Ready to Register?

MyLawCLE All-Access Pass

Best choice

Add the All-Access Pass and get this program —
plus 1,000+ live CLE programs every year.


All specialty & ethics credits included
38 practice areas
New sections: AI & the Law, Practice Management
100s of current and trending legal topics
Nationally recognized and highly experienced presenters

$395 / year — this program included
Register with the All-Access Pass

This program + 1,000+ CLE programs, all year

Or register for just this program

Live Video Broadcast

Live webinar of this one program.
$195 Register

On-Demand Video

Recorded access + self-study credit.
$195 Register

Opposing the Prevailing Party’s Fee Motion: Cutting Hours, Rates, and Multipliers After the 2026 Rulings

Recent 2026 fee rulings show courts will make substantial cuts when the paying party builds a precise record. Learn to turn the applicant’s time records into line-item objections, impeach hourly rates, propose an alternative lodestar, and oppose a multiplier.

2026-12-15 14:30:00

Program Details

2026-12-15 14:30:00

Program Details

2026-12-15 14:30:00

Over 1,000+ webinars

2026-12-15 14:30:00

Course Overview

The Fee Award Is Cut Line by Line and Rate by Rate

2026-12-15 14:30:00

Recent fee rulings, including the California Court of Appeal’s July 2026 decision in Del Biaggio v. Bansen and the 2026 In re Google Real-Time Bidding order, show courts will make substantial cuts when the paying party builds a precise record. In class actions and other fee-shifting cases, the applicant’s own time records are the raw material. The question is whether the opposition turns them into findings a court can adopt.

Ask for an unexplained haircut above 10%, and the Ninth Circuit may vacate it. Attack a rate without market evidence, and the rate survives, as it did in Del Biaggio. Benchmark against your own hours, and your own billing may become discoverable. Concede exceptional results, and the multiplier follows.

Attendees walk out with a category-exhibit template, a sequencing checklist, a rate-evidence checklist, and an alternative-figure worksheet. It is practitioner judgment from attorneys whose practice centers on attorney fee disputes and the line-by-line analysis of fee requests.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
The Native Export
How to obtain the applicant’s native billing export without opening your own billing to discovery.
02
How to obtain the applicant’s native billing export without opening your own billing to discovery.
How to code time entries into totaled objection categories, including block billing and paralegal time after Del Biaggio.
03
Percentage Versus Line-Item Cuts
How Moreno’s 10% haircut and Gonzalez’s explanation requirement shape which reduction a court will sustain.
04
Impeaching the Rate
How prior awards, actual billing evidence, and rate schedules build a record that holds the hourly rate down.
05
The Alternative Lodestar
How the 2026 In re Google RTB order supports an alternative figure and answers valuation-based fee requests.
06
Defeating the Multiplier
How to oppose an enhancement without conceding exceptional results, and how to distinguish Rodriguez v. Google.

Program schedule

clock 2:30 pm - 3:30 pm EST

Building the Line-Item Fee Opposition From the Applicant's Own Time Records

This session walks fee opponents, the defendants and losing contract parties ordered to pay fees, through building a line-item fee opposition from the applicant’s own time records. Attorneys will learn how to obtain the native billing export without opening their own billing to discovery, how to code entries into totaled objection categories, what the July 2026 decision in Del Biaggio v. Bansen means for block billing and paralegal time, how to choose between the Ninth Circuit’s unexplained 10% haircut under Moreno v. City of Sacramento and explained line-item cuts under Gonzalez v. City of Maywood, and how federal-scale files such as In re Google Real-Time Bidding structure layered reductions. Attendees will leave with a category-exhibit template, a sequencing checklist, and a clear view of the objections that backfire.

John D. O’ConnorJohn D. O’Connor
clock 3:40 pm - 4:40 pm EST

Holding Down the Rate and Defeating the Multiplier in a Fee Opposition

This session takes paying-party counsel through holding down the hourly rate and defeating valuation methods and multipliers when opposing a prevailing party’s fee motion. Attorneys will learn why the rate attack in Del Biaggio v. Bansen failed for lack of market evidence, how to build a rate-impeachment record from prior awards, actual billing evidence, and rate schedules such as the Fitzpatrick Matrix, how to respond to mid-case rate increases and low-level work billed at full rates, how the 2026 In re Google RTB order supports an alternative lodestar figure and a deferral request, how to oppose a multiplier without conceding exceptional results, and how to distinguish Rodriguez v. Google as a comparator. Attendees will leave with a rate-evidence checklist, an alternative-figure worksheet, and a framework for deciding whether to retain a fee auditor or rate expert.

Benjamin J. PekarekBenjamin J. Pekarek
Benjamin J. Pekarek

Benjamin J. Pekarek

O'Connor and Associates

John D. O’Connor

John D. O’Connor

O'Connor and Associates

Benjamin J. Pekarek

Benjamin J. Pekarek

O'Connor and Associates

Benjamin J. Pekarek practices with O’Connor and Associates in San Francisco, a litigation boutique with recognized excellence in trial practice and an expertise in attorney fee disputes, where he works primarily in business litigation and attorney fee consultation. Drawing on a solid foundation in accounting and finance, he reviews legal invoices, cuts through cryptic and ambiguous descriptions of services, and synthesizes a case’s billings into easily digestible demonstratives that lay the foundation for the firm’s expert analysis of whether the hours billed on a given task, and on a case as a whole, are reasonable. He is especially well suited to this program: line-by-line review of attorney invoices, specialized review of billing-guideline compliance for insurance carriers and other clients, and concurrent legal and business graduate training with a concentration in corporate finance, bringing the perspective of a practitioner who turns raw time records into evidence a court can use.

Education & Credentials

Mr. Pekarek graduated in 2014 from both the University of San Diego School of Law and the University of San Diego School of Business, where he concurrently earned his Juris Doctor and a Master of Business Administration with a concentration in corporate finance. He earned his B.A. in Business Administration from the University of San Diego, graduating summa cum laude from the Honors Program. He is admitted to practice in California.

Professional Involvement

During law school, Mr. Pekarek was a Legal Intern at the University of San Diego's Entrepreneurship Clinic, where he provided legal services to low-income entrepreneurs in the San Diego area, and a Research Assistant to Professor Mark Lee, conducting research for the annual update to his textbook, Organizing Corporate & Other Business Enterprises. As a master's candidate, he traveled to Shanghai, China, where he consulted for a startup telecommunications company seeking to enter the United States market and presented his findings directly to its Board of Directors.

Experience

At O'Connor and Associates, Mr. Pekarek has specialized in reviewing invoices for compliance with billing guidelines set by insurance carriers and other clients, and his billing analysis and demonstratives support the firm's expert work on the reasonableness of fees in attorney fee disputes. He also practices business litigation alongside his attorney fee consultation work. Before joining the firm, he worked as a summer law clerk in the employment law department of Gordon Rees Scully Mansukhani, LLP's San Francisco office.
John D. O’Connor

John D. O’Connor

O'Connor and Associates

John D. O’Connor is the Principal of O’Connor and Associates in San Francisco, where he is regularly retained as both an expert and a litigator in attorney fee disputes and as a confidential fee consultant. He has more than 50 years of litigation experience, ranging from personal injury to civil rights, employment, and complex business cases, and for more than 40 years a significant part of his work has been the evaluation, litigation, and resolution of attorney fee issues for both fee payors and fee petitioners. He is especially well suited to this program: acceptance as an expert witness in more than 300 cases, representation of fee payors under fee-shifting statutes as an Assistant United States Attorney and for county and municipal governments, and consultation on hundreds of adversarial legal fee disputes, bringing the perspective of a fee expert whose analyses courts have repeatedly adopted.

Education & Credentials

Mr. O'Connor earned his J.D., cum laude, from the University of Michigan Law School in 1972, where he was a member of the Michigan Law Review and served as an Associate Editor, was elected to the Order of the Coif, and won three AmJur awards as the most outstanding student in a subject. He received his A.B., magna cum laude, from the University of Notre Dame in 1968.

Recognition & Leadership

The National Association of Legal Fee Analysis named Mr. O'Connor the Nation's Top Attorney Fee Expert for 2017 through 2024. For 20 years he served as managing partner of Tarkington, O'Connor and O'Neill, where he was responsible for all firm billings and supervised billing seminars for new lawyers, and from 2001 to 2006 he was a Director (Partner) and Special Counsel at Howard Rice.

Professional Involvement

Mr. O'Connor is a member of the National Association of Legal Fee Analysis and lectures on attorney fees in nationwide webinars for NALFA and other organizations. He has served as a JAMS mediator and as a named arbitrator on a three-arbitrator JAMS panel that heard competing fee experts and auditors over more than $2 million in asbestos billings.

Experience

Mr. O'Connor began his career at Belli, Ashe & Choulos and then served in the criminal and civil divisions of the U.S. Attorney's Office, where he assessed, negotiated, and litigated fees in fee-shifting civil rights cases, including Saunders v. NARF in the Northern District of California and the Ninth Circuit. He has represented governmental entities in fee litigation, including litigating the fees of Heller Ehrman in the Sonoma County jail class action, worked with the FDIC, NCUA, and RTC on billing protocols, and reviewed underlying counsel's bills for insurers and reinsurers. He has tried more than 80 cases in state and federal courts throughout the country, and courts have repeatedly cited and adopted his fee analyses in their orders.
Benjamin J. Pekarek

Benjamin J. Pekarek

O'Connor and Associates

Benjamin J. Pekarek practices with O’Connor and Associates in San Francisco, a litigation boutique with recognized excellence in trial practice and an expertise in attorney fee disputes, where he works primarily in business litigation and attorney fee consultation. Drawing on a solid foundation in accounting and finance, he reviews legal invoices, cuts through cryptic and ambiguous descriptions of services, and synthesizes a case’s billings into easily digestible demonstratives that lay the foundation for the firm’s expert analysis of whether the hours billed on a given task, and on a case as a whole, are reasonable. He is especially well suited to this program: line-by-line review of attorney invoices, specialized review of billing-guideline compliance for insurance carriers and other clients, and concurrent legal and business graduate training with a concentration in corporate finance, bringing the perspective of a practitioner who turns raw time records into evidence a court can use.

Education & Credentials

Mr. Pekarek graduated in 2014 from both the University of San Diego School of Law and the University of San Diego School of Business, where he concurrently earned his Juris Doctor and a Master of Business Administration with a concentration in corporate finance. He earned his B.A. in Business Administration from the University of San Diego, graduating summa cum laude from the Honors Program. He is admitted to practice in California.

Professional Involvement

During law school, Mr. Pekarek was a Legal Intern at the University of San Diego's Entrepreneurship Clinic, where he provided legal services to low-income entrepreneurs in the San Diego area, and a Research Assistant to Professor Mark Lee, conducting research for the annual update to his textbook, Organizing Corporate & Other Business Enterprises. As a master's candidate, he traveled to Shanghai, China, where he consulted for a startup telecommunications company seeking to enter the United States market and presented his findings directly to its Board of Directors.

Experience

At O'Connor and Associates, Mr. Pekarek has specialized in reviewing invoices for compliance with billing guidelines set by insurance carriers and other clients, and his billing analysis and demonstratives support the firm's expert work on the reasonableness of fees in attorney fee disputes. He also practices business litigation alongside his attorney fee consultation work. Before joining the firm, he worked as a summer law clerk in the employment law department of Gordon Rees Scully Mansukhani, LLP's San Francisco office.
John D. O’Connor

John D. O’Connor

O'Connor and Associates

John D. O’Connor is the Principal of O’Connor and Associates in San Francisco, where he is regularly retained as both an expert and a litigator in attorney fee disputes and as a confidential fee consultant. He has more than 50 years of litigation experience, ranging from personal injury to civil rights, employment, and complex business cases, and for more than 40 years a significant part of his work has been the evaluation, litigation, and resolution of attorney fee issues for both fee payors and fee petitioners. He is especially well suited to this program: acceptance as an expert witness in more than 300 cases, representation of fee payors under fee-shifting statutes as an Assistant United States Attorney and for county and municipal governments, and consultation on hundreds of adversarial legal fee disputes, bringing the perspective of a fee expert whose analyses courts have repeatedly adopted.

Education & Credentials

Mr. O'Connor earned his J.D., cum laude, from the University of Michigan Law School in 1972, where he was a member of the Michigan Law Review and served as an Associate Editor, was elected to the Order of the Coif, and won three AmJur awards as the most outstanding student in a subject. He received his A.B., magna cum laude, from the University of Notre Dame in 1968.

Recognition & Leadership

The National Association of Legal Fee Analysis named Mr. O'Connor the Nation's Top Attorney Fee Expert for 2017 through 2024. For 20 years he served as managing partner of Tarkington, O'Connor and O'Neill, where he was responsible for all firm billings and supervised billing seminars for new lawyers, and from 2001 to 2006 he was a Director (Partner) and Special Counsel at Howard Rice.

Professional Involvement

Mr. O'Connor is a member of the National Association of Legal Fee Analysis and lectures on attorney fees in nationwide webinars for NALFA and other organizations. He has served as a JAMS mediator and as a named arbitrator on a three-arbitrator JAMS panel that heard competing fee experts and auditors over more than $2 million in asbestos billings.

Experience

Mr. O'Connor began his career at Belli, Ashe & Choulos and then served in the criminal and civil divisions of the U.S. Attorney's Office, where he assessed, negotiated, and litigated fees in fee-shifting civil rights cases, including Saunders v. NARF in the Northern District of California and the Ninth Circuit. He has represented governmental entities in fee litigation, including litigating the fees of Heller Ehrman in the Sonoma County jail class action, worked with the FDIC, NCUA, and RTC on billing protocols, and reviewed underlying counsel's bills for insurers and reinsurers. He has tried more than 80 cases in state and federal courts throughout the country, and courts have repeatedly cited and adopted his fee analyses in their orders.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

Upcoming Live Online CLE Broadcasts

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Pending
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs