Can a defendant avoid the burden of establishing attorney fees by submitting a declaration from counsel rather than billing records or invoices?
California, United States of America
The following excerpt is from Biomedical v. Nunez, B243205, C/w B246602 (Cal. App. 2014):
time they spent of various tasks and "did not even supply time records to [ support] their . . . after-the-fact time estimates." A defendant, however, can carry its burden of establishing its entitlement to attorney fees by submitting a declaration from counsel instead of billing records or invoices. (City of Colton v. Singletary (2012) 206 Cal.App.4th 751, 785.)
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