California, United States of America
The following excerpt is from Limon v. Dep't of Fin., C082501 (Cal. App. 2019):
Kerkeles v. City of San Jose (2015) 243 Cal.App.4th 88 (Kerkeles) used this federal rule in reversing an award of attorney fees where the trial court reduced the lodestar amount by 50 percent without providing a sufficient explanation. (Id. at p. 104.)
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