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Patel v. Jakela
Cross-complainants[1] (the Patels) appeal from the courts order granting the motion of respondents Jakela, Inc., and Daniel O. Davis, Inc., (individually Jakela, Inc., and Davis, Inc.; collectively, Jakela) for attorney fees. They contend that the court erred in granting attorney fees under title 42 United States Code section 1988(b) because they were not afforded the 21‑day safe harbor period of Code of Civil Procedure section 128.7, subdivision (c)(1) in which to withdraw their cross-complaint. We affirm and remand the matter to the trial court for a determination of the amount of attorney fees and costs to be awarded on appeal.

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