Substantiation Of Reasonableness Of Fees: $387,464.50 Postjudgment Fee Award Reversed Based On Block Billed Entries And Severely Redacted Entries With No Justification

Entries Made It Hard To Discern What Work Was Performed.

            We like the result reached in R Consulting & Sales, Inc., Case No. D076749 (4th Dist., Div. 1 May 13, 2021) (unpublished), where an appellate court reversed a $387,464.50 postjudgment CCP §§ 685.040 and 685.070 enforcement fees award because the petitioning fee claimant had block billed entries and severely redacted entries not justified as being privileged or protected by the attorney work product doctrine.  Because these in tandem factors made it impossible to determine what was compensable, the fee award was reversed—basically on due process grounds.  The opposing party did a good job of objecting in the fee proceeding.

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