What is the test for recoverable out-of-pocket expenses in the context of an award of attorney's fees?
MultiRegion, United States of America
The following excerpt is from Willis v. City of Fresno, Case No. 1:09-cv-01766-BAM (E.D. Cal. 2018):
"Under 1988, the prevailing party may recover as part of the award of attorney's fees those out-of-pocket expenses that would normally be charged to a fee paying client." Dang v. Cross, 422 F.3d 800, 814 (9th Cir. 2005) (citations and internal quotation marks omitted). "Such out-of-pocket expenses are recoverable when reasonable." Id.
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