Section 1717: Court Of Appeal Affirms Fee Award, Confirming That A Notice Of Motion For An Attorney’s Fee Request Does Not Have To Specifically Recite The Contract Which Was A Predicate For The Fee Motion

General Reference To The Parties’ Contract Sufficed.

Yellow Dog Holdings, LLC v. Regions Bank, Case No. G064613 (4^th Dist., Div. 3) (May 12, 2026) (unpublished), authored by Justice Sanchez, did deal with a procedural issue we have seen frequently argued.  The notice of motion for attorney’s fees referenced the parties’ contract, but it did not go into any further detail.  The losing party challenged the notice was deficient, but that argument was not found persuasive on appeal.  The notice did explain the relief requested and discussed that the relief was based on the parties’ contract, further detailed in the supporting fee opening memorandum.  That sufficed.