Can a court award an excessive attorney fee for work related to an anti-SLAPP motion?

Appellants contend the fee award was excessive because it included "block billing entries" for legal work unrelated to the anti-SLAPP motion, but related instead to a demurrer that respondents filed together with the anti-SLAPP motion. The trial court specifically found that the time appellants' counsel spent preparing the demurrer was "inextricably entwined" with the time spent on the anti-SLAPP motion and should be included in the attorney fee award. (Mann v. Quality Old Time Service, Inc. (2006) 139 Cal.App.4th 328, 344-345.)

Appellants concede that "in some instances the work done on both demurrers and the anti-SLAPP motion cannot be reasonably separated" but take issue with time entries on invoices submitted by respondents' counsel that include work performed on both the demurer and the anti-SLAPP motion. A trial court is not required to allocate attorney fees for work on issues or claims that are so intertwined that it is impossible to separate them. (Akins v. Enterprise Rent-A-Car Co. (2000) 79 Cal.App.4th 1127, 1133.)