California Chamber of Commerce v. Rob Bonta

Summary

The United States District Court for the Eastern District of California denied the California Chamber of Commerce’s request for $64,653.60 in attorney’s fees and expenses under Federal Rule of Civil Procedure 37(c)(1)(A). Although the court had excluded the intervenor’s expert testimony for noncompliant disclosures, it found the fee request insufficiently supported and noted that the request could be pursued in a later motion for attorney’s fees under Local Rule 293.

Holdings

1. Plaintiff was not entitled to the requested additional monetary sanction because it failed to demonstrate that the amount of fees sought was reasonable, and the request was more appropriately presented in a motion for attorney's fees under Local Rule 293.
2. The court excluded testimony from CERT's experts because CERT's disclosures did not comply with Federal Rule of Civil Procedure 26(a)(2)(B).

Questions Presented

1. Whether plaintiff was entitled to additional monetary sanctions, including attorney's fees and expenses, under Federal Rule of Civil Procedure 37(c)(1)(A) after CERT's noncompliant expert disclosures resulted in exclusion of the experts.
2. Whether plaintiff demonstrated that the requested attorney's fees were reasonable under the lodestar method.

Disposition

denied