California, United States of America
The following excerpt is from Vescovi v. Clark, G052716 (Cal. App. 2017):
It is well settled the joinder of causes of action need not necessarily dilute the right to attorney fees. (Akins v. Enterprise Rent-A-Car Co. (2000) 79 Cal.App.4th 1127, 1133.) "Such fees need not be apportioned when incurred for representation of an issue common to both a cause of action for which fees are permitted and one for which they are not. All expenses incurred on the common issues qualify for an award.
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