Full opinion text
ORDER — ATTORNEYS’ FEES AND EXPENSES WILLIAM D. BROWNING, Chief Judge. This Order addresses the petitions of plaintiffs’ counsel for attorneys’ fees and expenses in this action. Initial fee petitions were filed in early 1989 prior to hearings held on April 11 and 12, 1989, in the United States District Court in Seattle, Washington, concerning the fairness, reasonableness and adequacy of settlements reached in this massive multi-district securities litigation. See Notice of Settlements and Settlement Hearings and Class Certification at 12, February 6, 1989. On September 5, 1989, in an opinion that recounted the history of this litigation, the Court approved the settlements that were the subject of the April 1989 hearings. In re Washington Public Power Supply System Secur. Litigation, 720 F.Supp. 1379 (D.Ariz.1989). The Court reserved jurisdiction over the attorneys’ fee petitions and over matters concerning the allocation and distribution of settlement proceeds among various claimants to the settlement funds. On July 24, 1990, after notice to all Class members and known bondholders, and after extensive briefing, a hearing was held in New York City concerning the allocation of settlement proceeds among claimants to the fund, other than these petitioning attorneys. The Court’s decision regarding the allocation of settlement proceeds among and between Class members and Chemical Bank on behalf of the Bond Fund was rendered the following month. (Order dated August 15, 1990.) CONTENTS THE FEE AND EXPENSE PETITIONS 1078 The Petitioners 1079 Class Counsels’ Petition 1080 AMBAC Petition 1082 The Haberman Petitions 1082 LEGAL STANDARDS 1082 METHODS OF FEE DETERMINATION 1084 Percentage-Based Fee Awards 1084 Blended Lodestar Analysis 1087 Fee Enhancements — The Use of Multipliers 1088 DETERMINATION OF THE LODESTAR 1091 General Comments Regarding the Fee Petitions 1092 Class Counsels’ Fee Petition 1092 Haberman and AMBAC Petitions 1094 GUIDELINES USED IN REVIEWING THE PETITIONS 1094 The Time and Labor Required 1094 Paralegal Time and Labor 1097 The Novelty and Difficulty of the Questions 1097 The Results Obtained and Amount Involved 1097 The Rates Charged 1099 Paralegal Rates 1100 The Nature of the Fee 1101 The Desirability or Undesirability of the Case 1101 Preclusion of Other Employment 1101 The Nature and Length of the Professional Relations with the Client 1102 Time Limitations Imposed 1102 Awards in Similar Cases 1102 EXPENSE REIMBURSEMENT REQUESTS 1102 LODESTAR FEE AND EXPENSE AWARDS 1103 Bernstein Litowitz Berger & Grossmann 1103 Milberg Weiss Bershad Specthrie & Lerach 1112 Shidler McBroom Gates & Lucas 1128 Barrack, Rodos & Bacine 1135 Berger & Montague, P.C. 1140 David B. Gold, P.C. 1145 Goodkind, Labaton & Rudoff 1149 Graham & Dunn 1155 Harvey Greenfield 1159 Hallisey & Johnson 1162 Kaufman Malchman Kaufmann & Kirby 1164 Meredith & Cohen, P.C. 1166 Molloy, Jones & Donahue, P.C. 1168 Much Shelist Freed Denenberg Ament & Eiger, P.C. 1171 Allan Peckel and Rabin & Silverman 1174 Pomerantz Levy Haudek Block & Grossman 1176 Sachnoff Weaver & Rubenstein, Ltd. 1180 Saveri and Saveri 1185 Schoengold & Sporn, P.C. 1187 Stull, Stull & Brody 1191 Wolf, Block, Schorr & Solis-Cohen 1193 Wolf Haldenstein Adler Freeman & Herz 1196 Wolf Popper Ross Wolf & Jones 1201 Zwerling, Schachter & Zwerling and Prince, Kelley, Newsham & Marshall, P.S. 1206 WPPSS Litigation Fund 1209 SUMMARY OF CLASS COUNSEL AWARDS 1211 Attorney Lodestar Summary 1211 Paralegal Lodestar Summary 1212 Expense Reimbursement Summary 1213 CHEMICAL BANK EXPENSES 1213 AMBAC INDEMNITY CORPORATION COUNSEL (FOLEY & LARDNER) 1220 HABERMAN COUNSEL 1223 Winthrop Stimson Putnam & Roberts 1225 Smith Smart Hancock Tabler & Middlebrooks 1228 GORDON THOMAS HONEYWELL 1228 AWARDS 1228 INTEREST 1229 ORDER 1229 FINAL JUDGMENT 1230 THE FEE AND EXPENSE PETITIONS The initial fee petitions, filed in connection with the April 1989 hearings, encompass counsels’ request for payment for work performed from the inception of this litigation through early 1989. A number of petitioning firms have since submitted supplemental reports for work done after the period covered by their initial petitions. The Court advised counsel that the amounts of fees and expenses reported in those supplemental reports, for work performed through December 31, 1989, would also be deemed petitioned for unless counsel objected promptly. (Minute Order, April 2, 1990.) On June 5,1990, Class counsel moved for relief from the April 2,1990, Minute Order. The Court has considered Counsel’s belated arguments and will not grant the relief requested. The Court has reviewed the nature of the work reported in the supplemental petitions and has determined, however, that an award for some of the work reported therein should not be considered, nor made, at this time. I will therefore defer consideration of certain undertakings until such time as a supplemental fee petition is filed. Deferral has been made, in particular, for work that clearly involved efforts related to on-going insurance litigation, as opposed to work more directly stemming from the settlement of MDL 551, or from the fee petitions that are the subject of this Order. The work of each attorney for which consideration has been deferred is indicated herein. With the exception of some post-petition work that has been deferred for the Court’s future consideration, therefore, today’s Order contemplates the aggregate of the amounts reported in both the initial petitions and in supplemental reports. The period of time encompassed by this Order, thus, extends from pre-1983 through December 1989 — more than seven years. It is understatement to say that this fee petition is, like the litigation itself, massive. The total amount sought at this time out of the settlement proceeds is slightly in excess of $162,327,340. Of that amount, approximately $54 million represents expenses amassed in connection with the litigation. The remaining $108 million request is for attorneys’ and paralegal fees. The petitions reflect a total of nearly 205,-000 hours of work performed by more than 340 different attorneys and approximately 250 paralegal employees. Described differently, the reported hourly figure converts to roughly one hundred working man-years. During the past months, the Court has methodically and painstakingly scrutinized the voluminous materials submitted by the petitioning firms in support of their reported fees and expenses. Numerous requests for explanatory information were made, and several Orders were issued requiring additional data. Various memoranda, declarations and affidavits submitted in support of and in opposition to the fee petitions have been studied. Relevant caselaw has been exhaustively analyzed. The amounts awarded herein will undoubtedly be viewed as both too generous and too restrictive by Class members, attorneys, objectors and others. My determinations reflect a tremendous amount of work, attention to detail and concern for fairness to all parties. As is to be expected, difficult and demanding decisions were required. Many decisions were subjective and not capable of calculation. They were not, however, arbitrary. I am keenly aware of the exceptional ability and industry of counsel in this case. Class Plaintiffs’ Lead counsel commanded the respect of the Court and all others. It should be beyond cavil that there is no imputation or implication of dishonesty or overreaching in connection with these fee applications. The question of supportability has been the overriding consideration throughout. In cases such as these, years intervene between the fee generating event and its review by the court. Memories fade, so it is impossible to re-create accurately the exact nature of services rendered if they are not adequately described at or near the time performed. There is also a lack of periodic review of services and charges that normally marks the attorney-client relationship and the attendant lack of ability of the client to question charges when events are fresh. Likewise, the attorney lacks the opportunity to justify charges when specific events are fresh in his or her own mind. If there is a message in the Court's treatment of the fees requested, it is that the requests were inadequately documented. Future common fund applicants should note that the awarding court will necessarily require comprehensive documentation of time spent on specific tasks in order to discharge its fiduciary duty to Class members. The court must apply scrutiny such that its decisions will be presented to Class members, counsel and any reviewing court as a reasoned and objective analysis and resolution. The Petitioners Thirty-two different law firms have applied for reimbursement of fees and/or expenses. Twenty-five of these firms participated, to one degree or another, as counsel for the Class Plaintiffs in this litigation. Initially, these firms submitted a joint petition for fees and expenses. These twenty-five firms will be referred to herein as “Class counsel.” Included with the petition of Class counsel is a request for reimbursement of expenditures made by the “WPPSS Litigation Fund” (“Litigation Fund” or “Fund”). This Fund was established and operated by Class counsel early in the litigation. It was managed by an attorney from one of the petitioning Class counsel firms. The Fund was established by means of monetary assessments of twenty-three of the firms that have filed a joint petition for fees. Litigation Fund expenditures were of two primary types: (1) reimbursement to Class counsel for litigation expenses reported to the Fund, and (2) payment of other litigation expenses. One other petition for reimbursement of expenses is before the Court. An application for more than $51 million was filed by Class counsel on behalf of Chemical Bank, the Bond Fund Trustee. The requested amount represents reimbursement sought, in large part, for expenses paid by Chemical in connection with the establishment and operation of a Data Center in Seattle, Washington, and a Trial Support Service facility in Tucson, Arizona, pursuant to an agreement between Chemical and Class counsel. This agreement, and the operations and expenditures it concerned, are discussed more fully herein in the section entitled “Chemical Bank Expenses.” An additional petition was submitted for payment for work done on behalf of AM-BAC Indemnity Corporation (formerly MGIC Indemnity Corporation), one of the Class members in the MDL 551 litigation. These petitioners will be referred to as “AMBAC counsel.” Another six law firms have submitted petitions for work done primarily in connection with litigation that was undertaken in the state courts of Washington and reported under the caption Haberman v. Washington Public Power Supply System, 109 Wash.2d 107, 744 P.2d 1032 (1987), mod. Haberman v. Washington Public Power Supply System, 750 P.2d 254 (Wash.1988), app. dismd. American Express Travel Related Services Co. v. Washington Public Power Supply System, 488 U.S. 805, 109 S.Ct. 35, 102 L.Ed.2d 15 (1988). These firms represented various plaintiffs, some of whom were Class members in MDL 551, in the state court litigation. Class Counsels’ Petition Class counsel submitted several documents in connection with their fee application. The “Declaration of Lead Counsel in Support of the Proposed Settlements and Class counsel’s Joint Application for Fees and Reimbursement of Expenses” was submitted by Lead Counsel in the litigation: Paul M. Bernstein, of the law firm of Bernstein Litowitz Berger & Grossman; Melvyn I. Weiss, of Milberg Weiss Bershad Spec-thrie & Lerach; and James R. Irwin, of Shidler McBroom Gates & Lucas. This Declaration was submitted in support of the Court’s approval of both the proposed settlements and of the joint application of Class counsel for an award of fees and reimbursement of expenses. Accompanying the Declaration of Lead Counsel were twenty-five separate “Declarations of Each Plaintiffs’ Class Counsel Re Lodestar and Expenses.” The declarations contain information regarding the hours, rates and expenses of each law firm, and the WPPSS Litigation Fund, that requested reimbursement in the initial petition. A third document, “Memorandum of Points and Authorities in Support of Application for Award of Fees and Reimbursement of Expenses of Class Plaintiffs’ Counsel,” accompanied by the “Declaration of Melvyn I. Weiss in Support of Memorandum of Points and Authorities in Support of Application for Award of Fees and Reimbursement of Expenses of Class Plaintiffs’ Counsel” was also submitted with Class counsels’ initial petition. Additionally, in February, 1989, Class Plaintiffs Counsel submitted “Class Plaintiffs’ Memorandum Regarding the Legal Standards Governing the Award of Attorney’s Fees” to the Court. That memorandum has today been made part of the record. Together, the documents described above comprise Class counsels’ petition. To supplement and support its petition, every firm was required to submit copies of the contemporaneous records reflecting the amount of time and the nature of each activity undertaken by each individual petitioning attorney and paralegal for which payment is sought. Furthermore, throughout the course of the litigation, beginning in the fall of 1984, all firms that anticipated the possibility of applying to the Court for an award of attorneys’ fees were required to provide the Court with a bi-monthly report indicating the billing rate and number of hours worked on the litigation for every attorney or paralegal in the firm (“Lodestar Reports”). In October, 1989, counsel were ordered to continue to submit similar reports, on a quarterly basis, for work done subsequent to the initial petition. Those reports, for work reported through December 31, 1989, have been deemed by the Court, and are referred to herein, as “supplemental petitions.” All of these documents have today been sealed and made part of the record of this litigation. They are not be opened except under Order of this Court. Many of the records, particularly those that meet the criteria of proper fee applications, contain accounts of petitioning attorneys’ undertakings that are, arguably, work product. The Court has been careful, in this Order, not to divulge sensitive information. It will not expose counsels’ methods and tactics, suggested and revealed within those records, unnecessarily. At the time of the initial application, Class counsels’ petition was supported by a reported lodestar of $33,271,203. Class counsel requested a fee award of $102,992,-564, noting that the amount was approximately 3.1 times the reported lodestar. Counsel proposed that the award be distributed among the twenty-five Class counsel firms in a manner reflecting lead counsel’s appraisal of a number of factors relevant to each petitioning firm's contribution to the litigation. The following table shows the amount that lead counsel proposed to distribute to each firm. Following each firm’s proposed share is the multiplier by which the firm’s reported lodestar amount was increased to arrive at the firm’s proposed share. Firm Fee Requested Bernstein Litowitz Berger & Crossman $ 26,796,240 I — Milberg Weiss Bershad Specthrie & Lerach 31,702,554 I — Shidler McBroom Gates & Lucas 15,450,697 I — Molloy, Jones & Donahue 968,073 I — Graham & Dunn 2,625,005 I — David B. Gold 3,271,912 I — & Montague, P.C. 2,576,678 I — Wolf Ross Wolf & Jones 2,392,767 I — Saveri & Saveri 2,237,409 I — Schachter & Zwerling 1,541,776 I — Wolf Haldenstein Adler Freeman & Herz 1,488,920 I — Goodkind, Labaton & Rudoff 1,208,489 I — Meredith & Cohen 920,085 I — Barrack, Rodos & Bacine 918,961 I — Sachnoff, Weaver & Rubenstein 891,302 I — Block, Schorr & Solis-Cohen 829,231 I — Pomerantz Haudek Block & Grossman 748,456 I — Much Shelist Freed Denenberg Ament & Eiger 699,083 I — & 677,712 I — Kaufman, Malchman & Kirby 393,758 I — Stull & 230,813 I — Hallisey & Johnson/O’Brien & Hallisey 99,617 I — Prince, Kelley & Newsham (by Zwerling) 25,798 I — Allan K. Peckel 3,816,661 I — Harvey Greenfield & Franco Asia 480,567 TOTAL Class counsel $102,992,564 The amount initially requested for attorneys’ fees was also described as “constituting” 13.6% of the settlement fund. Class counsel urge that the requested award is appropriate whether the Court adopts an approach approving such a “percentage-of-the-fund” award, or whether it approves an award based upon use of their reported lodestar enhanced by a multiplier. In addition to Class counsel’s request for fees, the petitioning firms also requested reimbursement of $2,336,438 for expenses incurred in connection with the litigation. That figure increased to $2,482,584.40 as a result of additional work reported through December 31, 1989. AMBAC Petition The law firm of Foley & Lardner petitions the Court for fees and expenses in connection with its representation of AM-BAC Indemnity Corporation. Foley & Lardner seeks an award of fees for attorney and paralegal services on behalf of this Class member totalling $134,886. The firm also requests reimbursement for expenses amounting to $9,964. The Haberman Petitions The Haberman petitioners represented plaintiffs in the Washington state courts. Four firms petition for their representation of individual bondholders. Collectively, the four firms are referred to herein as “Ha-berman Plaintiffs’ Counsel.” Two other firms seek recovery of fees and expenses for work done on behalf of Haberman Plaintiff Intervenors — American Express Travel Related Services Company, Inc., American Express Bank, Ltd., Fireman’s Fund Company, The American Insurance Company and Associated Indemnity Corporation and United States Trust Company of New York, as Trustee. Together, these firms are referred to as “Haberman Inter-venors’ Counsel.” The Haberman petitioners and the amounts sought by each firm are indicated in the following table. In some instances the amounts in initial petitions have been adjusted for mathematical corrections and/or to reflect supplemental petitions submitted. These last seven firms seek fees amounting to reported lodestar amounts. They seek neither a multiplier of such amounts nor a particular percentage of the settlement reached in MDL 551. LEGAL STANDARDS The ordinary rule in the American legal system precludes prevailing litigants from collecting attorneys’ fees from the losing party. Alyeska Pipeline Service Co. v. Wilderness Soc., 421 U.S. 240, 95 S.Ct. 1612, 44 L.Ed.2d 141 (1975). There are exceptions to this rule, however. One exception, long entrenched, permits proper allowances to persons who have instituted proceedings for the benefit of a general fund. Trustees v. Greenough, 105 U.S. 527, 535-36, 26 L.Ed. 1157 (1882). Courts possess equitable powers to permit persons recovering a fund for the benefit of others to recover costs, including attorneys’ fees, from the fund itself. Alyeska, 421 U.S. at 257, 95 S.Ct. at 1621. The fund amassed as a result of the settlement of the MDL 551 securities class action litigation under Fed. R.Civ.P. 23 meets the requirements of this “common fund” exception to the general American rule that would otherwise require every litigant to bear his or her own attorneys’ fees. Under the common fund doctrine, an attorney may be awarded fees and costs in recognition of efforts that resulted in the creation, preservation or protection of a fund that benefits the class whom the attorney represents. The attorney’s fees and expenses are paid out of the fund. Without such compensation, the beneficiaries of the fund would enjoy its benefits without sharing the costs of acquiring it. To avoid such unjust enrichment, the costs of creating or preserving the common fund are shared by the entire class that has benefit-ted by the attorney’s representation. In re Nucorp Energy, Inc., 764 F.2d 655, 661 (9th Cir.1985), citing Pawlak v. Greenawalt, 713 F.2d 972, 981 (3rd Cir.1983). The Court acts as a fiduciary, a guardian of the rights of absent class members, in deciding an award of attorneys’ fees in a class action. Grunin v. International House of Pancakes, 513 F.2d 114, 123 (8th Cir.1975), cert. denied, 423 U.S. 864, 96 S.Ct. 124, 46 L.Ed.2d 93 (1975); Detroit v. Grinnell Corp., 560 F.2d 1093, 1099 (2d Cir.1977) (“Grinnell II”); In re Capital Underwriters, Inc. Secur. Litigation, 519 F.Supp. 92, 98 (N.D.Cal.1981); In re Equity Funding Corp. Secur. Litigation, 438 F.Supp. 1303, 1325 (C.D.Cal.1977). Characteristically, defendants have no adversarial interest in fee petitions and no further interest in a fund that is composed of their contributions to settle an action. Plaintiffs’ counsel, otherwise a fiduciary for the class, has become a claimant against the fund created for the benefit of the class. It is obligatory, therefore, for the trial court judge to act with “a jealous regard to the rights of those who are interested in the fund” in determining what a proper fee award is. Trustees, 105 U.S. at 536. The common fund doctrine permits the Court to “make fair and just allowances for expenses and counsel fees to [those] parties promoting litigation.” Id. The doctrine requires such awards to be made with moderation, id., and to reflect the reasonable value of the attorneys’ services that resulted in the benefits conferred on the class. Lindy Brothers Builders, Inc. v. American Radiator & Standard Sanitary Corp., 487 F.2d 161, 165 (3d Cir.1973), aff'd in part, 540 F.2d 102 (3d Cir.1976) {“Lindy /”); Manual for Complex Litigation, Second, § 24.12 (1985). The Court has a great deal of discretion in deciding the amount of fees to be awarded. That discretion is not unrestricted, however. It must be exercised soundly, supported by meaningful reasoning, and be based on sufficient information. Kerr v. Screen Extras Guild, Inc., 526 F.2d 67, 69 (9th Cir.1975); Moore v. Jas. H. Matthews & Co., 682 F.2d 830, 838 (9th Cir.1982); Lindy I, 487 F.2d at 166). Above all, the awarded fee must be reasonable. See Pennsylvania v. Delaware Valley Citizens’ Council for Clean Air (“Delaware Valley I”), 478 U.S. 546, 106 S.Ct. 3088, 92 L.Ed.2d 439 (1986). Just as the Court must avoid awarding “windfall fees,” it must avoid any appearance of having done so. Detroit v. Grinnell Corp. (“Grinnell I”), 495 F.2d 448 (2nd Cir.1974); Equity Funding, 438 F.Supp. at 1325. The determination of a reasonable fee requires the Court to assess the reasonableness of the amount requested in light of several somewhat conflicting rationales. First, fee awards must be adequate to ensure that attorneys will be motivated to undertake representation in class action litigation. Equity Funding, 438 F.Supp. at 1325; Feuerstein v. Burns, 569 F.Supp. 268, 271 (S.D.Cal.1983). At the same time it must be recognized that the opportunity to represent the class as lead counsel is judicially determined. Class representation is also characterized, in part, as containing an element of public service. This is particularly true of litigation such as this, which arose in the context of the federal securities laws. Those laws are remedial in nature, and private lawsuits to effectuate their statutory purpose of protecting investors are both necessary and important. See Bateman Eichler, Hill Richards, Inc. v. Berner, 472 U.S. 299, 310, 105 S.Ct. 2622, 2628-29, 86 L.Ed.2d 215 (1985); Herman & MacLean v. Huddleston, 459 U.S. 375, 103 S.Ct. 683, 74 L.Ed.2d 548 (1983). METHODS OF FEE DETERMINATION Courts have used different methods in making fee determinations. Some courts have awarded petitioning counsel a percentage of the fund. Others have adhered to the lodestar approach developed in Lindy I and refined in Lindy Bros. Builders, Inc. v. American Radiator & Standard Sanitary Corp. (“Lindy II”), 540 F.2d 102 (3d Cir.1976), multiplying the hours worked by the normal billing rate of the attorneys and adjusting the result, through the use of a “multiplier,” for “contingency” or “quality considerations. This Circuit approves an approach that entails examination, in an orderly lodestar analysis, of factors referred to as the “Kerr guidelines.” These guidelines were adopted “as appropriate factors to be considered in the balancing process required in a determination of reasonable attorney’s fees.” Kerr, 526 F.2d at 70. The approach that incorporates their consideration in the court’s determination of a reasonable fee is described as a “blend” of lodestar and Kerr analysis. Moore, 682 F.2d at 838-40. Class counsel urge this Court to adopt either the percentage-of-recovery or a “lodestar/multiplier” approach in making its fee award. Percentage-Based Fee Awards Class counsel request a fee that is approximately 13.6% of the settlement fund. They contend that this would be a reasonable fee. Counsel suggest that the percentage method could be employed here either to determine their fee or, alternatively, to confirm the propriety of the amount they request. (The requested amount can also be computed by applying the requested multiplier to Class counsels’ reported lodestar.) It is the first suggestion — use of the percentage method to determine a fee — that this section addresses. A number of factors preclude use of this method. First, a variety of circumstances reveal that the percentage sought by Class counsel is, in fact, an artificial and fallacious figure. Class counsels’ requested fee actually represents a percentage of the amount of settlement funds that were projected to exist at a future time. Defendants’ settlement contributions amounted to a pre-interest total of approximately $690 million. The amount of fees requested by class counsel in this petition is approximately 14.9% of that pre-interest settlement amount. As a result of interest earnings, the settlement fund was expected to be approximately $757 million by December 1989. That figure, thus, included some $67 million in interest. It was the amount used by class counsel to compute the requested percentage, however. As a result of continued accrual of interest after the date selected by Class counsel, the fund has substantially increased, and the percentage derived by comparing the amount requested to the increasing fund has correspondingly decreased. Thus, even if the Court were to award the amount requested, using Class counsels’ approach of applying the pre-interest amount of an award to an after-interest amount of the fund, the percentage calculated would be constantly diminishing. The Court rejects the “moving-target” aspect inherent in this approach, and further concludes that, ignoring other relevant factors, 14.9% more accurately describes the percentage of fees actually requested by Class counsel. Other relevant factors also render Counsels’ percentage computation fallacious. As a result of the allocation to Chemical Bank of $50 million of the settlement fund’s principal, See Order dated August 15, 1990, fair treatment would require use of a figure amounting to $640,000,000, not $690,000,000, in computing the percentage to which Class counsels’ request equates. This would further enlarge the percentage actually requested. Even this would not result in a valid figure, however. Class counsel petition for payment of a substantial amount of paralegal fees through the Chemical Bank expense reimbursement request. A determination of the total amount of fees requested by Class counsel would require inclusion of amounts that are related to paralegal fees in that petition. Similarly, fees petitioned for and awarded herein to non-Class counsel firms for work done on behalf of Class members would also require inclusion. Addition of these amounts to Class counsel’s petition would significantly increase the requested percentage. Thus it would be misleading to contend that Class counsels’ request even amounts to just 14.9% of the settlement fund. Undeniably, application of an appropriate percentage to the settlement fund would provide an uncomplicated solution to this undertaking. A number of considerations preclude such a simplistic approach, however. Foremost among them is the requirement in this Circuit that the Court conduct an analytical evaluation to determine a reasonable fee. Further, even assuming a percentage-based methodology were acceptable here, the Court finds insufficient guidance to prescribe an appropriate percentage. There is no rationale that would sustain the use of 13.6% (or 14.9%) as precisely the appropriate percentage. Independent of other considerations, a figure of 16.3%, or 3.6%, or 36.1%, might just as well be urged. All of these numbers are arbitrary. Given the variances in the sizes of settlement funds, Class counsels’ data, intended to demonstrate that the percentage they request is far less than the norm, aptly demonstrate the virtually impossible task of setting any particular percentage as a proper one. While many sources indicate that a fee in the range of 20% to 40% may be typical, see, e.g., In re TSO Financial Litigation, Nos. 87-7903, 87-7961, 87-8302, 1989 WL 80316 (E.D.Pa.1989), or that, for example, 25%, or 30%, may be an appropriate “benchmark,” e.g., Paul, Johnson, Alston & Hunt v. Graulty, 886 F.2d 268, 272 (9th Cir.1989), citing Mashburn v. National Healthcare, Inc., 684 F.Supp. 679, 692 (M.D.Ala.1988); In re Activision Secur. Litigation, 723 F.Supp. 1373 (N.D.Cal.1989), it cannot go unnoticed that the immense size of the settlement fund in this action far exceeds the amount of settlement funds in virtually all similar cases that counsel have cited and/or that the Court has reviewed. Just one percent of the settlement in this action is the equivalent of nearly seven million dollars. Every adjustment of .1% (Vioth of one per cent) in an applied percentage would result in a fee variance amounting to approximately $700,-000. A 5% modification in the percentage selected to compute an award would equate to a fee increase or decrease of almost $35,000,000. Fee awards frequently do not fall in the “typical” range. There is abundant authority that suggests that, as the amount of a settlement fund increases, the percentage of an award should decrease. The proper extent of a corresponding decrease has not been satisfactorily resolved, however, and the Court has found no authority that address a potentially appropriate percentage where the settlement fund is as extraordinarily large as it is here. In the absence of specific guidance requiring the application of an appropriate percentage to a given settlement amount, thus, the Court is reluctant to apply any percentage in order to determine a fee award. That 20% to 45% of the fund may have been awarded in the “overwhelming number” of common fund situations suggests little if anything about what might be an appropriate award in this uncommon case. The recommendation of the Third Circuit Task Force dictates against use of a percentage-based fee in this case. The Task Force, chaired by the Honorable H. Lee Sarokin, United States District Court Judge for the District of New Jersey, appointed Professor Arthur Miller of Harvard, as its Reporter. The Task Force recommended that, upon counsels' motion, or on the court’s initiative, a percentage fee arrangement should be established, after arm’s length negotiations, by the court and counsel early in the litigation. Court Awarded Attorney Fees, Report of the Third Circuit Task Force, 108 F.R.D. 237, 255 (1985). No motion was made by MDL 551 Class counsel, when the Task Force report was published, when the Class was certified, or at any other time during the litigation to establish a percentage fee arrangement satisfactory to the Court. The time to negotiate such an arrangement has passed. The element of contingency, crucial to such negotiations, is absent, and the incentives to be gained from the establishment of such a percentage have been foregone. Furthermore, the Task Force observed that a pre-negotiated percentage would involve a sliding scale, dependent on the ultimate amount recovered, and would decrease with corresponding increases in the fund. In a footnote, the Task Force noted that negotiated percentage ranges might include relatively small percents. As an example, the Task Force cited the Agent Orange settlement, noting that plaintiffs’ attorneys in that litigation were awarded over $10 million, a fee that equalled only about six percent of the settlement fund. Id. at 256. See In re “Agent Orange” Product Liability Litigation, 611 F.Supp. 1296 (E.D.N.Y.1985), aff’d in part and rev’d in part In re “Agent Orange” Product Liability Litigation, 818 F.2d 226 (2d Cir.1987). Here, the Court is faced with a fee request nearly ten times the Agent Orange award and a settlement sum about four times as large. Class counsel also do not acknowledge the impact of existing fee agreements on other courts’ decisions to grant percentage-based fee awards. Typically, the cases in which a fee was determined in this manner arose from situations in which a contingency fee arrangement provided guidance and supported a percentage-based fee award. See, e.g., Graulty, 886 F.2d 268; Kirkorian v. Borelli, 695 F.Supp. 446, 455 (N.D.Cal.1988). Such a situation does not characterize this litigation. Counsel rely on a footnote in Blum v. Stenson, 465 U.S. 886, 104 S.Ct. 1541, 79 L.Ed.2d 891 (1984), in attempting to persuade the Court that the percentage method is the “proper approach” to computing fees in common fund cases. The Blum footnote appears in a section of the opinion observing the general unacceptability of a fee enhancement for “results obtained” in litigation. The footnote appears to have been intended to demonstrate that use of a percentage-based fee could result in inadequate compensation to attorneys in federal civil rights litigation, where a fund might be small relative to the amount of effort required by attorneys to generate the fund. Application of a percentage in such situations would not only result in insufficient compensation, but would also discourage 42 U.S.C. § 1988 litigation. See Rothfarb, 649 F.Supp. at 185 n. 1. The Blum footnote indicates the Supreme Court’s recognition that the percentage of recovery approach may have legitimate application in appropriate common fund cases. This may be so, for instance, where pre-existing contingent fee agreements provide for a specific percentage recovery. See e.g. Graulty, 886 F.2d at 272; Kirkorian, 695 F.Supp. at 446. It does not mandate such an approach. In appropriate circumstances, determination of reasonable compensation for creating a common fund may be accomplished by multiplying the number of hours reasonably spent by a reasonable hourly rate, and then enhancing that figure, if necessary, to account for the risks associated with the representation. Graulty, 886 F.2d at 272. Where special circumstances indicate that a percentage recovery would be too large in light of the time spent on the case, or other relevant factors, the use of a benchmark percentage may properly be supplanted by a lodestar calculation. Six (6) Mexican Workers v. Arizona Citrus Growers, 904 F.2d 1301, 1311 (9th Cir.1990). This action, the amount of the settlement, and the accompanying fee and expense petitions, are replete with special circumstances that dictate against the application of a percentage. See Florida v. Dunne, 915 F.2d 542 (9th Cir.1990). Finally, although the Ninth Circuit has not disapproved the use of the percentage of recovery approach in an appropriate case, Kirkorian, 695 F.Supp. at 455, it has certainly approved, if not required, the blending of the Kerr guidelines in a lodestar analysis in multidistrict securities actions such as this. Moore, 682 F.2d at 840 (approving the district court’s blended approach in Capital Underwriters); See also, Donnarumma v. Barracuda Tanker Corp., 79 F.R.D. 455, at 462 and n. 12 (C.D.Cal.1978). Blended Lodestar Analysis The Ninth Circuit has repeatedly held that it is an abuse of discretion for a district court to award fees without considering the Kerr guidelines. Moore, 682 F.2d at 838. The guidelines enumerate factors that should be considered in awarding fees. The court’s consideration of at least some of the twelve guidelines helps to assure a meaningful review of fee applications. The twelve Kerr factors are: (1) the time and labor required (2) the novelty and difficulty of the questions involved (3) the skill necessary to perform the legal services properly (4) the preclusion of other employment by the attorney due to acceptance of the case (5) the customary fee (6) whether the fee is fixed or contingent (7) time limitations imposed by the client or circumstances (8) the amount involved and the results obtained (9) the experience, reputation and ability of the attorneys (10) the “undesirability” of the case (11) the nature and length of the professional relations with the client, and (12) awards in similar cases Johnson v. Georgia Highway, 488 F.2d 714 (5th Cir.1974), adopted by the Ninth Circuit in Kerr, 526 F.2d at 69-70. Application of these factors in the context of a lodestar analysis eliminates flaws that would exist if, instead, an independent application of either approach were undertaken. Use of the lodestar framework provides structure that is given flexibility through incorporation and consideration of the Kerr factors in the analysis. Use of the lodestar framework helps, for example, to avoid improper effects of redundancy in the Kerr guidelines. Use of the Kerr guidelines permits a meaningful evaluation of the reasonableness of the hours worked and the rates charged that is not achieved in a “pure” lodestar approach. Blending of the two methods thus permits a systematic and substantive analysis resulting in a determination of a lodestar figure that reflects the number of hours reasonably worked and the reasonable rates at which the hours were worked. See Moore, 682 F.2d at 839-41. A strong presumption exists that this figure represents a reasonable attorneys’ fee. Delaware Valley I, 478 U.S. at 565, 106 S.Ct. at 3098; Jordan v. Multnomah County, 815 F.2d 1258, 1263 (9th Cir.1987). Although the lodestar will normally provide full and reasonable compensation, in rare cases, marked by exceptional success, an enhanced award may be justified. Blum, 465 U.S. at 901, 104 S.Ct. at 1550. In such rare cases, the lodestar figure may be adjusted as necessary in the circumstances. Id. at 888, 104 S.Ct. at 1543. Review of Kerr factors that are not subsumed in the lodestar remains, in this circuit, the appropriate procedure for considering a request for an adjustment to the lodestar. See, e.g., Cunningham v. County of Los Angeles, 879 F.2d 481, 486 (9th Cir.1988), cert. den. Cunningham v. County of Los Angeles, 493 U.S. 1035, 110 S.Ct. 757, 107 L.Ed.2d 773 (1990); Miller v. Los Angeles County Board of Education, 827 F.2d 617, 621 (9th Cir.1987). Upward adjustments, or enhancements, to the lodestar are generally made through the use of multipliers. Fee Enhancements — the Use of Multipliers Historically, courts have stated a variety of reasons for their use of multipliers to adjust lodestar fee determinations. In Blum the Supreme Court narrowed the number of factors that had previously been used to support such adjustments in several important ways. Blum invalidated the use of a multiplier to support an upward adjustment of the lodestar to reflect the novelty and complexity of the issues and the special skill and experience of counsel. The Court observed that these considerations are fully reflected in a lodestar analysis: the former in the number of billable hours recorded by counsel, the latter in the reasonableness of counsel’s hourly rates. Blum, 465 U.S. at 898-99, 104 S.Ct. at 1548-49. Similarly, the “quality of representation” is also generally reflected in the reasonable hourly rate of counsel, and thus in the lodestar. Id. An upward adjustment for “quality” is appropriate only in the “rare case where the fee applicant offers specific evidence to show that the quality of service rendered was superior to what one reasonably should expect in light of the hourly rates charged and that the success was ‘exceptional’.” Id. at 899, 104 S.Ct. at 1549. The level of performance necessary to qualify for a quality multiplier must be particularly outstanding where, as here, a limited fund is available. Capital Underwriters, 519 F.Supp. at 102. Appraisal of the “results obtained,” which is a particularly relevant consideration in civil rights litigation where a plaintiff succeeds only on some of his claims, is also generally subsumed in the lodestar figure. Blum, 465 U.S. at 900,104 S.Ct. at 1549-50. It is measured by the benefit accruing to the client as a result of the attorneys’ services. See, e.g., Donnarum-ma, 79 F.R.D. at 461. The Kerr “results obtained” factor is equivalent to the “degree of success” attained in litigation. Both criteria are therefore subsumed within the lodestar and ordinarily should not be used separately to justify an adjustment to it. Cunningham, 879 F.2d at 486. The Ninth Circuit has adopted the Blum standards, and recognizes that each of these considerations is contemplated in the blended lodestar analysis. The results of the appraisal of all of the foregoing factors are subsumed within the lodestar, and the factors may not act as independent bases for adjustments of that presumably reasonable figure. Cunningham, 879 F.2d at 487, Cabrales v. County of Los Angeles, 864 F.2d 1454 (9th Cir.1988). Thus, after Blum, an adjustment of a fee award by use of a multiplier will be justified only in rare, exceptional instances. Chalmers v. Los Angeles, 796 F.2d 1205, 1215 (9th Cir.1986), amd. Chalmers v. Los Angeles, 808 F.2d 1373 (9th Cir.1987), and on remand Chalmers v. Los Angeles, 676 F.Supp. 1515 (C.D.Cal.1987). Further refinement of factors that might justify use of a multiplier were delineated by the Supreme Court in Delaware Valley I and Pennsylvania v. Delaware Valley Citizens’ Council for Clean Air (“.Delaware Valley II”), 483 U.S. 711, 107 S.Ct. 3078, 97 L.Ed.2d 585 (1987). Like Blum, these opinions concerned statutory fee questions, but insofar as they address the reasonableness of a fee award, the decisions are applicable here. See Lange v. Penn Mut. Life Ins. Co., 843 F.2d 1175 (9th Cir.1988). The first Delaware Valley opinion further resolved the question of whether a court may enhance a fee award to reflect superior quality of representation. The opinion dealt with a post-Blum fee award in which an upward adjustment had been granted because it “was ‘the rare case where the fee applicant offer[ed] specific evidence to show that the quality of service rendered was superior to that one reasonably should expect in light of the hourly rates charged and that the success was “exceptional” ’ ” Delaware Valley I, 478 U.S. at 556, 106 S.Ct. at 3094. The Court reversed the application of multipliers, observing that the justification for multiplication — “the ‘superior quality’ of counsel’s performance,” — was fully reflected in the lodestar. Id. at 567, 106 S.Ct. at 3089. Justice White observed that the fee-shifting statutes, including the one in question, were “not designed as a form of economic relief to improve the financial lot of attorneys.” Id. at 565, 106 S.Ct. at 3098. The comment is applicable, also, to the federal securities laws. The second Delaware Valley opinion dealt with the issue of whether the attorney for a prevailing plaintiff should or may be awarded separate compensation for assuming the risk of not being paid. Delaware Valley II, 483 U.S. at 715, 107 S.Ct. at 3081. That risk — the risk of losing — is determined by the amount the law is unsettled on the issues and the likelihood that the facts could be decided adversely for the plaintiff. Id. at 715-16, 107 S.Ct. at 3081-82. The risk is often described as a “contingency risk,” and “contingency multipliers” have generally been the courts’ means of adjusting a lodestar fee for such a risk. The Ninth Circuit has provided a clear statement of the Supreme Court’s decision in Delaware Valley II: [A] majority of the Court held that enhancing a fee award for contingency is permissible if two prerequisites identified in Justice O’Connor’s concurrence are met.... First, the fee applicant must establish that “without an adjustment for risk the prevailing party ‘would have faced substantial difficulties in finding counsel in the local or other relevant market.’ ” [Citation omitted.] Second, any enhancement for contingency must reflect “the difference in market treatment of contingent fee cases as a class, rather than ... the ‘riskiness’ of any particular case.” ... The fee applicant bears the burden of proving the degree to which the relevant market compensates for contingency. [Citation omitted.] Fadhl v. San Francisco, 859 F.2d 649, 650 (9th Cir.1988) (quoting Delaware Valley II, (footnote and citations omitted). Justice O’Connor’s concurring opinion constitutes the Court’s holding in Delaware Valley II. See Fadhl, 859 F.2d 650 n. 1. The record should provide evidence, and the trial court should specifically find, that plaintiff would have faced substantial difficulties in finding counsel in the local or other relevant market without an enhancement for risk. Delaware Valley II, 483 U.S. at 731, 107 S.Ct. at 3089-90. The record does not reveal such a situation in this case. It is undeniable that most law firms would lack the economic and professional stamina necessary to sustain the long, uncompensated involvement required by this litigation. Nonetheless, the deliberate, almost aggressive, efforts to obtain and maintain instrumental roles in this litigation, demonstrated by the numerous firms whose time records are before the Court, is also irrefutable. Absent evidence to the contrary, the Court cannot find that substantial difficulties would have been encountered by these plaintiffs. The record indicates otherwise. Any enhancement for risks unique to the case — i.e. the existence of new and novel issues, the protraction of litigation, the tenacity of defendants — should be reflected in the number of hours expended and in the hourly rates. They are impermissible bases on which to increase an already reasonable lodestar. Id. As with other enhancements, “enhancement for the risk of nonpayment should be reserved for exceptional cases where the need and justification for such enhancements are readily apparent and are supported by evidence in the record and specific findings by the courts.” Delaware Valley II, 483 U.S. at 728, 107 S.Ct. at 3088 {citing Blum, 465 U.S. at 898-901, 104 S.Ct. at 1548-1550). Finally, delay in payment is not an appropriate consideration for a risk enhancement. Delay in payment is, however, appropriately recognized in one of two ways: the fee award can be based on current rates, or the historically-based fee can be adjusted to reflect its present value. Delaware Valley II, 483 U.S. at 716, 107 S.Ct. at 3081-82. In sum, after these three recent Supreme Court opinions, the Court’s discretion to grant an enhancement or to apply a “multiplier” to a reasonable lodestar fee has been severely restricted. This case presents unique circumstances, however. While I am keenly aware of the authorities holding that a multiplier is not a commonly accepted vehicle by which to enhance fees or reward counsel for their skill in handling novel and complex issues, I am mindful of the result obtained in this case and the fact that the quality of representation was exceptional. I have lived with this case for over five years. I have observed counsel in a variety of situations both first hand and through the quality of work presented throughout. I have observed the intensity of representation by defense counsel and I know that defendants’ attorneys were of the highest quality that could have been arrayed against the resources of Class counsel. This was a case of overwhelmingly unique proportions, in terms of the amount at issue, as well as the duration of time, numbers of witnesses, numbers of documents, and related matters that demanded the attention to minute detail of Class counsel. It was a rare and exceptional case involving extraordinary services on behalf of Class plaintiffs. I observed counsels’ uncommon dedication and timely attention to the affairs of the Class. It became clear, during the development and course of the litigation, that the undertaking was vastly greater than had been anticipated by counsel when they originally sought and obtained the designation of lead counsel. Lead counsel were precluded from taking a lead role in other class action litigation during the near seven year pend-ency of this case. Consistent with professional responsibility, counsel unwaveringly fulfilled their duty of fidelity to the Class and obtained a result which is, at the very least, sufficient to satisfy the requirements regarding fairness of the settlement. For these reasons I believe that a fee enhancement, for the work of certain attorneys, is neither inappropriate nor proscribed. A number of attorneys dedicated significant portions of their professional careers to this litigation. Some literally lived with the litigation for more than five years. They underwent personal hardships in the form of long and tedious hours, separation from families, relinquishment of community involvement, and renunciation of other professional pursuits. They devoted themselves to the action, and I believe it became, for some, more than just the mundane object of their work. It engrossed and absorbed their intellects, their energies and their talents. They championed the cause of Class members in the face of commanding and vastly outnumbering opposition. They maintained their tenacity in the face of uncertain victory. All of this was done with absolutely no guaranty of payment. They succeeded admirably. I believe their commitment is worthy of an award that reflects, not only the hours they reasonably worked, but also the unmeasurable but substantial endurance, dedication and deprivations they experienced. The attorneys I deem deserving of monetary remuneration for these intangible aspects of the litigation effort will be indicated, through application of a multiplying factor to their lodestar award, at the conclusion of my lodestar determinations for each applicable firm. DETERMINATION OF THE LODESTAR Determination of the lodestar under the blended method begins by equating the first factor in the lodestar approach, “hours spent,” with the “time and labor required” element of the Kerr factors. Consideration of the novelty and difficulty of the questions involved will be subsumed in my determination of the required time and labor, in accordance with the guidance provided by the Supreme Court and the Ninth Circuit. The skills necessary to conduct the litigation and the experience, reputation and abilities of the attorneys will weigh heavily in my evaluation of the reasonableness of the rates reported by counsel. The amount involved and results obtained, the nature of the fee, and the desirability or undesirability of the case will also be considered in connection with the appropriate rates and the establishment of a reasonable lodestar. See, Moore, 682 F.2d at 839-40 n. 12, Copeland v. Marshall, 641 F.2d 880, 890 (D.C.Cir.1980). I will undertake this process, after some comments about the fee petitions in general. I will then set out certain broad guidelines that were used in reviewing the petitions. Thereafter, I will discuss each firm’s separate petition and will indicate, for the work of each attorney for whom payment has been requested, my decisions regarding the hours reasonably expended and the reasonable rate or rates. The sum of these individual attorney lodestar amounts, for each firm, will constitute the firm’s reasonable lodestar award for attorney work. Thereafter, in a similar manner, I will indicate my decisions regarding each firm’s petition for reimbursement for work done by paralegals and/or law clerks. Finally, I will consider and indicate my decisions regarding the expense petitions of every firm, the WPPSS Litigation Fund, and Chemical Bank. General Comments Regarding the Fee Petitions Counsel bear the burden of submitting adequately-documented fee applications. Those who fail to, do so at their own risk. Equity Funding, 438 F.Supp. at 1327. The burden of proving entitlement to fees out of a common fund rests on the petitioner. Capital Underwriters, 519 F.Supp. at 102. Attorneys undertaking representation in common fund cases—including many of those attorneys and firms whose petitions are now before me—have long been on notice of the critical importance of maintaining accurate time records. E.g., Donnarumma, 79 F.R.D. at 464; In re Continental Illinois Secur. Litigation, 572 F.Supp. 931 (N.D.Ill.1983); Capital Underwriters, 519 F.Supp. at 104; In re Fine Paper Antitrust Litigation, 98 F.R.D. 48 (E.D.Pa.1983), aff'd. in part and revd. in part In re Fine Paper Antitrust, 751 F.2d 562 (3rd Cir.1984); Rothfarb, 649 F.Supp. 183. Lead counsel firms involved in this litigation have been admonished by other courts regarding the necessity of providing adequate documentation of attorneys’ time. E.g., Feuerstein v. Burns, 569 F.Supp. 268; Continental Illinois, 572 F.Supp. 931. In countless opinions of other district and appellate courts, moreover, other petitioning firms have similarly been advised of this need. The requirement is neither novel nor unduly burdensome. What is unduly burdensome, however, is the task that is left to a court as a result of vague, imprecise, illegible, meaningless and generally inadequate records reflecting counsels’ undertakings. The records before this Court contain, to one degree or another, a multitude of such infirmities. The Court has struggled with the records, and has given counsel much latitude in its review. Nonetheless, bearing in mind the burden that rests on counsel, in my analysis I have resolved the uncertainties that remained, where the records were simply inadequate to do otherwise, against petitioners and in favor of Class member claimants to the settlement fund. Class Counsels’ Fee Petition Class counsel submitted several documents with their initial fee application. The Declaration of Lead Counsel is primarily a detailed description of the history of this litigation. A small portion of the document, pages 113 to 120, concerns Class counsels’ $103 million fee request. The twenty-five separate Lodestar Declarations contain, for each petitioning Class counsel firm, seven or eight paragraphs that provide the following limited and repetitive information: 1. The declarant’s firm affiliation and reason for the declaration. 2. The firm’s relation to the litigation. Generally, petitioning firms are counsel of record for one of the class representatives. A number of class representatives have more than one firm as counsel of record. 3. A brief description of charts, attached as Exhibits A, and a statement that the charts were prepared from contemporaneous, daily time records regularly prepared and maintained by the firm. 4. A statement that Exhibits B contain a brief biography of the firm. 5. The firm’s total number of hours spent on the litigation and the total “lodestar” amount for attorneys’ and paralegal time. 6. The total amount spent in connection with the litigation, and information (sometimes in a separate paragraph) regarding the firm’s contribution and/or reimbursement from the WPPSS Litigation Fund. Following this is a short list of the categories and amounts of disbursements for which reimbursement is sought. 7. A statement that “[t]he expenses incurred ... are reflected on the books and records of the firm. These books and records are prepared from expense vouchers and check records and are an accurate recordation of the expenses incurred.” Exhibits A to these declarations contain lists of each firm’s attorneys, paralegals, and law clerks who worked on the litigation, their total hours (generally through March 1989), their billing rates (generally as of August 1988), and the multiplied “lodestar” for each. The charts also contain a breakdown of reported hours among the following ten categories. (A) Preparation of Pleadings, including preparation of complaints and related research; (B) Document discovery; (C) Depositions, interrogatories, and related work; (D) Preparation of motions and briefs; (E) Court appearances and preparation; (F) Expert related work and damages; (G) Lead counsel duties and class administration, including proof of claim procedure and communications with class members; (H) Trial and trial preparation; (I) Settlement analysis, negotiations and documentation; (J) Appellate work. Except for a very broad indication of the general orientation of the work of the applicants, these charts provide little meaningful information. They were prepared after-the-fact, through a review of time records, at the time the fee petitions were prepared. In at least some cases, the categorization was done by clerical employees. For reasons that will become evident, the accuracy of any such summary prepared in retrospect from the petitioning firms’ time records is dubious, at best. Several firms did not categorize all employees’ time and at least one firm substituted even less meaningful categories than the standard ten. Even assuming any real accuracy in the categorization, the amount of time included in each of the ten categories encompasses time spent in that general litigation area, regardless of the nature of any particular activity. A given category, therefore, includes time that may have been spent on research, reading, review, drafting, telephone conversations, discussions, meetings, travel, and myriad other tasks. No summary was provided to describe the amount of time applicants spent in any of those activities, although daily time records often provided such a description. One perhaps valid conclusion can be drawn from a compilation of all Class counsels firms’ time categorization summaries: At the time the initial petitions were filed, over half of Class counsels’ time on this litigation involved discovery, depositions and expert witness work. An additional 17% of applicants’ time related broadly to the preparation of pleadings, motions, and briefs. About 13% of their time was attributed to preparation for and attendance at court hearings and trial. Approximately 10% of attorney and paralegal time was spent by 19 petitioning firms on “lead counsel duties and administration of class matters.” Settlement activities absorbed about 5%% of the time charged. Exhibits B to the individual Class counsel firms’ declarations vary significantly in both size and content. They contain biographical information regarding the legal activities of some of the petitioning attorneys and of the firms themselves. In addition to the exceedingly abbreviated information supplied in class counsels’ declarations and in the bi-monthly “Lodestar Reports” that had been submitted under seal throughout the litigation, petitioning firms were required provide the Court with copies of contemporaneous records prepared to reflect the expenditure of every attorneys’ time. Those detailed records, supplemented by the declarations and bi-monthly reports, and aided by my familiarity with the lawyers and litigation, were used to determine the nature of the work and the reasonableness of the time and labor expended by Class counsel attorneys, paralegals, and law clerks. Haberman and AMBAC Petitions The fee petitions submitted by Haber-man counsel and by the law firm of Foley and Lardner vary, both among themselves and compared to Class counsels’ rather uniform declarations. Those petitions contained some of the best, and some of the worst, documentation submitted. They will be discussed, to the extent necessary, subsequently. GUIDELI