D. Puerto Rico cuts commercial fee award 1.5%, including for vague entries
Dorado Gardens LLC et al v. Efron et al, No. 3:22-cv-01402. District Court, D. Puerto Rico, Judge Francisco A. Besosa. Decided . Read the opinion
- Requested
- $183,295
- Awarded
- $180,482.50
- Cut
- 1.5%$2,812.50
Commercial · Contract fee clause
What happened
The fee applicant sought $183,295 under a contract fee clause. Judge Francisco A. Besosa awarded $180,482.50, a reduction of $2,812.50. The court cut $425 for entries too vague to evaluate, halved $662.50 in hours it found excessive for the tasks described, and disallowed $1,050 for unnecessary work, including a reply never filed and an entry dated months after the opposition. It also reduced by 30% $675 in entries mixing clerical and legal work.
What the court said
Several entries are too vague to evaluate whether the time spent was reasonable.
Because it is difficult to tell the proportion of clerical versus legal work in these entries, the reasonable billed amount will be approximated by reducing these amounts by 30%
The court also reduced the award for: excessive hours, other.
Why it matters
The ruling shows that even a small reduction can rest on several distinct recordkeeping problems. Courts will trim entries that lack enough detail to assess reasonableness, separate clerical tasks from legal work, and check dates and task descriptions against the docket.
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
Dorado Gardens LLC v. Efron, No. 3:22-cv-01402 (D.P.R. June 16, 2025) See hourly rates the D. Puerto Rico approves.
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.
More rulings like this
- D. Arizona cuts wage and hour fee award 5.3% over clerical work Zommick v. Lewis Construction Company LLC et al · Oct 2, 2026
- M.D. Tennessee cuts intellectual property fee award 12%, including for vague entries Livingston v. Jay Livingston Music, Inc., et al. · Sep 28, 2026
- E.D. Pennsylvania cuts wage and hour fee award 91%, including for clerical work LIN v. LEES HOUSE RESTAURANT INC et al · Sep 28, 2026