S.D. Florida cuts fee award, including for vague entries

What happened

Coffey Burlington sought fees in Bakhai v. BDO USA, P.C. before Judge Enjolique A. Lett. The court did not state the amount requested or awarded. It imposed a 25% reduction on the Yanowitch & Co. attorney fee award because most of those entries were billed in .25 increments for email review and drafting. It applied a further 25% reduction to the same entries because many were vague and used improper quarter-hour increments.

What the court said

The majority of the Yanowitch time entries include improper quarter-hour billing increments ... and a number of the entries are vague as Respondent notes. See Resp. 6. The fees will be reduced on these bases.

The court also reduced the award for: excessive hours.

Why it matters

The ruling shows courts will cut fees when time entries are vague or billed in uniform quarter-hour increments, even without stating a total award. It also shows reductions can stack when the same entries raise more than one problem, so the final award reflects each basis separately.

How to keep this out of your fee petition

• Name the task, the document or person involved, and the purpose.
• Avoid stock phrases that could describe any day in any matter.
• Keep privileged detail general, but specific enough to show the work.

Cite this ruling

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.