Is a plaintiff entitled to attorney's fees for services performed after the trial?

Where a statute defines "costs" to include attorney's fees, such fees are to be included as costs for purposes of Rule 68 cost shifting. Marek v. Chesny, 473, U.S. 1, 8-9 (1985) (concluding "that the term 'costs' in Rule 68 was intended to refer to all costs properly awardable under the relevant substantive statute or other authority.") Thus, a plaintiff who rejects an offer more favorable than what is thereafter recovered at trial will not recover attorney's fees for services performed afterwards. Id.