What is the burden of proving that a fee is in line with the prevailing community for similar services?
The following excerpt is from Lin v. Dignity Health-Methodist Hosp. of Sacramento, Civ. No. S-14-0666 KJM CKD (E.D. Cal. 2014):
It is the requesting party's burden to produce evidence that its requested rates are in line with those in the prevailing community for similar services. Minichino, 2012 WL 6554401, at *5 (in anti-SLAPP case, "burden is on the fee applicant to produce satisfactory evidence 'that the requested rates are in line with those prevailing in the community for similar services by lawyers of reasonably comparable skill, experience, and reputation'") (citing Blum v. Stenson, 465 U.S. 886, 895 n.11 (1984)).
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