Foot & Ankle Center of Florida, LLC v. Carlos Vargas, IV
After winning summary judgment on FCCPA and declaratory relief claims, Vargas obtained a fee award enhanced by a 1.5 contingency fee multiplier. The Sixth DCA reversed the multiplier because the fee movant presented no competent, substantial evidence on the first Quanstrom factor — whether the relevant market required a multiplier to obtain competent counsel — and remanded solely for entry of a judgment without the multiplier, denying a second evidentiary hearing.
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