On remand, what are the costs of attorney fees deducted from the settlement proceeds?

On remand, the court must also determine whether attorney fees and other litigation costs should be deducted from the settlement proceeds before [66 Cal.App.4th 744] City is reimbursed. Ordinarily, parties are responsible for their own attorney fees. (Code Civ. Proc., 1021.) "But an established exception to this rule is the so-called 'common fund doctrine.' [Citation.] That is, a party who expends attorney fees in winning a lawsuit which creates a fund from which others derive benefits may require those passive beneficiaries to bear a fair share of the litigation costs. The amount of the judgment owing to the passive beneficiary may be reduced to compensate the active litigant for his [or her] attorney fees. [Citation.]" (Walsh v. Woods (1986) 187 Cal.App.3d 1273, 1276, 232 Cal.Rptr. 629.)