Ramle Int’l Corp. v. The Greens Condo. Assoc., No. 3D08-2834 (Fla. 3d DCA Feb. 10, 2010)

In this attorneys’ fees case, Ramle Int’l prevailed at trial and was awarded attorneys’ fees as part of the judgment. The trial court reserved jurisdiction as to the amount of fees and Ramle waited eleven months to file its motion to determine the amount of attorneys’ fees owed.

After Ramle moved for a determination of fees, The Greens Condo filed a brief in opposition arguing that Ramle waived its right to seek attorneys’ fees by failing to file its motion within 30 days of judgment, which they argued was required by Rule 1.525, Fla. R. Civ. Pro. The trial court then denied Ramle’s fee motion as untimely and The Greens Condo appealed.
The Third DCA reversed the trial court, finding that the time limit in Rule 1.525 only applied to the determination of entitlement to fees, not in cases where the Court has already established entitlement.  Citing Amerus Life Ins. Co. v. Lait, 2 So.3d 203, 207 (Fla. 2009).