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On February 1, 2021, in an unpublished opinion resolving a Fair
Labor Standards Act (FLSA) attorney s fees dispute, the
Eleventh Circuit Court of Appeals, in 
Batista v. South Florida Womans Health
Associates, Inc., struck another blow against unreasonable
plaintiffs counsel seeking reasonable fees. Mitzy
Batista appealed the district court s finding that it would be
unreasonable to award her counsel, Elliot Kozolchyk, any
attorney s fees given his conduct during litigation filed under
the FLSA. Ultimately, the Eleventh Circuit remanded the case to the
district court to make necessary findings of fact and to issue its ....

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