Alexander, 2014 WL 1165844, at *8. Recovery under more than one cause of action would provide “double recovery.” Id. Although punitive damages are available under common law fraud but not her statutory causes of action, “an ‘award of treble damages . . . is sufficient to further the purposes of a punitive damages award.'” Id. at *9 (quoting Reynolds v. Reliable Transmissions, Inc., 3:09-cv-238-DWD, 2010 WL 2640065, at *6 (E.D.Va. June 29, 2010)).
The Court finds these rates reasonable considering prior fee awards in the Richmond Division of the Eastern District of Virginia. Matter of Mediation in Health Diagnostic, Lab., Inc., No. 3:17mc4, 2018 WL 524711, at *5 (E.D. Va. Jan. 23, 2018) (finding hourly rate of $400 for lead attorney and $200 for third-year associate reasonable in the Richmond Division); Jones v. Southpeak Interactive Corp. of De., No. 3:12cv443, 2014 WL 2993443, at *8 (E.D. Va. July 2, 2014), aff'd, 777 F.3d 658 (4th Cir. 2015) (finding hourly rate of $250 for an associate to be reasonable in the Richmond Division); Reynolds v. Reliable Transmissions, Inc., No. 3:09cv238, 2010 WL 2640065, at *9 (E.D. Va. June 29, 2010) (finding fee awards ranging between $275 and $450 reasonable in the Richmond Division) (J. Payne). The School Board states that "[t]he regular hourly rates for attorneys at the firm are $230 for Mr. Phinyowattanachip, $280 for Ms. Haney, and $195 for Mr. Selman."
"Rather, punitive damages are appropriate 'if the defendant's conduct was wanton, malicious, or oppressive, or if the defendant acted in reckless disregard of the law.'" Id. (citing Reynolds v. Reliable Transmissions, Inc., No. 09-238, 2010 WL 2640065, at *4 (E.D. Va. June 29, 2010)). In determining the amount of punitive damages to award, the ECOA instructs courts to consider, "among other relevant factors, the amount of any actual damages awarded, the frequency and persistence of failures of compliance by the creditor, the resources of the creditor, the number of persons adversely affected, and the extent to which the creditor's failure of compliance was intentional."
"Rather, punitive damages are appropriate 'if the defendant's conduct was wanton, malicious, or oppressive, or if the defendant acted in reckless disregard of the law.'" Id. (citing Reynolds v. Reliable Transmissions, Inc., No. 09-238, 2010 WL 2640065, at *4 (E.D. Va. June 29, 2010)). In determining the amount of punitive damages to award, the ECOA instructs courts to consider, "among other relevant factors, the amount of any actual damages awarded, the frequency and persistence of failures of compliance by the creditor, the resources of the creditor, the number of persons adversely affected, and the extent to which the creditor's failure of compliance was intentional."
[He] need not prove the exact amount of loss with mathematical precision, but [his] loss must be established by facts and circumstances that would permit an intelligent and probable estimate thereof." Reynolds v. Reliable Transmissions, Inc., No. 3:09cv238, 2010 WL 2640065, at *3 (E.D. Va. June 29, 2010) (citing Gertler v. Bowling, 202 Va. 213, 215 (1960) (internal citation omitted)). "However, when the amount of damages is left to conjecture or speculation, there can be no recovery therefor.
Rather, punitive damages are appropriate "if the defendant's conduct was wanton, malicious, or oppressive, or if the defendant acted in reckless disregard of the law." Reynolds v. Reliable Transmissions, Inc., No. 09-238, 2010 WL 2640065, at *4 (E.D.Va. June 29, 2010) (citing Fischl, 708 F.3d at 148; Anderson, 666 F.2d at 1278); see also Bayard v. Behlmann Auto. Servs., Inc. , 292 F.Supp.2d 1181, 1187 (E.D.Mo. 2003) ("The concept of damages as 'punitive' implies some degree of blame beyond a technical violation of the [ECOA] . "). In deciding whether to award punitive damages, the ECOA instructs courts to consider, "among other relevant factors, the amount of any actual damages awarded, the frequency and persistence of failures of compliance by the creditor, the resources of the creditor, the number of persons adversely affected, and the extent to which the creditor's failure of compliance was intentional."