California, United States of America
The following excerpt is from Millennium-Diamond Rd. Partners, LLC v. Diamond Bar Country Estates Ass'n, B285539, c/w B288020, c/w B289009 (Cal. App. 2019):
Moreover, apportionment is not required where the distinct causes of action involve a common core of facts or are based on related legal theories. (Drouin v. Fleetwood Enterprises (1985) 163 Cal.App.3d 486, 493.) Here, the trial court declined to apportion fees and stated the reasons for doing so.
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