California, United States of America
The following excerpt is from Urquhart v. Kurtin, B250245 (Cal. App. 2014):
Defendant argues plaintiff is not entitled to recover attorney's fees for fees incurred during the confirmation proceedings in the trial court. As noted, plaintiff represented itself during the judicial confirmation proceeding. Defendant contends section 1717 applies in this instance because plaintiff seeks to enforce an award pursuant to a mandatory arbitration provision in the parties' contract. We review this issue de novo. (Connerly v. State Personnel Bd. (2006) 37 Cal.4th 1169, 1175 [de novo review of a trial court's award of attorney's fees "is warranted where the determination of whether the criteria for an award of attorney fees and costs in this context have been satisfied amounts to statutory construction and a question of law"]; Ramon v. Count of Santa Clara (2009) 173 Cal.App.4th 915, 920.)
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