Does the joinder of the two separate causes of action constitute an equalization of attorney fees?

California, United States of America


The following excerpt is from Vescovi v. Clark, G052716 (Cal. App. 2017):

It is well settled the joinder of causes of action need not necessarily dilute the right to attorney fees. (Akins v. Enterprise Rent-A-Car Co. (2000) 79 Cal.App.4th 1127, 1133.) "Such fees need not be apportioned when incurred for representation of an issue common to both a cause of action for which fees are permitted and one for which they are not. All expenses incurred on the common issues qualify for an award.

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