California, United States of America
The following excerpt is from City of Palmdale v. Palmdale Lodging, LLC, B282995 (Cal. App. 2019):
evaluation of the reasonable worth of the work done in light of the nature of the case, and of the credibility of counsel's declaration unsubstantiated by time records and billing statements. Although a fee request ordinarily should be documented in great detail, it cannot be said in this particular case that the absence of time records and billing statements deprived the trial court of substantial evidence to support an award; we do not reweigh the evidence." (Weber v. Langholz (1995) 39 Cal.App.4th 1578, 1587.) Thus, although the City submitted a bare-bones declaration supporting the amount of its fees and costs, we conclude the evidence before the trial court was not so insufficient to require a reversal and remand to determine the amount of mandatory section 473 attorney fees and costs awarded.
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