California, United States of America
The following excerpt is from Steiny v. Calif. Electric Supply, 79 Cal.App.4th 285, 93 Cal.Rptr.2d 920 (Cal. App. 2000):
Morley complains that Steiny failed to supply billing statements to support its attorneys declaration seeking attorneys fees. But there is no legal requirement that such statements be offered in evidence. An attorney's testimony as to the number of hours worked is sufficient evidence to support an award of attorney fees, even in the absence of detailed time records. (Martino v. Denevi (1986) 182 Cal.App.3d 553, 559.) The trial court did not err in crediting the attorney declaration here, which included detailed evidence of hours spent, tasks concluded, and billing rates.
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