The Law Firm of Fox & Fox v. Arteaga CA2/5
Plaintiff and appellant, the Law Firm of Fox and Fox (the Fox firm) represented itself through Attorney Frank O. Fox in a lawsuit filed against a former client—defendant and respondent Miguel Arteaga. Following a judgment in plaintiff’s favor, plaintiff filed a motion for attorney fees. Although the California Supreme Court has held an attorney who litigates in propria persona cannot recover attorney fees under Civil Code section



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