S.D. Florida cuts wage and hour fee award 9.8% over clerical work | LegalTime AI

S.D. Florida cuts wage and hour fee award 9.8% over clerical work

Adderley v. Preferred Primary Care Associates LLC et al, No. 0:24-cv-61295. District Court, S.D. Florida, Judge William P. Dimitrouleas. Decided . Read the opinion

Requested
$4,880
Awarded
$4,400
Cut
9.8%$480

Wage and hour · Fair Labor Standards Act · Fee applicant's counsel: Koz Law, P.A.

What happened

Koz Law, P.A., counsel for the plaintiff, requested $4,880 in attorney fees under the Fair Labor Standards Act for 12.2 hours of work. The court awarded $4,400, a reduction of $480 or 9.8%. The court excluded 1.2 hours of clerical tasks that had been billed as legal work, leaving 11.0 hours. The figures do not include costs. Judge William P. Dimitrouleas entered the order.

What the court said

Clerical work billed as legal work
Therefore, the undersigned excludes 1.2 hours of clerical tasks from Plaintiff’s fee award.

Why it matters

The ruling shows that courts separate clerical tasks from legal work when reviewing time records on a fee petition, and that hours billed for clerical tasks are excluded from the award even when the overall reduction is small.

How to keep this out of your fee petition

  • Leave purely clerical work off the fee petition.
  • Describe paralegal tasks so the substantive work is clear.
  • Split mixed entries into their substantive and clerical parts.

Cite this ruling

Adderley v. Preferred Primary Care Associates LLC, No. 0:24-cv-61295 (S.D. Fla. Sept. 4, 2025)

See hourly rates the S.D. Florida approves and attorney fee motions in Florida federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.

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