Can an attorney who chooses to litigate in propria persona, therefore not pay consideration in exchange for legal representation, recover reasonable attorney fees?
California, United States of America
The following excerpt is from Law Offices of Mark B. Plummer PC v. Bayuk, G053836 (Cal. App. 2017):
"[A]n attorney who chooses to litigate in propria persona and therefore does not pay or become liable to pay consideration in exchange for legal representation cannot recover 'reasonable attorney fees' under section 1717 as compensation for the time and effort he expends on his own behalf or for the professional business opportunities he forgoes as a result of his decision." (Trope v. Katz (1995) 11 Cal.4th
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