California, United States of America
The following excerpt is from City of Whittier v. Southland Display Co., B255573, B257744, B260292 (Cal. App. 2016):
While defendants contend the rate was "unreasonable on its face," presumably meaning the rate is unreasonable as a matter of law, they cite no legal authority in support of this assertion. As the appellants, defendants had the burden to affirmatively demonstrate error. (See Denham v. Superior Court (1970) 2 Cal.3d 557, 564 ["A judgment or order of the lower court are presumed correct. . . ., [and] error must be affirmatively shown"].) Simply stating that an hourly rate is unreasonable on its face, without identifying any supporting legal authority, is not sufficient to demonstrate error.
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