A federal magistrate judge has recommended a Manhattan firm that formerly represented plaintiffs in a personal injury case be sanctioned for failing to disclose documents for discovery.

Texas-based attorneys for Lapolla Industries, the defendant in the personal injury case that filed for sanctions against Morelli Alters Ratner, requested $800,000 for fees and costs associated with the sanction proceedings and the personal injury litigation.

But Eastern District Magistrate Judge A. Kathleen Tomlinson wrote Tuesday in her report and recommendation to Eastern District Judge Joanna Seybert that Houston firm Hoover Slovacek billed $1,020 for reviewing emails that were not produced in discovery in Markey v. Lapolla Industries, 12-cv-4622, and that attorneys were unable to undertake a line-by-line breakdown of expenses.