method” of awarding fees— rather than the lodestar method, which arguably encourages lawyers to run up their billable hours—-“is to encourage early settlements by not penalizing efficient counsel.... ” Manual for Complex Litigation, supra, § 24.121, at 207 (citing 3 Herbert B. Newberg & Alba Conte, Newberg on Class Actions § 14.03, at 14-3 to 14-7 (3d ed.1992)). If the District Court, in fact, denied Counsel their requested fee award merely because Counsel were able to settle this complicated matter, then the Court ignored the stated goal in percentage fee-award cases of “ensuring that competent counsel continue to be willing to undertake risky, complex, and novel litigation.” Id. (citing Deposit Guaranty Nat’l Bank v. Roper, 445 U.S. 326, 338-39, 100 S.Ct. 1166, 63 L.Ed.2d 427 (1980) (<HOLDING>)). Procuring a settlement, in and of itself, is
recognizing importance of transcript to rehabilitation of debtor recognizing the importance of grand jury secrecy recognizing the importance of a financial incentive to entice qualified attorneys to devote their time to complex timeconsuming cases in which they risk nonpayment recognizing the diminished importance of the state policy factor recognizing the importance of the employers knowledge of the disability