The Second Circuit held that Southern District Judge Deborah Batts abused her discretion by "imposing a sanction of attorneys' fees without explicitly finding that [Langrock Sperry & Wool] acted in bad faith, and by sanctioning Langrock without affording the attorneys prior notice and an opportunity to be heard."
Circuit Cancels Order for Firms to Pay $24,400 in Attorney Fees
New York Law Journal
December 28, 2012
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