Immigrant Rights Defense Council v. Sklar CA2/5
I. INTRODUCTION Immigrant Rights Defense Counsel, as the prevailing plaintiff in an action filed under the Immigrant Consultants Act (the ICA; Bus. & Prof. Code, § 22440 et seq.), filed a postjudgment memorandum of costs, seeking to recover attorney fees for enforcing its judgment against defendants. The trial court denied the request for attorney fees on the sole ground that such fees were not recoverable under Code of Civil Procedure
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