Trial Judge Found Summaries Credible—Credibility Being The Key.
In American Diversified Properties, Inc. v. Re/EX Valencia, Inc., Case No. B260155 (2d Dist., Div. 8 Aug. 22, 2106) (unpublished), appellant challenged a fee order on the ground that the attorney relied on summaries rather than detailed billing records. The appellate court rejected this challenge, because detailed billing invoices are not a mandatory requirement as far as fee substantiation in California state courts. (Martino v. Denevi, 182 Cal.App.3d 553, 559 (1986).) Although trial judges do have discretion to reduce awards if more detailed substantiation is not provided, it will not happen—as here—where the lower court found credible the time summaries provided by counsel.