California, United States of America
The following excerpt is from Majestic Asset Mgmt., LLC v. Colony At Cal. Oaks Homeowners Ass'n, D072627, D072628 (Cal. App. 2018):
Based on our review of the record, we conclude the trial court did not abuse its discretion by not apportioning, or attempting to apportion, attorney fees between work performed on contract causes of action and work performed on tort causes of action. After presiding over the trial and posttrial proceedings in this case, the court was in an optimal position to make its determination that the contract and tort causes of action involved in this case were so intertwined that apportionment of attorney fees was not appropriate. As discussed above, a trial court is not required to apportion attorney fees between contract claims and noncontract claims when it reasonably finds all claims in the case were inextricably intertwined. (Abdallah v. United Savings Bank, supra, 43 Cal.App.4th at p. 1111.)
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