On June 18, 2024, the First Department issued a decision in Fuks v. Rakia Assocs., 2024 NY Slip Op. 03327, decreasing an attorneys’ fees award because of, among other things, the use of block billing, explaining:
The court properly exercised its discretion in awarding less in attorneys’ fees than Shomron sought. Her counsel engaged in block billing, making it impossible to discern the reasonableness of the fees. Moreover, counsel did not differentiate the fees for the constructive trust claim, which was the claim upon which Shomron was entitled to fees.
(Internal citations omitted).