Defendant SLAPP Winner Awarded Full Amount Of Request, Waiving Supplemental Request Based On Actions Below.
In Jaguar Land Rover North America, LLC v. Kasparian, Case No. B260613 (2d Dist., Div. 3 Aug. 31, 2017) (unpublished), a defendant successfully won a SLAPP action and was awarded $4,027.50 in fees, the exact amount requested. However, even though knowing at the time of the fee hearing that defendant expended more than this in supplemental time from the request contained in the papers, its counsel did not ask for more fees at the hearing or file a supplemental fee motion. Defendant cross-appealed for a fee enhancement, but the appellate court refused that request based on not taking further actions below and based on the lower awarding exactly what defendant requested at the start.