Can a pro se lawyer recover reasonable attorney's fees?

Until then, there are at least some costs that can be recovered. As Argaman v. Ratan, supra, 73 Cal.App.4th at page 1180 recognizes, a pro se litigant, including a lawyer, is entitled to recover reasonable expenses actually incurred.⁶ If pro se litigants (including pro se lawyers) actually incur expenses for computer-assisted legal research, or photocopying, or transportation to and from court, or any other identifiable item, there is no reason those expenses cannot be recovered as discovery sanctions. It bears noting, we think, that even if a pro se lawyer could recover his "reasonable attorney's fees," that would not necessarily mean that he could recover the usual hourly rate (including both profit and overhead) at which he bills his clients for similar services or calculates his fees for other purposes, or that he could recover for all of the time he devoted to his own case. A client who had anyone other than himself for a lawyer might question the reasonableness of three and one-half hours spent on a boilerplate motion to compel production of documents, or the propriety of two hours charged for his appearance at a hearing held at the same time as other unrelated motions and a status conference. But legitimate costs that can be identified ought to be recoverable by all litigants, including those who appear pro se.