California, United States of America
The following excerpt is from City of Upland v. Inland Oversight Comm., E073768 (Cal. App. 2020):
"The applicant bears the burden of establishing each criterion required for an attorney fee award under section 1021.5 . . . [citation] . . . ." (Bui v. Nguyen (2014) 230 Cal.App.4th 1357, 1375, fn. 9.)
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