When will an employer be required to provide an adequate record to support its claim for attorney fees?

As the party challenging the fee award, Employers had an affirmative obligation to provide an adequate record so that we may assess whether the trial court abused its discretion. (Vo v. Las Virgenes Municipal Water Dist. (2000) 79 Cal.App.4th 440, 447.) We are mindful the "experienced trial judge is the best judge of the value of professional services rendered in his court, and while his judgment is of course subject to review, it will not be disturbed unless the appellate court is convinced that it is clearly wrong." (Serrano v. Priest (1977) 20 Cal.3d 25, 49 [internal citations].) Thus, the absence of a transcript detailing precisely what the trial court considered in making its

Page 5

award of attorney fees to Barahona hampers a determination the trial court abused its discretion.