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In December 2015, Venture Corporation v. Barrett, 2015 WL 8588239, the plaintiff won reasonable fees and costs. However the court refused to award Venture fees or costs temporarily because their entries were too vague. Venture Corporation had summarized the daily and total hours billed but did not supply any further detail. The attorneys for Venture Corporations claimed they were purposefully vague, claiming Attorney-Client and Work Product privilege especially since the defendant was likely to appeal.

The Court rejected this argument, without prejudice to renewal, because the vague entries have “two unfortunate effects.” Firstly, the court concluded that the vague entries limit the courts ability to assess if the fees are reasonable, is requirement of the Court. Secondly, vague entries limit the defendants ability to challenge the fees as “unreasonable, excessive or otherwise flawed.”

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