Disbarred Attorney’s Work Effort Was Allowed, Although His Hourly Rate Was Reduced In Performing Paralegal Services.
In Hope and Trust Trading, Inc. v. Ciling, Case No. B351756 (2d Dist., Div. 1 July 29, 2026) (unpublished), a post-judgment creditor was granted $356,223 in judgment enforcement fees, with a principal reduction for a disbarred attorney who performed paralegal services (with his hourly rate being reduced from $500 to $200 per hour). [The original fee request was $643,300.] The appellate court affirmed the fee award, determining that disbarred attorneys may perform research, drafting, or clerical activities (such as paralegal services) as long as they are supervised by an attorney.