S.D. Florida cuts commercial fee award 21.4%, including for block billing
Ladenburg Thalmann & Co. Inc. v. Bright Mountain Media, Inc., No. 9:23-cv-81019. District Court, S.D. Florida, Judge Aileen M. Cannon. Decided . Read the opinion
- Requested
- $255,935
- Awarded
- $201,122.50
- Cut
- 21.4%$54,812.50
Commercial · Contract fee clause · Fee applicant's counsel: Patrick J. Rengstl, P.A.
What happened
Patrick J. Rengstl, P.A. sought $255,935 in fees under a contract fee clause. Judge Aileen M. Cannon awarded $201,122.50, a reduction of $54,812.50 or 21.4%. The court applied a 25% reduction to the total hours, rather than the smaller cut recommended in the report, citing block billing, vague entries, clerical work billed as legal work, excessive hours for simple tasks, and duplicative staffing at partner rates.
What the court said
the Court determines that a twenty-five percent reduction—rather than the proposed ten percent cut as recommended in the Report—accurately captures a reasonable number of compensable hours billed in this matter.
That figure considers the deficiencies noted above, ranging from block billing (at approximately 40 percent), vague entries (at approximately 20 percent, instances of excessive billing at partner rates, and inadequate delegation
Plaintiff improperly seeks a portion of the attorneys' fees for clerical work such as redactions, e-filing documents, and putting together hearing binders—some of which was done by a partner at $500 an hour
The court also reduced the award for: excessive hours, duplicative staffing.
Why it matters
The ruling shows that a court may apply a single percentage cut to total hours when time records show block billing, vague entries, and clerical work, and may increase a recommended reduction when the records support it.
How to keep this out of your fee petition
- Record one task per entry, each with its own time.
- Write the entry when the work happens, not at the end of the week.
- If a task really is one unit of work, say what it was and what it produced.
Cite this ruling
Ladenburg Thalmann & Co. Inc. v. Bright Mountain Media, Inc., No. 9:23-cv-81019 (S.D. Fla. May 21, 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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