15, Ex. 4 to [930].) Davidson thus concludes that Wilmer Hale’s rates “are comparable to the prevailing market rates and [ ] well within the reasonable range of rates for a law firm such as WilmerHale undertaking matters of the magnitude and complexity of those involved here.” (Davidson Decl. ¶ 16, Ex. 5 to [930].) Relator’s evidence demonstrates that Wilmer Hale’s established billing rates— those charged to all litigation clients— align with the established rates of lawyers of reasonably comparable skill, experience, and reputation in the D.C. legal community. See Kattan, 995 F.2d at 278. Thus, the Court will accord these rates a presumption of reasonableness. See Covington, 57 F.3d at 1110. Defendants’ rebuttal to this evidentiary showing rests on a single proposition. Under Blum, a reasonable rate must align with “those prevailing in the community for similar services.... ” 465 U.S. at 896 n. 11, 104 S.Ct. 1541. Whereas relator appears to define “similar services” in terms of complex, federal-court civil litigation, defendants insist “similar” must be construed more narrowly. {See HII’s Opp’n [949] at 30-34.) In their view, the hourly rates typically charged by FCA relators’ counsel are the benchmark against which this Court should evaluate relator’s requested rates. {Id. at 32-33.) This contention fails for three reasons. First, the authority on which defendants rely does not support their argument. Second, case law in this Circuit does not support the Balkanized approach to fee calculation that defendants advocate. In 1983, then-Chief Judge Aubrey Robinson adopted an hourly rates scheme for complex, federal litigation under which an attorney’s years of experience determined his reasonable hourly rate. Laffey v. Northwest Airlines, Inc., 572 F.Supp. 354, 371-75 (D.D.C.1983). In the ensuing twenty-five years, this scheme, the Laffey matrix, has achieved broad acceptance in this Circuit and has served as a guide in nearly every conceivable type of case. See, e.g., Hansson v. Norton, 411 F.3d 231, 236 (D.C.Cir.2005) (employment discrimination); Role Models Am., Inc. v. Broum-lee, 353 F.3d 962, 970 (D.C.Cir.2004) (Administrative Procedures Act); Covington, 57 F.3d at 1110 (civil rights); Judicial Watch, Inc. v. BLM, 562 F.Supp.2d 159, 175 (D.D.C.2008) (Lamberth, J.) (Freedom of Information Act); MacClarence v. Johnson, 539 F.Supp.2d 155, 160 (D.D.C.2008) (Facciola, M.J.) (Clean Air Act). The generic matrix’s use in such a diverse range of cases cuts against defendants’ argument that reasonable rates can be derived only from data peculiar to a case’s legal specialty area. Third, and most critically, defendants have failed to demonstrate that for purposes of calculating a reasonable hourly rate, qui tarn litigation differs in any meaningful way from other complex, civil litigation that occurs in federal court. Defendants contend that “FCA litigation, particularly for relator’s counsel, is a specialized, niche practice that is distinct from other types of civil litigation, and certainly differs from the defense-oriented commercial litigation practiced by firms like Wil-merHale.” (HII’s Opp’n [949] at 33.) If, as defendants suggest, qui tam litigation is a “niche” field because FCA-specific treatises and hornbooks, legal symposia, and professional organizations exist, then virtually every type of litigated case could be so characterized. The allegation that some attorneys “dedicate their entire practice to representing relators” is no more persuasive. (Id. at 34.) Defendants contend the rates charged by FCA specialists at Cincinnati’s Helmer, Martins, Rice & Popham (“HMRP”) establish the benchmark for reasonableness. (Id. at 35-38.) “[E]ven assuming, arguendo, the existence of [ ] a [FCA litigation] submarket,” rates charged by a single, Ohio firm do not constitute “evidence that submarket rates are lower than the prevailing rates in the broader legal market.” See Covington, 57 F.3d at 1111. Defendants point out that HMRP’s rates conform almost precisely to those outlined in the Lajfey matrix, as updated by the U.S. Attorney’s Office (“USAO”), and that using rates from either source would reduce relator’s requested fee award by 38%. (HII’s Opp’n [949] at 38-39.) This tremendous disparity gives the Court pause. But two factors overcome its skepticism. First, simple reference to the Lajfey matrix cannot defeat the presumption of reasonableness accorded relator’s requested rates. Though it “serves as a useful starting point for determining prevailing market rates in the District of Columbia,” Cobell, 407 F.Supp.2d at 170, the Laffey matrix is not the only acceptable starting point. Our Court of Appeals has never held that Laffey rates are the only rates that a court may consider reasonable. Instead, it has advised that “an attorney’s usual billing rate is presumptively the reasonable rate, provided that this rate” aligns with prevailing community rates. Kattan by Thomas v. District of Columbia, 995 F.2d 274, 278 (D.C.Cir.1993). “[F]ee claimants must provide the court with specific evidence of the prevailing community rate.” Jordan, 691 F.2d at 521. See also Blum, 465 U.S. at 896 n. 11, 104 S.Ct. 1541 (fee applicant must “produce satisfactory evidence — in addition to the attorney’s own affidavits — that the requested rates” align with prevailing rates). This evidence may include the Laffey matrix, in its original form and/or as updated by the USAO. See Covington, 57 F.3d at 1110. But it may also consist of comparable fee awards or affidavits from knowledgeable local practitioners, such as those relator has submitted here. See Jordan, 691 F.2d at 521. If non-conformity with updated USAO Laffey rates could doom a petitioner’s request, this' would moot the evidentiary showing envisioned by Blum. See 465 U.S. at 896 n. 11, 104 S.Ct. 1541. It would effectively impose a ceiling on the rates courts can award pursuant to fee-shifting statutes — a ceiling never endorsed by Congress. Neither it nor the courts have ever “propose[d] ... that all attorneys be remunerated at the same rate, regardless of their competence, experience, and marketability.” Save Our Cumberland Mountains, Inc. v. Hodel, 857 F.2d 1516, 1522 n. 4 (D.C.Cir.1988). Second, the Supreme Court clarified in Blum that a reasonable hourly rate should ordinarily reflect the quality of counsel’s representation. See 465 U.S. at 899, 104 S.Ct. 1541. Defendants balk at the “mega-law firm rates” relator seeks. (HII’s Opp’n [949] at 30.) But these rates reflect counsel’s “mega-law firm”-quality representation. Having observed more than a few attorneys in the past twenty years, this Court is well-suited to judge the quality of counsel’s representation, both in the courtroom and in written submissions. By this Court’s assessment, relator’s counsel — particularly the more junior trial team members — acquitted themselves admirably. Their zealous, polished, and astute advocacy justifies, and is reflected in, their established billing rates. Further, according to government counsel, [t]he availability of Relator’s counsel from WilmerHale was essential in meeting the overwhelming demands of discovery and ultimately of the trial in this matter. Indeed, attorneys and support staff from WilmerHale played a vital role in getting this case ready for trial and ultimately in successfully trying it. (Morgan Decl. ¶ 7, Ex. 1 to Mot. for Fees, Costs, and Expenses [930].) During the discovery period alone, relator’s counsel reviewed 665 boxes of documents, from which they culled over 97,000 documents with over 320,000 pages, attended 40 depositions, taking a leading role in some, and participated in two evidentiary hearings. (Bell Decl. ¶¶ 74-75, 78, 85, Ex. 2 to [930].) Had Wilmer Hale not been able to call on its “mega-law firm” resources, plaintiffs might have struggled to meet these “overwhelming demands.” See Wilcox v. Sisson, No. 02-1455, 2006 WL 1443981, *2, 2006 U.S. Dist. LEXIS 33404, at *8 (D.D.C. May 25, 2006) (Collyer, J.) (“The market generally accepts higher rates from attorneys at firms with more than 100 lawyers than from those at smaller firms — presumably because of their greater resources and investments.... ”). For all these reasons, the Court finds defendants have failed to rebut relator’s evidentiary showing that the requested rates — Wilmer Hale’s established rates— align “with those prevailing in [this] community for similar services by lawyers of reasonably comparable skill, experience and reputation.” See Blum, 465 U.S. at 896 n. 11, 104 S.Ct. 1541. Wilmer Hale’s established billing scale will supply the reasonable hourly rates with which this Court will calculate the lodestar. b. Wiley Rein Relator also seeks compensation for work performed by four Wiley Rein attorneys (other than Bell) and two paralegals. (Bell Decl. ¶ 103, Ex. 2 to Mot. for Fees, Costs, and Expenses [930].) Of these six individuals, only one, Michael Sturm, remains at Wiley Rein. (Id. ¶ 104.) In light of the Court’s conclusion concerning Wilmer Hale’s rates, Sturm’s established billing rate is eminently reasonable. For the other five professionals, however, relator has provided neither their current billing rates nor those of their Wiley Rein peers. Instead, he asks that their work be compensated at rates derived from economist Kavanaugh’s Laffey matrix. (See id. ¶ 104.) Unlike the USAO’s matrix, which calculates inflation based on the metropolitan D.C. Consumer Price Index (“CPI”), Kavanaugh’s version relies on a legal services sub-component of the broader, national CPI. (See Kavanaugh Deck ¶ 9, Ex. 4 to Mot. for Fees, Costs, and Expenses [930].) Kavanaugh’s alternative methodology has achieved only limited acceptance in this District. As he did in Salazar, Kavanaugh presents a well-reasoned, if condensed, economic argument for his index’s superiority. (See id. ¶¶ 9-14.) Nevertheless, after reviewing his declarations, the Court is not convinced. Kavanaugh’s matrix incorporates price inflation data specific to the market for legal services, while the USAO matrix relies on data specific to the Washington, D.C. metropolitan area. (Id. ¶ 9.) Kavanaugh’s matrix thus reflects national inflation trends, while the USAO matrix accounts for price inflation within the local community — a crucial distinction. As the Supreme Court and our Court of Appeals have both emphasized, rates used in calculating the lodestar should accord with those “prevailing in the community.” Blum, 465 U.S. at 896 n. 11, 104 S.Ct. 1541 (emphasis added); see also Covington v. District of Columbia, 57 F.3d 1101, 1108 (D.C.Cir.1995) (“plaintiff must produce data concerning the prevailing market rates in the relevant community ”) (emphasis added). Kavanaugh’s matrix does not comply with this mandate for geographic specificity. Hence, with due respect to its colleagues, the Court declines to adopt Kavanaugh’s methodology. It will thus award fees for the remaining five Wiley Rein professionals at USAO Laffey matrix rates. 2. Current vs. Historical Rates The time entries included in relator’s fee petition span a thirteen-year period: Wiley Rein personnel devoted time to this case from 1995-1999, and Wilmer Hale’s involvement has stretched from 1999-2007. (See Exs. B-2, D-2, to Bell Deck, Ex. 2 to Mot. for Fees, Costs, and Expenses [930].) Relator seeks to recover all fees at current billing rates, (Mot. for Fees, Costs, and Expenses [930] at 12), while defendants favor using historical rates corresponding to the years when the work was performed, (see HII’s Opp’n [949] at 40-43; BHIC and HUK’s Opp’n [948] at 19-21.) In 1911, Ambrose Bierce described litigation as “[a] machine which you go into as a pig and come out of as a sausage.” Ambrose Bierce, The Devil’s Dictionary 72 (1979 ed.). Since Bierce’s day, the process has become, if anything, more drawn out and contentious. Recognizing that in many cases, an attorney may put in years of effort before realizing any tangible return, the Supreme Court has held that a “reasonable attorney’s fee” awarded pursuant to a fee-shifting statute should account for delay in payment. See Missouri v. Jenkins, 491 U.S. 274, 282, 109 S.Ct. 2463, 105 L.Ed.2d 229 (1989). “Clearly, compensation received several years after the services were rendered — as it frequently is in complex [qui tarn ] litigation — is not equivalent to the same dollar amount received reasonably promptly as the legal services are performed....” Id. at 283, 109 S.Ct. 2463. Thus, courts should make “an appropriate adjustment for delay in payment — whether by the application of current rather than historic hourly rates or otherwise.” Id. at 284, 109 S.Ct. 2463. Courts in this Circuit have frequently employed the Supreme Court’s suggested method of adjustment. See, e.g., Murray v. Weinberger, 741 F.2d 1423, 1433 (D.C.Cir.1984) (“Current market rates have been used in numerous cases to calculate the lodestar figure when the legal services were provided over a multiple-year period and when use of the current rates does not result in a windfall for the attorneys.”); Muldrow, 397 F.Supp.2d at 4 n. 4 (“Nor does the Court object to plaintiffs use of the Laffey rates for 2005-06 even though much of the litigation took place several years ago. The Supreme Court has held that it is acceptable to use current market rates, rather than historic rates, as a convenient method of compensating prevailing parties for a delay in receiving payment.”). See also Copeland v. Marshall, 641 F.2d 880, 893 n. 23 (D.C.Cir.1980) (en banc) (noting that lodestar may be “based on present hourly rates, rather than the lesser rates applicable to the time period in which the services were rendered,” to reduce or eliminate “harm resulting from delay in payment”). Several observations are in order. First, though relator seeks compensation for 24,584.6 billable hours, spread over thirteen years, roughly half those hours were billed in 2007, the year for which relator has provided Wilmer Hale’s standard billing rates. (See Exs. C-2, C-4 to Bell Supplemental Deck, Ex. 1 to Reply to HII’s Opp’n [957].) Indeed, only 1,826.3 hours — 7.4 percent of the total — -were billed prior to 2006. (See id.) Thus, defendants’ “windfall” objection, discussed below, pertains to only a small portion of relator’s overall fee request. Second, according to Robert Bell, Wilmer Hale’s billing cycle averages 89 days. (See Bell Supplemental Deck ¶¶ 23-24, Ex. 1 to [957].) By contrast, here, by the time Wilmer Hale receives payment pursuant to the instant fee award, at least a full year will have passed since it billed the last hours addressed therein. Third, as relator’s economist points out, accounting for delay by applying current rates across the board boasts distinct, practical advantages: There may be other ways to compensate [for delay in payment] — that is, to restore the firm that provided the legal services to the level of wealth it could have obtained had it been paid at the time the service was performed- — but the other compensation methods are more complex, have higher transaction costs, raise the specter of interest payments and may not be any better than simply using the current prevailing market rates. (Kavanaugh Deck ¶ 18, Ex. 5 to Mot. for Fees, Costs, and Expenses [930].) See also Murray, 741 F.2d at 1433 (“Ease of administration is an important objective ... because there is a pressing need for simple rules in attorney’s fees cases.”). Moreover, Kavanaugh’s alternative proposed method of compensating for delay— using the historical prime rate to calculate the present value of a timely payment stream for the hours billed — produces a lodestar figure 1.6 percent higher than that requested by relator. (Kavanaugh Supplemental Deck ¶¶ 6-12, Ex. 4 to Reply to HII’s Opp’n [957].) Notwithstanding these various points, defendants oppose applying current rates to compensate for delay for two reasons. First, they contend that application of current rates will result in a forbidden “windfall” to relator’s counsel. (See HII’s Opp’n [949] at 40-41; BHIC and HUK’s Opp’n [948] at 19-21.) They insist that fee awards must reflect lawyers’ experience levels at the time they performed the work, lest they be afforded credit for experience — and the heightened skill, productivity, and efficiency that usually accompany it — they did not then possess. (See HII’s Opp’n [949] at 40-41; BHIC and HUK’s Opp’n [948] at 19-21.) This argument has some superficial appeal, but it misunderstands the rationale behind compensating for delay in payment. “[C]om-pensation received several years after the services were rendered ... is not equivalent to the same dollar amount received reasonably promptly as the legal services are performed.” Jenkins, 491 U.S. at 283, 109 S.Ct. 2463. Paying counsel at historical, or even current, rates based on their experience levels when they performed the work would not achieve this equivalence because it ignores the time value of money: one dollar received today is more valuable than it would be if received five years from now for two reasons — first, because it will buy more now than it will after five years of price inflation, and second, because of the interest that can be earned from it in the interim. Paying counsel at their current, established billing rates does not result in a windfall; it simply takes the this second factor into account. Second, they contend that relator bears responsibility for the delay, and that consequently, he should not be rewarded with a fees adjustment therefor. (HII’s Opp’n [949] at 42-43.) Both components of this argument are flawed. Responsibility for the first period of delay defendants cite— June 1995 to March 2001 — can be laid at the government’s feet, but not relator’s. Under the FCA’s qui tarn provisions, once he files his complaint under seal, a relator must simply await the government’s decision on intervention. See 31 U.S.C. § 3730(b) (2008). As this Court expressed in an earlier opinion in this case, the government’s “unreasonable inaction” precipitated this first period of delay. (See Mem. Op. of June 14, 2007[872] at 30.) All parties contributed to the next, post-seal period of delay: defendants opposed plaintiffs’ request to commence discovery in 2003, (see Joint Rule 16.3 Report of Nov. 13, 2003[148] at 2), and plaintiffs repeatedly amended their complaints, (e.g., Relator’s Third Am. Compl. [233] (filed Mar. 9, 2006); Government’s First Am. Compl. [237] (filed Mar. 9, 2006)). Moreover, regardless of who caused what period of delay, defendants’ authorities for denying the responsible party compensation for delay merely confirm that a court’s decision to account for delay in awarding attorneys’ fees is discretionary. See Sands v. Runyon, 28 F.3d 1323, 1334 (2d Cir.1994) (finding no abuse of discretion where district court refused to “apply multiplier to the basic hourly rate to account for the delay between the investment of time and the receipt of the fee award” because plaintiff had caused unnecessary delay); Paris v. Dallas Airmotive, Inc., No. 97-0208, 2004 WL 2100227, **11-12, 2004 U.S. Dist. LEXIS 18893, at *35-36 (N.D.Tex. Sept. 21, 2004) (declining to exercise discretion to award fees at current market rates because, but for plaintiffs actions, case could have been concluded at least three years earlier). Here, having concluded that no “windfall” will result, and in light of the practical advantages to be derived, the Court will exercise its discretion to compensate relator’s counsel for delay in payment by applying current rates in calculating the lodestar. Appendix I delineates the rates the Court will use for both Wiley Rein and Wilmer Hale professionals. B. Reasonable Hours Several principles govern the Court’s calculation of this second component of the lodestar, “the number of hours reasonably expended on the litigation.” See Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983). First, the fee petitioner must submit evidence that justifies the hours he claims his counsel have worked. Id. “Where the documentation of hours is inadequate, the district court may reduce the award accordingly.” Id. A “fee application need not present the exact number of minutes spent[,] nor the precise activity to which each hour was devoted[,] nor the specific attainments of each attorney.” Nat’l Ass’n of Concerned Veterans v. Sec’y of Def., 675 F.2d 1319, 1327 (D.C.Cir.1982) (internal quotation marks omitted). But where time entries “are so vaguely generic that the Court can not determine with certainty whether the activities they purport to describe were ... reasonable,” the petitioner has not met his burden. Cobell v. Norton, 407 F.Supp.2d 140, 158 (D.D.C.2005) (Lamberth, J.). Instead, “the application must be sufficiently detailed to permit the District Court to make an independent determination whether or not the hours claimed are justified.” Nat’l Ass’n of Concerned Veterans., 675 F.2d at 1327. Second, “[t]he hours reasonably expended are not necessarily equal to the hours actually expended.” McKenzie v. Kennickell, 645 F.Supp. 437, 446 (D.D.C.1986) (Parker, J.). “Hours that are not properly billed to one’s client also are not properly billed to one’s adversary pursuant to statutory authority.” Copeland v. Marshall, 641 F.2d 880, 891 (D.C.Cir.1980) (en banc). See also Laffey v. Northwest Airlines, Inc., 572 F.Supp. 354, 369 (D.D.C.1983) (Robinson, C.J.), reversed in part on other grounds by 740 F.2d 1071 (D.C.Cir.1984) (“Counsel is not free ... to exercise its judgment in a fashion that unnecessarily inflates the losing party’s fee liability”). The petitioner should exercise billing judgment, making “a good-faith effort to exclude from [his] fee request hours that are excessive, redundant, or otherwise unnecessary, just as a lawyer in private practice ethically is obligated to exclude such hours from his fee submission.” Hensley, 461 U.S. at 434, 103 S.Ct. 1933. As the Court of Appeals admonished in Copeland, however, a defendant “cannot litigate tenaciously and then be heard to complain about the time necessarily spent by the plaintiff in response.” 641 F.2d at 904. Third, “[cjompensable time should not be limited to hours expended within the four corners of the litigation.” Nat’l Ass’n of Concerned Veterans, 675 F.2d at 1335. The petitioner need only show that the hours for which he seeks compensation were “expended in pursuit of a successful resolution of the case in which fees are being claimed.” Id. While “no compensation should be paid for time spent litigating claims upon which the party seeking the fee did not ultimately prevail,” a reduction in fee is appropriate only when the non-prevailing matters “ ‘are truly fractionable.’ ” Copeland, 641 F.2d at 891-92 & n. 18 (quoting Lamphere v. Brown Univ., 610 F.2d 46, 47 (1st Cir.1979)). With this guidance in mind, the Court will analyze relator’s claimed hours along with defendants’ objections to them. The latter fall into two categories. First, defendants contend that certain tasks for which relator’s counsel have billed time in this case are per se non-compensable. Second, they cite several broader defects in relator’s counsel’s billing statements which they allege warrant across-the-board, percentage reductions in the fee award. The Court will address each category of complaints in turn. 1. Non-Compensable Tasks Defendants allege a variety of tasks are non-compensable. The Court has grouped their contentions under the following six subheadings. a. Criminal Case After relator filed his qui tarn complaint, the government delayed its prosecution of the civil case to pursue criminal, antitrust charges against Bilhar, Anderson, and others. (See generally Mem. Op. of June 14, 2007[872] at 18-26 (describing government’s deplorable lack of diligence as reason multiple claims must be dismissed as untimely).) During this period, relator’s counsel assisted him in securing immunity from criminal prosecution, in complying with obligations incurred as a result, and in responding to subpoenas in the criminal matter. (See Bell Decl. ¶¶ 12-19, Ex. 2 to Mot. for Fees, Costs, and Expenses [930]; Bell Supplemental Decl. ¶¶2-15, Ex. 1 to Reply to HII’s Opp’n [957].) Defendants argue these efforts are not compensable because the civil and criminal cases were separate and distinct matters, and because relator’s immunity deal, not his interest in the qui tam litigation, obliged him to cooperate with the Antitrust Division. (See BHIC and HUK’s Opp’n [948] at 3-5; HII’s Opp’n [949] at 4-7.) On the contrary, most of this work is compensable. Relator likely had more than one motivation to appear for depositions, provide documents, and otherwise assist the government with the criminal case. Compliance with the immunity letter’s terms was doubtless among them. He also had a strong financial incentive to cooperate: to ultimately secure his relator’s share, he needed to maintain good relations with DOJ, with whom he would prosecute the civil case as co-plaintiff, and to assist it in developing evidence that could be used in that case. His motives, however, are irrelevant. The information relator provided to the Criminal Division materially aided its investigation, and the Civil Division later relied on that investigation’s fruits in prosecuting the FCA case. (See Bell Deck ¶¶ 24-27, Ex. 2 to Mot. for Fees, Costs, and Expenses [930].) Relator’s cooperation during this early period ultimately proved crucial to the “successful resolution of the case in which fees are [now] being claimed.” See Nat’l Assoc. of Concerned Veterans, 675 F.2d at 1335. In other circumstances, courts have awarded attorneys’ fees for hours expended on prior litigation if those efforts also advanced the instant case. See, e.g., Kulkarni v. Alexander, 662 F.2d 758, 766 (D.C.Cir.1978) (legal services rendered in prior administrative proceedings and litigation pertaining to same claim were compensable because “holding of the first suit ... [was] a necessary predicate for a large part of [plaintiffs] claim in the present action”). This Court has no qualms about following suit and will compensate relator for time his counsel spent assisting him in complying with his immunity obligations and in responding to subpoenas in the criminal matter. This logic does not extend to time spent securing the government’s immunity grant, however. Bell now characterizes the immunity letter as “unnecessary” and insists relator would have aided the government regardless. (See Bell Supplemental Decl. ¶¶ 2, 14, Ex. 1 to Reply to HII’s Opp’n [957].) Thus, any work relator’s counsel performed to negotiate or effectuate the immunity deal had no impact whatever on plaintiffs’ subsequent success in the civil case and is therefore not compen-sable. b. Personal Matters Relator’s counsel’s billing statements include research and consultation concerning his personal, financial, and employment matters, and defendants contend these efforts in no way contributed to plaintiffs’ successful resolution of the instant case. Conceding to some of defendants’ objections, relator has excluded from his revised fee request time entries devoted to unrelated personal matters and preparation of counsel’s fee agreement. (See Bell Supplemental Decl. ¶ 25, Ex. 1 to Reply to HII’s Opp’n [957].) He has not, however, eliminated all challenged entries, and the Court will assess the remaining objections, i. Relator’s Attorney-Client Privilege Even before relator filed his original complaint under seal, his counsel began researching how to protect relevant documents potentially protected by attorney client privilege or the work product doctrine. Relator claims his counsel were simply being proactive, and that this research “was [ ] designed primarily to prevent eventual disclosure to the civil defendants in this litigation.” (Reply to HII’s Opp’n [957] at 21.) He points out that defendants sought and failed to obtain certain privileged documents at trial, and that his attorneys had an ethical obligation to preserve his privilege. (Id.) He does not, however, point to any evidence that supports his bald claim that his attorneys’ research and discussions in 1995 were primarily directed to protecting his privilege in a case that remained under seal until 2001. On reviewing the filings associated with defendants’ failed motion to compel and the challenged time entries, however, the Court concludes these hours are compen-sable. In the civil case, the magistrate judge denied defendants discovery of certain privileged materials that relator had voluntarily disclosed to the government, holding that plaintiffs’ common interest in the prosecution of common defendants in the then-existing civil case defeated waiver. (See Mem. Op. of Feb. 20, 2007[530] (denying motion to compel); Am. Mem. Op. of Mar. 27, 2007[750] (denying motion for reconsideration).) The subject matter of counsel’s earlier research suggests they had anticipated this very issue and wanted to ensure the common interest doctrine would protect disclosed materials in the later qui tarn litigation. Rationally, based on the results of these inquiries and discussions, counsel could limit the scope of relator’s disclosures to prevent defendants from gaming a tactical advantage in the civil ease. Because counsel’s early research allowed them to formulate a disclosure strategy focused on the qui tam litigation, the Court concludes these hours were “expended in pursuit of a successful resolution of the case in which fees are being claimed.” See Nat’l Ass’n of Concerned Veterans, 675 F.2d at 1335. ii. Relator’s Ongoing Employment at Jones Relator continued to work at J.A. Jones after filing his complaint under seal, which named his employer as a defendant. In connection with his continued employment at Jones, relator’s counsel: (1) analyzed his potential liability for removing confidential and privileged documents from his employer’s offices; (2) advised him on how to respond to an internal Jones investigation commenced after Jones received a grand jury subpoena; and (3) counseled him on how to effectuate his eventual resignation from Jones. Relator deems these tasks compensable because they are “related to representation of a whistleblower and the potential conflicts that arise from assisting the Government.” (Reply to BHIC and HUK’s Opp’n [960] at 8.) “Related to representation of a whistle-blower,” however, is not the standard in this Circuit for compensable time. While the Court accepts that “[c]ompensable time should not be limited to hours expended within the four corners of the litigation,” to hold that the hours challenged here were “expended in.pursuit of a successful resolution” of the qui tam case would render this phrase meaningless. See Nat’l Ass’n of Concerned Veterans, 675 F.2d at 1335. In analyzing his potential liability to his employer, relator’s counsel sought to protect their client from a counterclaim in the qui tam action or a collateral lawsuit. This was diligent lawyering, but it had no effect on the qui tam claims. Further, the narratives in counsel’s time records indicate they spent substantial time weighing whether relator should refuse to cooperate with his employer’s internal investigation. Whatever their substantive advice may ultimately have been — and it appears relator resigned rather than cooperate — counsel’s drawn out research and strategy development almost certainly hindered Jones’ own investigation of the fraud and may consequently have prolonged this litigation unnecessarily. Finally, advice concerning relator’s employment status lacks even a tenuous connection to the qui tam litigation. For example, relator does not attempt to explain, and the Court cannot surmise, how the “resignation script” his attorneys prepared for him could possibly have served to advance the qui tam litigation. (See 2/23/96 MLS.) Hence, the Court will not compensate relator for time his counsel expended on this set of tasks. iii. Relator’s Share and Attorneys’ Fees Even before relator filed his complaint, his counsel had begun estimating his potential bounty, and after DOJ prioritized the criminal case, counsel researched whether relator could claim a share of any criminal fines. When the Civil Division later settled with various defendants, relator’s counsel lobbied heavily for his share and sought attorneys’ fees from the settling defendants. Defendants object to time entries associated with each of these activities. Relator, of course, asserts that all are compensable. Fortunately, other courts have weighed these issues before. The Court of Appeals for the Sixth Circuit has considered whether the FCA requires a liable defendant to pay attorneys’ fees a prevailing relator incurs in pursuing his relator’s share. See Taxpayers Against Fraud, 41 F.3d at 1045-46. Relator Miller offers, in essence, the same argument the court rejected in that case: “ ‘that as between [him] and the wrongdoer [defendant], it is the wrongdoer who should bear the costs.’ ” See id. at 1046 (quoting Bigby v. City of Chicago, 927 F.2d 1426, 1428 (7th Cir.1991)) (second alteration in original). There, as here, the defendant had no “right to participate” in relator’s share negotiations between the relator and the government, and “nothing suggested] that [the defendant] prolonged the [ ] process or could have hastened its conclusion.” Id. Thus, the court concluded, “the defendant [] should not be required to pay the costs incurred by the prevailing plaintiffs in the course of their collateral litigation.” Id, This Court finds the Sixth Circuit’s reasoning persuasive and will follow it here. Accordingly, hours relator’s counsel devoted to recovery of a relator’s share from the government are not compensable. Authority from this Circuit speaks to the second issue presented here: whether a relator may recover attorneys’ fees from non-settling defendants for time devoted to obtaining such fees from settling defendants. “It is well settled that hours reasonably devoted to negotiating and/or litigating a statutory fee award are compensable.” Laffey v. Northwest Airlines, Inc., 572 F.Supp. 354, 367 n. 21 (D.D.C.1983), reversed in part on other grounds by 740 F.2d 1071 (D.C.Cir.1984). See also Copeland v. Marshall, 641 F.2d 880, 896 (D.C.Cir.1980) (en banc) (“time spent litigating the fee request is itself compensable”). Thus, the only remaining question is whether liability for attorneys’ fees under the FCA is joint and several, such that non-settling defendants share liability for fees incurred in obtaining fees from settling co-defendants. Though never presented with the precise situation here, other courts have unanimously concluded that fee liability under the FCA is joint and several. See United States ex rel. Greendyke v. CNOS, P.C., No. 04-4105, 2007 WL 2908414, *7, 2007 U.S. Dist. LEXIS 72987, at *21-22 (D.S.D. Sept. 27, 2007) (adhering to “general rule that co-defendants are to be held jointly and severally liable for costs and attorney’s fees,” where defendants failed to cite authority for departing from it); United States ex rel. Abbott-Burdick v. Univ. Med. Assocs., No. 96-1676, 2002 WL 34236885, **4-5, 2002 U.S. Dist. LEXIS 26986, at *18-20 (D.S.C. May 23, 2002) (holding defendants jointly and severally liable for attorneys fees because FCA’s “other provisions dictate a joint and several relationship among culpable parties,” and due to “unequivocal congressional intent of encouraging qui tam suits and the unique pro-plaintiff structure of litigation under the [FCA]”); United States ex rel. Wiser v. Geriatric Psychological Servs., Inc., No. 96-2219, 2001 WL 286838, *3, 2001 U.S. Dist. LEXIS 12930, at *11 (D.Md. Mar. 22, 2001) (holding that “attorneys fees awarded under 31 U.S.C. § 3730(d)(1) should [not] be apportioned among defendants [because] all other recovery need not be”). Thus, under a scheme of joint and several liability for attorneys’ fees, if hours devoted to obtaining fees are, themselves, compensable, then each and every defendant against whom relator prevails is liable for fees the relator incurred in obtaining fees from each and every other non-prevailing defendant. The hours relator’s counsel spent attempting to recover attorneys’ fees from settling co-defendants are thus compensable. c. Settlement Efforts Relator’s petition also includes hours his counsel spent in settlement negotiations with various defendants, both successfully and unsuccessfully, and in court-ordered mediation. Contrary to defendants’ protests, these tasks are uniformly compensa-ble. The FCA’s qui tam provisions make clear that a prevailing relator may recover fees when settlement efforts succeed. See 31 U.S.C. § 3730(d)(1) (2008). Under the statute, a relator receives a share “of the proceeds of the action or settlement of the claim,” and any person who receives such a share “shall also receive ... reaso