$19,125 Was The Fee Recovery.
Losing party hit with a $19,125 contractual fee award appealed in White v. Taylor, Case No. B252350 (2d Dist., Div. 4 Sept. 25, 2014) (unpublished). The principal basis was that an attorney declaration in support of work effort and hourly rates did not adequately underpin a fee award. No, the $425 rate for the Los Angeles area was reasonable and an attorney declaration alone will suffice in substantiating work effort reasonably expended in a case. (Raining Data Corp. v. Barrenechea, 175 Cal.App.4th 1363, 1375 (2009).)