MedLab2020, Inc. v. UHC of California

America (2020) 48 Cal.App.5th 240, 246-247.) The party claiming fees has the burden of showing that the fees incurred were reasonably necessary to the conduct of the litigation, and reasonable in amount. (Ibid; Levy v. Toyota Motor Sales, U.S.A., Inc. (1992) 4 Cal.App.4th 807, 816.)

“In challenging attorney fees as excessive because too many hours of work are claimed, it is the burden of the challenging party to point to the specific items challenged, with a sufficient argument and citations to the evidence. General arguments that fees claimed are excessive, duplicative, or unrelated do not suffice.” (Premier Medical Management Systems, Inc. v. California Ins. Guarantee Assn. (2008) 163 Cal.App.4th 550, 564.)

With regard to the determination of a reasonable hourly rate, the court may rely on its own knowledge and familiarity with the legal market as well as the experience, skill, and reputation of the attorney requesting fees, the difficulty or complexity of the litigation to which that skill was applied, and declarations from other attorneys regarding prevailing fees in the community and rate determinations in other cases. (Morris v. Hyundai Motor America (2019) 41 Cal.App.5th 24, 41.)

The Court finds the hourly rates requested adequately supported and reasonable given counsels’ experience and the nature of the dispute. (See Wirtz Decl., ¶¶ 4-11, 17-26 and Exs. 2-4; see also, Baer v. Tedder (2025) 115 Cal.App.5th 1139, 1160-1161.) Defendant argues the hourly rates are unreasonable. However, Defendant failed to present any evidence to rebut the hourly rates requested.

The Court finds the requested multiplier not justified on the record presented and thus the request for a multiplier is DENIED

The Court has reviewed the billing records submitted by Plaintiff’s counsel and determines the fees claimed are reasonable in light of the circumstances of this case. While the total amount of fees sought is substantial, the amount of time incurred is supported by counsel’s declaration and the detailed billing records.

Defendant failed to show any specific billing entries should be reduced as excessive or unreasonable.

Based on the foregoing, the motion is GRANTED IN PART to award Plaintiff total attorney’s fees against Defendant in the sum of $42,125.00.

Plaintiff’s evidentiary objections are OVERRULED.

Counsel for Plaintiff is ordered to give notice of this ruling.

2. MedLab2020, Inc. v. UHC of California Before the Court is the unopposed application of attorney Robert Keefe to appear in this matter pro hac vice as counsel for defendants.

25-1506621

Mr. Keefe has complied with the requirements set forth in California Rules of Court, Rule 9.40. Accordingly, the application is GRANTED.

Mr. Keefe is ordered to give notice of this ruling.

3. Kolaar v. FCA US LLC 25-1493558 The motion for terminating sanctions filed by defendants FCA US LLC and Huntington Beach Chrysler Dodge Jeep Ram (collectively, Defendants) against plaintiff Aaron Van Korlaar (Plaintiff) is DENIED WITHOUT PREJUDICE.

The proof of service for this motion lists an incorrect email address for Plaintiff’s counsel. The email address for Plaintiff’s counsel listed in the proof of service contains a misspelling and omits the number 4 from the email address. (See ROA 10, 41.) There is no opposition filed. It is thus unclear if Plaintiff received proper notice of this motion.

Based on the foregoing, the motion is DENIED WITHOUT PREJUDICE.

Counsel for Defendant shall give notice.

4. Jergensen v. NAHS Holding, Inc. 24-1411114 The Motion for an Order Authorizing Alternative Service by Defendants, NAHS Holding, Inc., NAHS SouthEast, Inc., Mark Walton and Michael Moore, is DENIED.

The only method authorized for service of a subpoena on a non-party deponent is personal service. [CCP §1981(a); CCP 2020.220(b); Target National Bank v. Rocha (2013) 216 CA4th Supp. 1, 7-8; In re Abrams (1980)108 Cal.App.3rd 685, 690] No “alternate service” is authorized.

5. Li v. Li 25-1517999

Self-represented plaintiff Jun Li brought this action against defendant Xian Li on October 13, 2025. The complaint (ROA 1) asks for declaratory relief in the form of a judicial statement that defendant’s unauthorized modification of the official filing of StarRide Auto Services, LLC, is invalid.

On December 31, 2025, plaintiff filed proof of service on defendant Xian Li by personal service on November 18, 2025.

When electronic filing and service are mandatory, some important exemptions apply, including one relating to self-represented litigants. Code Civ. Proc. § 1010.6(g)(4); CRC 2.253(b)(2).

If a case involves both represented and unrepresented parties, the electronic filing and service requirements apply only to the represented parties. Unrepresented parties are permitted to file, serve, and be served by nonelectronic means unless they affirmatively consent to electronic service. CRC 2.254(b)(3).

Nothing in the Court’s file indicates that plaintiff has affirmatively consented to electronic service. Therefore, plaintiff was entitled to service of the motion through a means other than electronic service.