However, Block Billing Is A Problem In A Complex Case With Multiple Billing Attorneys Involved.
In Minser v. Collect Access, LLC, Case Nos. B318325/B321996 (2d Dist., Div. 1 May 24, 2023) (unpublished), plaintiff prevailed on a Rosenthal Act debt collector claim, which has a fee shifting provision under Civil Code section 1788.30(c). The lower court awarded plaintiff $12,100.50 in fees and $1,097.23 in costs. On appeal, defendant argued that plaintiff’s fee substantiation was inadequate. Not at all, said the Court of Appeal. An attorney working on a case in a firm, if involved, can verify the firm’s work effort from a synergistic perspective. Although there was some block billing, the fee request was so modest such that the transgression did not require a reduction, although the appellate court did note that the result would be different in a complex case with many attorneys billing hundreds of hours on a case. Fee award affirmed.