Judge: Malcolm Mackey, Case: 20STCV25977, Date: 2022-12-12 Tentative Ruling
Case Number: 20STCV25977 Hearing Date: December 12, 2022 Dept: 55
FLORES
v. GENERAL MOTORS, LLC 20STCV25977
Hearing Date: 12/12/22,
Dept. 55
#3: MOTION FOR ATTORNEYS' FEES AND COSTS.
Notice: Okay
Opposition
MP:
Plaintiffs
RP:
Defendant
Summary
On 7/9/20, plaintiff filed a Lemon Law Complaint, alleging
that they purchased a 2017 GMC Terrain vehicle, manufactured by Defendant,
having defects, including the transmission, control system, and inoperable
reverse shifting.
MP
Positions
Moving parties request an order awarding attorneys’
fees and costs, in the sum of $43,725.01, on
grounds including the following:
·
GM merely contends that "Plaintiffs'
counsels' fees are unreasonable and exaggerated" with the only evidence in
support being the personal opinion of its counsel, which is not the standard
upon which this Court must use in determining
whether Plaintiffs are entitled to their fees and costs. Attorney fee
awards should be "fully compensatory[.]" (Ketchum v. Moses (2001) 24 Cal.4th
1122, 1133.).
·
GM did not meet the burden to overcome the
presumed credibility of TBLF's billing records (Horsford v. Board of Trustees
of California State University (2005) 132 Cal.App.4th 359, 396).
·
There were not seven attorneys used for
"egregious level[s] of 'padding"' on this case. Exhibit "5" attached to
Plaintiffs' fee motion clearly shows billing details, as well as declarations
attached to the reply.
·
GM's speculation and opinions regarding TBLF's
time entries, should be disregarded.
·
Pre-engagement work and status
communications with the client sufficiently fall within the statutory mandate
of providing recovery for fees "in connection with the commencement and
prosecution of such action" (Civil Code § 1794(d)). Distinguishably, Dominguez v. Am. Suzuki
Motor Corp. (2008) 160 Cal. App. 4th 53, 58, dealt with the willfulness issue
as it applies to civil penalties and attorneys’ fees.
·
The discovery was tailored to this case,
and not copied from other Lemon Law cases.
·
This case was in litigation for almost 2
years.
·
Specifics are as follows:
RP
Positions
Opposing party advocates reducing the award to at
least $29,150.00, for reasons including the following:
·
The Barry Law Firm seeks $43,725.01 in
fees and costs, for “billing” 100.80 hours of work, done by seven different
timekeepers, in a breach of warranty
case that did not raise any complex or novel issues.
·
Counsel has billed grossly excessive
amounts for preparing template-based correspondence, discovery and motions.
·
Meet-and-confer discovery letters did not
try to resolve any disputes; they simply listed so-called deficiencies.
·
Counsel’s time records and its actual
work-product, does not support that the time “billed” was either actually or
reasonably incurred.
·
Mr. Barry should not recover anything for
the 2.9 hours ($1,575.00) he “billed” to the file before Plaintiffs were even
clients of Counsel’s firm, such as a “telephonic conference with potential
client.” Dominguez v. Am. Suzuki Motor Corp.
(2008) 160 Cal. App. 4th 53, 58.
·
Mr. Barry should not recover anything for
the 0.4 hours ($210.50) he “billed” to “prepare representation agreement,”
which is a business expense not billed to clients.
·
Mr. Barry should not recover for the .5
hours ($262.50) he “billed” communicating with Plaintiffs about case status.
·
Mr. Barry, Ms. Galaviz and Mr. Hayes
entered duplicative billing on Plaintiffs’ status reports to their clients and
meet and confer letters.
·
Counsel should not get full credit for the
12.8 hours ($5,722.50) that Counsel claims that it has spent or will spend on
its fee motion based on templates.
·
Some costs are not recoverable, including
reporter fees, messenger fees, and mileage and parking for hearings.
Tentative
Ruling
The motion is granted, as prayed.
The Court awards to plaintiffs attorneys' fees in the
amount of $43,725.01 against Defendant.
The opposing memorandum and declaration with exhibits
do not disprove any of the claimed attorneys’ fees, expenses or costs as
defined by law addressing the Song-Beverly Act, and moving counsel’s documents
do not reveal that attorneys duplicated other attorneys’ work.
As to Song–Beverly warranty claims, prevailing buyers
have the burden to show that the fees incurred were reasonably necessary to the
conduct of the litigation, and were reasonable amounts. Doppes v. Bentley Motors, Inc. (2009)
174 Cal.App.4th 967, 998. Under the
Song-Beverly Act, the question whether attorneys’ fees were reasonably incurred
may depend on circumstances including, “factors such as the complexity of the
case and procedural demands, the skill exhibited and the results achieved.” Goglin v. BMW of North America, LLC
(2016) 4 Cal.App.5th 462, 470. The
appellate court reviews awards of attorney fees under Civil Code section 1794,
subdivision (d), for abuse of discretion.
Doppes, supra, at 998.
Civil Code Section 1794(d) requires a court to base
the attorneys’ fee award on actual time expended on the case, and reasonably
incurred, as to time spent, and amount, under all circumstances including
complexity of the case, procedural demands, skill exhibited, and results
achieved. McKenzie v. Ford Motor Co.
(2015) 238 Cal. App. 4th 695, 698, 703 (reversing a judge’s denial of fees
where based on instances of duplicative work).
“The ‘plain wording’ of section 1794, subdivision (d) requires the trial
court to ‘base’ the prevailing buyer's attorney fee award ‘upon actual time
expended on the case, as long as such fees are reasonably incurred—both from
the standpoint of time spent and the amount charged.’ ” Warren v. Kia Motors Am., Inc. (2018)
30 Cal. App. 5th 24, 35. Accord Robertson v. Fleetwood Travel Trailers of
California, Inc. (2006) 144 Cal.App.4th 785, 817. But see Reynolds v. Ford Motor Co. (2020) 47
Cal. App. 5th 1105, 1110 (as to the
Song-Beverly Act, fee awards must be based on the judge’s calculation of actual
time expended determined to have been incurred reasonable, and the Act
does not include a requirement that the court also determine that the amount
of attorneys’ fees is reasonable).
Parties opposing motions for attorneys' fees fail to
show any abuse of discretion where they merely contend that amounts of
attorneys' fees are excessive without providing a specific analysis or factual
support. Mallard v. Progressive
Choice Ins. Co. (2010) 188
Cal.App.4th 531, 545; Raining Data
Corp. v. Barrenechea (2009) 175
Cal.App.4th 1363, 1376 (an “‘assertion [that] is unaccompanied by any citation
to the record or any explanation of which fees were unreasonable or
duplicative’ is insufficient to disturb the trial court's discretionary award
of attorney fees.”); Maughan v.
Google Technology, Inc. (2006) 143 Cal. App. 4th 1242, 1250; Avikian v. Wtc Fin. Corp. (2002) 98
Cal. App. 4th 1108, 1119; Premier
Medical Management Systems, Inc. v. California Insurance Guarantee Association
(2008) 163 Cal.App.4th 550, 560
(emphasizing that opposing parties “submitted no evidence that the hours
claimed by counsel were excessive,” and declining to “declare as a matter of
law that the hours were unreasonable”); Villanueva
v. City of Colton (2008) 160 Cal.App.4th 1188, 1204 (opposing party
“offered no evidence of any kind which might have warranted a reduced fee
award.”).
A trial court’s referencing counsel’s use of
templates, as one part of reasoning that a reduced number of attorneys was
needed in a case, was affirmed. See Morris v. Hyundai Motor Am. (2019) 41
Cal. App. 5th 24, 31-33, 39 (“asserted
that even though her counsel used ‘form documents’ in the case, work was
necessary to conform those templates to the actual facts of this case.”). Legal
research indicates that there is no governing California authority requiring
reduced fees for efficiently reusing information derived from other cases that
counsel handled. "A legal
proposition asserted without apposite authority necessarily fails." People v. Taylor (2004) 119
Cal.App.4th 628, 643.
A court “ ‘indicated a fee reduction was warranted
because it was unreasonable to have so many lawyers staffing a [Song-Beverly
Act] case that did not present complex or unique issues, did not involve
discovery motions, and did not go to trial.’ ” Mikhaeilpoor v. BMW of North America, LLC
(2020) 48 Cal.App.5th 240, 253.
[Emphasis added.]
“[W]hen attorney fees are recoverable by statute, the
reasonable attorney fees incurred in preparing the motion are also
recoverable.” Doppes v. Bentley
Motors, Inc. (2009) 174 Cal.App.4th 967, 1002.
“An across-the-board reduction in hours claimed based
on the percentage of total time entries that were flawed, without respect to
the number of hours that were actually included in the flawed entries, is not a
legitimate basis for determining a reasonable attorney fee award.” Mountjoy v. Bank of America, N.A.
(2016) 245 Cal.App.4th 266, 282.
The Song-Beverly Act requires allowing costs
“determined by the court to have been reasonably incurred by the buyer in
connection with the commencement and prosecution” of the case, which is
reviewed under the abuse of discretion standard. Levy v. Toyota Motor Sales, U.S.A., Inc.
(1992) 4 Cal. App. 4th 807, 813. Cf. Warren v. Kia Motors Am., Inc. (2018)
30 Cal. App. 5th 24, 43 (“it is
indisputable that Warren ‘reasonably incurred’ the $5,882 cost of the trial
transcripts ‘in connection with the ... prosecution of [the] action.’ ”). See also generally Duff v. Jaguar Land Rover N. Am., LLC
(2022) 74 Cal. App. 5th 491, 501
(summarizing Civ. C. § 1794(d)).
“[I]n enacting Civil Code section 1794, subdivision
(d) the Legislature intended the phrase ‘costs and expenses’ to cover items not
included in “ ‘the detailed statutory definition of ‘costs’ ” set forth in Code
of Civil Procedure section 1033.5.” Warren v. Kia Motors Am., Inc. (2018) 30 Cal. App.
5th 24, 42.
As to parties prevailing in an action on a contract
with terms for recovery of attorney fees and costs, counsel's disbursement
costs, such as secretarial, copying, telephone, expert fees and travel, are
recoverable as a part of attorney fees, “if they represent expenses ordinarily
billed to a client and are not included in the overhead component of counsel's
hourly rate.” Bussey v. Affleck
(1st Dist. 1990) 225 Cal. App. 3d 1162, 1166-67. But
see, e.g., Benson v. Kwikset Corp. (4th Dist. 2007) 152
Cal. App. 4th 1254, 1283 (recognizing great weight of a split of authority); Fairchild v. Park (2d Dist.
2001) 90 Cal. App. 4th 919, 930 (disagreeing with Bussey opinion, and
following view that attorney fees and expenses are distinctly different by
statute); Robert L. Cloud &
Assocs., Inc. v. Mikesell (1st
Dist. 1999) 69 Cal. App. 4th 1141, 1154
(“attorney fees do not include expenses….”). Support services, including expenses related
to secretaries and paralegals, are includable in an award for attorneys’
fees. City of Oakland v. McCullough
(1996) 46 Cal.App.4th 1, 7.
Finally, an opinion cited in opposition
distinguishably did not involve a plaintiff prevailing in litigation—the reason
why attorneys’ fees were not available in that case. See
Dominguez v. American Suzuki Motor Corp. (2008) 160 Cal.App.4th
53, 60 (“the Legislature would have
provided for an attorney fees award in section 1793.2, subdivision (d)(1),
which it did not, or it would not have conditioned an attorney fees award on
prevailing in an action, which it did in section 1794, subdivision (d).7 Based
on a plain reading of the applicable statutory provisions, we cannot conclude
the Legislature intended that every time a manufacturer repurchases or replaces
consumer goods, a consumer is entitled to attorney fees, regardless of whether
it was pre- or postcommencement of litigation.”).