Legal Fee Audit Declaration - Attorney Fee Motion

Declaration Regarding Plaintiff's Motion for Attorney's Fees

Report Details

• Date: June 10, 2026
• Matter: Christina N. v. City of San Bernardino, et al.
• Court: United States District Court for the Central District of California
• Case No.: 5:24-cv-01593-KK-AGR
• Category: Legal fee audit declaration sample
• Report Type: Declaration concerning a motion for attorney's fees and legal fee audit

Engagement Summary

This declaration was submitted in support of Defendant City of San Bernardino's opposition to Plaintiff's motion for attorney's fees. Plaintiff's attorneys requested $749,835.00 in base fees and sought a 1.25 multiplier, for a total fee request of $937,293.75.

Because the full declaration is lengthy, this page provides a concise summary of the audit, methodology, principal findings, and recommended fee calculation. The full declaration is available as a PDF for attorneys and claims professionals who need the complete analysis.

Audit Scope

The audit reviewed the fee motion, attorney declarations, billing records, deposition and trial materials, and related case documents. The auditor reports reviewing at least 45 documents totaling 4,229 pages and analyzing 849 billing entries for necessity and reasonableness.

Areas of Concern

The declaration identifies several areas of concern with the fee request, including uncertainty over whether certain billing records were contemporaneous or reconstructed estimates, unsupported hourly rates, duplicative work among attorneys, excessive intra-office conferencing, billing for clerical and administrative tasks, vague trial-preparation entries, unusually long billed days, and the requested 1.25 multiplier.

Issues Addressed in the Declaration

• Whether the billing records were adequately supported and contemporaneous.
• Whether the requested hourly rates were supported by the record.
• Whether attorney staffing resulted in duplicated or unnecessary work.
• Whether intra-office conferences and trial-preparation entries were reasonable and sufficiently described.
• Whether clerical, administrative, or vague entries should be reduced or excluded.
• Whether unusually long billed days required adjustment.
• Whether the requested 1.25 multiplier was justified.

Conclusion and Recommendation

The declaration concludes that the requested rates and hours should be reduced and that no multiplier should be awarded. After applying recommended adjustments by timekeeper, the declaration recommends a total attorneys' fee award of no more than $531,468.76.

The full declaration provides the auditor's methodology, supporting analysis, itemized findings, recommended rate adjustments, and final fee calculation.

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