Reasonable Attorney’s Fee Hearing – Does Attorney Need to Testify at Hearing

Does an attorney at the law firm performing the work need to testify at an evidentiary attorney’s fees hearing to support the reasonableness of the rate and number of hours? Seems like an attorney at the law firm seeking to recover attorney’s fees would absolutely testify, right? Who better to speak about the work performed, number of hours expended, and the reasonableness of the rate than an attorney at the law firm performing the work. Interestingly enough, this was the issue decided by Florida’s new 6th District Court of Appeal in CED Capital Holdings 2000 EB, LLC v. CTCW-Berkshire Club,...