UPDATE: Judge Sanctions Class Action Plaintiff’s Counsel for Frivolously Failing to Disclose Arbitration Agreement

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This post is an update to our November 11, 2025 blog, in which we first reported on the court’s decision sanctioning Plaintiff’s counsel for failing to disclose the existence of an arbitration agreement. In this update, we provide new details from Defense Counsel’s Supplemental Brief in Golikov v. Walmart Inc. —including the total fees sought, the categories of work performed, and the billing rates submitted to the court.

Defense Counsel’s Supplemental Brief seeks $745,422 in attorneys’ fees as sanctions for the substantial work necessitated by Plaintiff’s failure to correct the false allegation, which triggered extensive and unnecessary litigation activity.

The Supplemental Brief delineates fees associated with:

  1. Moving to Dismiss the First Amended Complaint;
  2. Answering the First Amended Complaint;
  3. Opposing Class Certification;
  4. Engaging in Discovery;
  5. Moving to Decertify the Class; and
  6. Seeking Sanctions.

The Supplemental Brief identifies that discounted rates were charged ranging from $540-$720/hour for associates, $733-$805/hour for counsel, $891/hour for partners, and $1,237/hour for an appellate specialist.

CDF will continue to monitor the matter and share additional updates as developments occur.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© CDF Labor Law LLP

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