California, United States of America
The following excerpt is from Cosolo v. Verizon Cal. Inc, E049017, No. RCVRS099168 (Cal. App. 2011):
"'[I]f the items appear to be proper charges, the verified memorandum is prima facie evidence that the costs, expenses and services therein listed were necessarily incurred by the [party] [citations], and the burden of showing that an item is not properly chargeable or is unreasonable is upon the [objecting party].' [Citations.]" (Nelson v. Anderson (1999) 72 Cal.App.4th 111, 131.) "The court's first determination, therefore, is whether the statute expressly allows the particular item, and whether it appears proper on its face. [Citation.] If so, the burden is on the objecting party to show them to be unnecessary or unreasonable. [Citation.]" (Ibid.)
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