Message Is That Incivility Can Lead To A Negative Multiplier To A Fees Request, On Top Of Other Reductions.
On October 3, 2023, we posted on Snoeck v. ExakTime Innovations, Case No. B321566 (2d Dist., Div. 3 Oct. 2, 2023 unpublished), but it was certified for publication on October 25, 2023. The main lesson from this case is that appellate courts will have no trouble affirming a lodestar request reduction, aside from other deductions, separate for the incivility of the party requesting a fee award where the record supports such a reduction for incivility.