The following excerpt is from Ralph v. HAJ, Inc., Case No.: 17cv1332 JM(LL) (S.D. Cal. 2021):
"[T]here is nothing in the Federal Arbitration Act which provides attorneys' fees to a party who is successful in seeking confirmation of an arbitration award in the federal courts."). See Menke v. Monchecourt, 17 F.3d 1007, 1009 (7th Cir.1994). Federal courts may award attorneys' fees if there is a valid contract that provides for the award, an express statutory authority or rule authorizing the award, or if the opposing party "has acted in bad
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