account for any further duplicity or work that could have been performed by paralegals, rather than attorneys, that may be impossible to discern based on the vagueness of entries. Rather than attempt to identify specific hours that should be eliminated for duplication of efforts or vagueness, and to account for those clerical tasks that could have been performed by paralegals, the court is permitted to make a simple reduction in the number of hours to “trim the fat.” McDonald, 450 F.3d at 96 (citing Kirsch v. Fleet St., Ltd., 148 F.3d 149, 173 (2d Cir.1998) (deducting a “reasonable percentage of the number of hours claimed” to account for “excessive, redundant, or otherwise unnecessary” hours)). See New York State Ass’n for Retarded Children v. Carey, 711 F.2d 1136, 1146 (2d Cir.1983) (<HOLDING>). For example, on November 25, 2009, Sciotti
recognizing that because it is unrealistic to expect a trial judge to evaluate and rule on every entry in an application a specific percentage cut is a practical means of trimming fat from a fee application recognizing that the application of a retroactive amendment is discretionary recognizing conflict between filing motion to dismiss and fee application and noting postponement of fee application resulted in no prejudice to any party recognizing that a state courts determination is not an unreasonable application of law merely because it is erroneous recognizing district court application of the same rule