Tillman v. Advanced Pub. Safety, Inc.
Tillman v. Advanced Pub. Safety, Inc.
| Case Date: | 11/02/2018 |
| Citation: | 2018 U.S. Dist. LEXIS 187977 |
| Court Type: | Federal District |
| Court: | Southern District of Florida (S.D. Fla.) |
| Judge: | Federal Magistrate Judge: William Matthewman |
| Issues: | Whether a party may recover attorney’s fees and costs billed by an e-discovery manager where the cause of action otherwise permits the recovery of attorney’s fees. Further, if recovery of the fees billed by the e-discovery manager are recoverable, what are the limitations? |
| Resolution: | Here, the Court found the fees billed by the firm’s e-discovery expert were recoverable where the cause of action permitted recovery of attorney’s fees and costs. However, the Court noted that the “time claimed by an e-discovery expert should relate to appropriate legal work and not merely administrative tasks.” The Court also noted billing entries which contain a mix of legal and administrative work are improper and deducted these entries from the award of attorney’s fees. |
| Relevant Documents: | Defendant’s Motion to Dertermine Entitlement to Attorney’s Fees (Doc. 262) Supplemental Brief in Support of Motion for Attorney’s Fees (Doc. 277) Plaintiff’s Motion For Entitlement to Attorneys’ Fees and Costs Plaintiff’s Response in Opposition to Defendant’s Supplemental Brief (Doc. 285) Defendant’s Respone to Plaintiff’s Motion for Entitlement to Attorney’s Fees (Doc. 286) Defendant’s Reply to Plaintiff’s Response in Opposition to Defendant’s Supplemental Brief (Doc. 289) |
| E-Discovery Issues: | Motion to Review Costs |
| E-discovery Tags: | Costs |