Cases: Paralegal Time

Judgment Enforcement, Paralegal Time: Post-Judgment Enforcement Fee Award Of $356,223 (Reduced From The Fee Request) Was Affirmed On Appeal

Cases: Judgment Enforcement, Cases: Paralegal Time

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 In Hope and Trust Trading, Inc. v. Ciling, Case No. B351756 (2d Dist., Div. 1 July 29, 2026) (unpublished), a post-judgment creditor was granted $356,223 in judgment enforcement fees, with a principal reduction for a disbarred attorney who performed […]

Appeal Sanctions, Paralegal Time, Reasonableness Of Fees: Trial Court’s Refusal To Award Contractual Fees For Paralegal Work Reversed On Appeal

Cases: Appeal Sanctions, Cases: Paralegal Time, Cases: Reasonableness of Fees

Also, Attorney Fee’s Reductions Were Affirmed And Appellant Was Ordered to Pay Minimal Appeal Sanctions For AI Hallucinations In Appellate Briefing. The memorable thing about this opinion, Del Biaggio v. Bansen, Case No. A174647 (1st Dist., Div. 4 July 10, 2026) (published), is what it determined in compensating paralegal work under a contractual fees clause

Paralegal Time, Special Fee Shifting Statutes: Reduced Change Of Venue Fee Award Of $9,019.50 To Certain Defendants Affirmed In Part

Cases: Paralegal Time, Cases: Special Fee Shifting Statutes

Lower Court Properly Did Not Award Self-Represented Attorney Any Fees Relating To Himself (But Okay For Other Codefendants), But Matter Remanded To Apportion Fees And To Award Paralegal Compensation For A Law Clerk’s Work.                Civil Code section 396b, subd. (b) allows a lower court, in its discretion, to award attorney’s fees to a defendant

Costs, Default Judgments, Multipliers, Paralegal Time: $709,620 In Attorney’s Fees Entered As Part Of A Default Judgment After Entry of Terminating Sanctions Was Affirmed On Appeal

Cases: Costs, Cases: Default Judgments, Cases: Multipliers, Cases: Paralegal Time

Complaint Did Not Have To Plead An Exact Amount Of Fees; 3.0 Positive Multiplier Appropriate; PAGA Settlement Administration Expenses/Paralegal and Legal Assistant Expenses Properly Allowed As Routine Costs.             Haaverson v. Tavistock Freebirds, LLC, Case No. A164043 (1st Dist., Div. 5 Aug. 18, 2023) (unpublished) is an interesting opinion which explores whether a complaint needs

Indemnity, Paralegals, Reasonableness Of Fees: Famed Volleyball Player Kerri Walsh Jennings Properly Awarded Attorney’s Fees Of $92,726 For Contract Breach Claim Of $150,000

Cases: Indemnity, Cases: Paralegal Time, Cases: Reasonableness of Fees

Indemnification Clause Was Not A Third-Party Clause, So Fees Were Proper; $790-$850 Hourly Rate For 43-44 Year Los Angeles Litigator, $360-$395 For 4-5 Year Associate, And $290 For Paralegals Found To Be Reasonable By The Trial Judge And Appellate Court.             Just to show you how fee recovery can frequently come close to the underlying

Paralegals: Can California State Court Judges Compensate For Time By Non-Licensed Summer Clerks? No Clear Decision Exists, But We Say Yes … With An Important Caveat

Cases: Paralegal Time

Fee Claimants Would Need To Show That The Summer Clerk Work Resulted In Efficiencies Contributing To The Value Of The Case For Fee Purposes.             We had an interesting question posed by Reynaldo Fuentes as to whether summer clerk work could be compensated on a fee motion by California state courts, presumably a non-licensed law

Allocation, Civil Rights, Paralegals, Reasonableness Of Fees: Substantial Fee Recovery Remanded Based On Merits Reversal

Cases: Allocation, Cases: Civil Rights, Cases: Paralegal Time, Cases: Reasonableness of Fees

  However, Appellate Court Provides Remand Guidance On Allocation, Paralegal Compensation, And Reasonableness Issues.      In Samuelson v. Dept. of State Hospitals, Case No. A143149 (1st Dist., Div. 2 Oct. 28, 2016) (unpublished), plaintiff was awarded $1 million in damages against defendants Dept. of State Hospitals and three psychologists hired by Napa State Hospital based

Fee Clause Interpretation/Paralegals: Broad Fees Clause Justified $93,200 Fee Award, Inclusive Of Work By Paralegals

Cases: Fee Clause Interpretation, Cases: Paralegal Time

  Paralegals, Even Uncertificated Ones, Are Compensable In Fee Proceedings.      The Fourth District, Division 3, in Alcone v. SLV Associates, LLC, Case No. G051813 (4th Dist., Div. 3 Aug. 30, 2016) (unpublished), dealt with a trustee under a lease who prevailed where there was a broad “arising out of lease” fees clause. Trustee then

Appealability, Costs, Paralegal: $40,610.68 In Paralegal Fees To Prepare/Present Electronic Evidence At Trial Properly Awardable As Costs

Cases: Appealability, Cases: Costs, Cases: Paralegal Time

  Trial Court Properly Found They Were “Reasonably Necessary.”      In Green v. County of Riverside, Case No. D067424 (4th Dist., Div. 1 July 29, 2015) (published), plaintiff lost an unreasonable police force civil rights case. Later, the trial judge awarded defendants $66,453.02 in costs, $40,610.68 of which constituted paralegal fees for helping prepare/present electronic

Deadlines/Paralegals: Prevailing Party Under Brown Act And Political Reform Act Fee-Shifting Statutes Had Fees And Paralegal Fees Stricken From Costs Award

Cases: Deadlines, Cases: Paralegal Time

    Reason Was Failure to File a Noticed Motion or Submit Costs Memo With an Affidavit.        Arth v. Raine, Case No. C071303 (3d Dist. Nov. 25, 2014) (unpublished) is a somber reminder to follow Code of Civil Procedure section 1033.5 dictates when seeking attorney’s and paralegal fees under statutory fee-shifting provisions.     

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