With no explanation, chose the best option from "A", "B", "C" or "D". should arguably be avoided in situations where such a common fund exists because it does not adequately acknowledge (1) the result achieved or (2) the special skill of the attorney(s) in obtaining that result, courts and commentators have been skeptical of applying the formula in common fund cases.... [M]any courts have strayed from using the lodestar in common fund cases and moved towards the percentage of the fund method which allows for a more accurate approximation of a reasonable award for fees. Id. at 831-32 (citations omitted). Here, the 18% and 20% fees requests appear to be more than reasonable. Indeed, when compared to the range of percentage fee awards generally accepted in this Dis trict, the amounts requested are below that range. See e.g., Cardizem, 218 F.R.D. at 532 (<HOLDING>); F & M, 1999 U.S. Dist. LEXIS 11090 at *19-20

A: recognizing that fees of 2030 are generally awarded in this circuit
B: holding that awarded fees were reasonable and that proof that attorneys fees are necessary apart from testimony as to the reasonableness of the fee is not required
C: holding that fees may be awarded for litigating amount of fees only where language of statute supports such conclusion
D: holding that such fees are discretionary but routinely awarded
A.