However, No Authority Supported Vacating Entire Award, Including The Part Of It Against Losing Plaintiff.
In Clements v. Sojourn Properties, Inc., Case No. A141288 (1st Dist., Div. 1 Sept. 24, 2015) (unpublished), the appellate court had no trouble vacating a SLAPP fee award of $3,400 against a losing plaintiff’s attorney, given that Moore v. Kaufman, 189 Cal.App.4th 604, 615 (2010) established counsel cannot be ordered to pay such fees. Losing plaintiff argued the entire fee award should be vacated, even against it, but the reviewing court observed that plaintiff “cited no authority, and we are aware of none that would require us to vacate the entire order.” (Slip Op., at p. 14.)