avoid[] an interpretation of the fee-shifting statutes that would spawn[] a second litigation of significant dimension.” Buckhannon Bd. & Care Home, Inc. v. West Virginia Dep’t of Health & Human Servs., 532 U.S. 598, 609, 121 S.Ct. 1835, 149 L.Ed.2d 855 (2001) (citations and internal quotations omitted). In this case, because fee requests are made at the time of a remand order, applying § 1447(c) to counsel would build an extra layer of litigiousness into the middle of a case. Since § 1447(c) provides no “formula for ‘ready administrability,’ ” id. at 610, 121 S.Ct. 1835, a litigious period would be required to establish the proper standards for attorney, as opposed to party, liability. See Martin v. Franklin Capital Corp., 546 U.S. 132, 141, 126 S.Ct. 704, 163 L.Ed.2d 547 (2005) (<HOLDING>). Courts would also be forced to decide,
holding that the party prevailing on the significant issues in the litigation is the party that should be considered the prevailing party for attorneys fees holding a party seeking mandamus must serve the party against whom relief is sought holding a party cannot be joined to prevent removal where no cause of action can be brought against that party holding that a private party may bring an action in a federal district court seeking injunctive relief on the basis of garmon preemption for only arguably protected or prohibited activity holding that a party may be liable under  1447c only where the removing party lacked an objectively reasonable basis for seeking removal