The following excerpt is from Shalaby v. Bernzomatic, 21-55034 (9th Cir. 2021):
Shalaby's assertion that the district court erred in awarding attorneys' fees to and for the work of an attorney allegedly engaged in the unauthorized practice of law lacks merit. First, opposing counsel's work in the present case does not constitute the unauthorized practice of law. See Winterrowd v. Am. Gen. Annuity Ins. Co., 556 F.3d 815, 822-24 (9th Cir. 2009). Second, Shalaby fails to demonstrate any instance of misconduct, let alone the unauthorized practice of law, by his opposing counsel, nor does he provide legal support for the bearing of any alleged misconduct on the fee award here. Accordingly, the district court did not err in its award of reasonable attorneys' fees and costs.
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