California, United States of America
The following excerpt is from Hoffman v. Superior Ready Mix Concrete, L.P., 241 Cal.Rptr.3d 476, 30 Cal.App.5th 474 (Cal. App. 2018):
"Once a trial court determines entitlement to an award of attorney fees, apportionment of that award rests within the court's sound discretion." ( Carver v. Chevron U.S.A., Inc. (2004) 119 Cal.App.4th 498, 505, 14 Cal.Rptr.3d 467 ( Carver ).) " Attorney's fees need not be apportioned when incurred for representation on an issue common to both a cause of action in which fees are proper and one in which they are not allowed. [Citation.] Attorneys fees need not be apportioned between distinct causes of action where plaintiff's various claims involve a common core of facts or are based on related legal theories. [Citation.] Apportionment is not required when the issues in the fee and nonfee claims are so inextricably intertwined that it would be impractical or impossible
[241 Cal.Rptr.3d 485]
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