Block Billing, Substantiation Of Reasonableness Of Fees: Where Attorney’s Fee Request Was Modest, An Attorney In A Firm Can Substantiate His Firm’s Fees And Block Billing Was Not An Issue Where Fee Request Was Not Substantial

However, Block Billing Is A Problem In A Complex Case With Multiple Billing Attorneys Involved.

            In Minser v. Collect Access, LLC, Case Nos. B318325/B321996 (2d Dist., Div. 1 May 24, 2023) (unpublished), plaintiff prevailed on a Rosenthal Act debt collector claim, which has a fee shifting provision under Civil Code section 1788.30(c).  The lower court awarded plaintiff $12,100.50 in fees and $1,097.23 in costs.  On appeal, defendant argued that plaintiff’s fee substantiation was inadequate.  Not at all, said the Court of Appeal.  An attorney working on a case in a firm, if involved, can verify the firm’s work effort from a synergistic perspective.  Although there was some block billing, the fee request was so modest such that the transgression did not require a reduction, although the appellate court did note that the result would be different in a complex case with many attorneys billing hundreds of hours on a case.  Fee award affirmed.