S.D. Florida cuts intellectual property fee award 11.3%, including for vague entries

What happened

The fee applicant in Marano v. TBC Multimedia LLC requested $4,880 for 12.3 hours. The magistrate judge recommended awarding $4,330, a reduction of $550 or 11.3%. The court did not credit 1.0 hour of paralegal time because counsel provided no description for that work. It also reduced the combined time of attorneys Vera and Quintero by 1.0 hour, finding unnecessary and unreasonable duplication of attorney time on October 8, 2024, in preparing a simple motion for extension of time.

What the court said

the undersigned does not credit the 1.0 hour of work claimed for Paralegal Arielle Marra, as Plaintiff's counsel provides no description for this time

The court also reduced the award for: duplicative staffing.

Why it matters

The ruling shows that a fee petition can lose hours for entries that lack any description of the work, and that courts will trim time when two attorneys bill for the same simple task. Even small requests are examined line by line, and the applicant bears the burden of explaining each entry.

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.