Emil James Kohan v. Lucid Group USA, Inc.

CourtDistrict Court, N.D. California
DecidedDecember 18, 2025
Docket3:24-cv-02030
StatusUnknown

This text of Emil James Kohan v. Lucid Group USA, Inc. (Emil James Kohan v. Lucid Group USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emil James Kohan v. Lucid Group USA, Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 EMIL JAMES KOHAN, Case No. 3:24-cv-02030-JSC Plaintiff, 8 ORDER RE: MOTION FOR 9 v. ATTORNEYS’ FEES AND COSTS 10 LUCID GROUP USA, INC., Re: Dkt. No. 31 Defendant. 11 12 13 Emil James Kohan brings warranty claims under California’s Song-Beverly Act against 14 Lucid Group USA, Inc., a vehicle manufacturer Plaintiff purchased a vehicle from in March 2022. 15 The Court previously granted Lucid’s motion to compel arbitration and nine months later Plaintiff 16 accepted Lucid’s Rule 68 offer of judgment. (Dkt. Nos. 22, 24.) Plaintiff now moves for 17 attorneys’ fees and costs seeking $115,429.50 in attorneys’ fees and $5,850.18 in costs. (Dkt. No. 18 31.) After carefully considering the arguments and briefing submitted, the Court concludes oral 19 argument is unnecessary, see Civ. L.R. 7-1(b), VACATES the January 8, 2026 hearing, and 20 GRANTS IN PART and DENIES IN PART the motion. 21 DISCUSSION 22 State law governs attorneys’ fees in diversity cases such as this. Riordan v. State Farm 23 Mut. Auto. Ins. Co., 589 F.3d 999, 1004 (9th Cir. 2009) (“In a diversity case, the law of the state in 24 which the district court sits determines whether a party is entitled to attorney fees, and the 25 procedure for requesting an award of attorney fees is governed by federal law”). Under California 26 law, buyers who prevail in an action under the Song-Beverly Act are entitled to “the aggregate 27 amount of costs and expenses, including attorney’s fees based on actual time expended, 1 commencement and prosecution of such action.” Cal. Civ. Code § 1794(d). A party is a prevailing 2 party if the court, guided by equitable principles, decides the party has achieved its “main 3 litigation objective.” Graciano v. Robinson Ford Sales, Inc., 144 Cal.App.4th 140, 150–51 (2006); 4 see also Wohlgemuth v. Caterpillar Inc., 207 Cal. App. 4th 1252, 1262 (2012) (holding 5 “consumers who successfully achieve the goals of their litigation through a compromise 6 agreement” may recover attorneys’ fees and costs as prevailing parties under the Song-Beverly 7 Act). 8 Courts calculate attorneys’ fees under Section 1794(d) using the “lodestar adjustment 9 method.” Robertson v. Fleetwood Travel Trailers of Cal., Inc., 144 Cal. App. 4th 785, 818 (2006). 10 The lodestar figure consists of “the number of hours reasonably expended multiplied by the 11 reasonable hourly rate.” PLCM Grp. v. Drexler, 22 Cal. 4th 1084, 1095 (2000). A reasonable 12 hourly rate is defined as “that prevailing in the community for similar work.” Id. As to the 13 computation of hours, “trial courts must carefully review attorney documentation of hours 14 expended.” Ketchum v. Moses, 24 Cal. 4th 1122, 1132 (2001). 15 The parties do not dispute Plaintiff, as the prevailing party in this action, is entitled to 16 recoup reasonable attorneys’ fees, costs, and expenses under the Song-Beverly Act. (Dkt. No. 25, 17 Offer of Judgment at § 5.) See also Cal. Civ. Code § 1794(d). Instead, the question is whether 18 Plaintiff’s request for $121,279.68 in attorneys’ fees and costs is reasonable. Lucid insists it is not 19 because Plaintiffs’ counsels’ hourly rates and hours billed are excessive, Plaintiff is not entitled to 20 recovery for certain categories of work, and Plaintiff is not entitled to the 1.5 multiplier sought. 21 A. Lodestar Calculation 22 Plaintiff contends counsel performed 121.60 hours of work for a total lodestar of $77,058. 23 Plaintiff categorizes the work performed as follows: 24 25 Litigation Stage Hours Fees 26 Pre-Filing 11 $5,980 27 Post-Filing/Discovery and Settlement 71.9 $44,050 1 Motion for Attorneys’ Fees and Costs 31.6 $9,085 2 (Dkt. No. 31-2.) 3 1. Reasonable Hourly Rates 4 To determine whether counsel’s hourly rates are reasonable, the Court looks to the “hourly 5 amount to which attorneys of like skill in the area would typically be entitled.” Ketchum, 24 Cal. 6 4th at 1133. “The fee applicant has the burden of producing satisfactory evidence, in addition to 7 the affidavits of its counsel, that the requested rates are in line with those prevailing in the 8 community for similar services of lawyers of reasonably comparable skill and reputation.” Jordan 9 v.Multnomah Cty., 815 F.2d 1258, 1263 (9th Cir. 1987). In addition, Civil Local Rule 54-5(b)(3) 10 requires the party seeking fees to submit “[a] brief description of relevant qualifications and 11 experience and a statement of the customary hourly charges of each such person or of comparable 12 prevailing hourly rates or other indication of value of the services.” 13 Plaintiff contends counsel’s current billing rates for contingency cases are as follows: 14 15 Timekeeper Total Hours Billed Rate1 16 Hovanes Margarian 25.2 $650/$750 17 Armen Margarian 38.6 $550/$670 18 Shushanik Margarian 17.7 $550/$670 19 Patrick Kimball 38 $700.00 20 Elmira Oganyan, Assistant 2.1 $150.00 21 (Dkt. No. 31-2 at 6.) Plaintiff contends courts have approved these rates for attorneys of similar 22 skill and experience and insists the rates are supported by the Adjusted Laffey Matrix. (Dkt. No. 23 31-20 at 16-17.) There are several issues with Plaintiff’s request. 24 First, it is not reasonable to add $100 to each biller’s hourly rate, as Plaintiff does, simply 25 because the case was taken on a contingency basis. See Ketchum v. Moses, 24 Cal. 4th 1122, 1133 26 (2001) (noting the lodestar is calculated using the “hourly prevailing rate for private attorneys in 27 1 the community conducting noncontingent litigation of the same type”). 2 Second, the Laffey Matrix is “an inflation-adjusted grid of hourly rates for lawyers of 3 varying levels of experience in Washington, D.C.” and the Ninth Circuit has explained “just 4 because the Laffey matrix has been accepted in the District of Columbia does not mean that it is a 5 sound basis for determining rates elsewhere, let alone in a legal market 3,000 miles away.” See 6 Prison Legal News v. Schwarzenegger, 608 F.3d 446, 454 (9th Cir. 2010) (discussing Laffey v. 7 Northwest Airlines, Inc., 572 F. Supp. 354, 371-75 (D. D.C. 1983)). 8 Third, although the relevant community for determining a reasonable hourly rate is “the 9 forum in which the district court sits” Plaintiff does not offer any evidence as to the reasonable 10 hourly rates for attorneys in lemon law cases in this District. Camacho v. Bridgeport Fin., Inc., 11 523 F.3d 973, 979 (9th Cir. 2008). Instead, Plaintiff relies on decisions, predominantly from the 12 Los Angeles County Superior Court and the Central District of California, approving counsel’s 13 hourly rates. (Dkt. No. 31-20 at 16-18; Dkt. No. 31-1 at ¶¶ 25-30.) There are, however, numerous 14 decisions from the Central District of California declining to award counsel their requested rates. 15 See, e.g., Danielyan v. Mercedes-Benz USA LLC, No. CV 24-2918 FMO (MAAX), 2025 WL 16 2019933, at *2 (C.D. Cal. June 18, 2025) (“Given the routine nature of this action, coupled with 17 the fact that Margarian charges paying clients $550 an hour, the court finds that $550 is a 18 reasonable hourly rate”); Kumuryan v. Mercedes Benz USA LLC, No. 8:24-CV-00367-DOC-KES, 19 2024 WL 5369425, at *3 (C.D. Cal. Nov.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Prison Legal News v. Schwarzenegger
608 F.3d 446 (Ninth Circuit, 2010)
PLCM Group, Inc. v. Drexler
997 P.2d 511 (California Supreme Court, 2000)
Moreno v. City of Sacramento
534 F.3d 1106 (Ninth Circuit, 2008)
Nadarajah v. Holder
569 F.3d 906 (Ninth Circuit, 2009)
Riordan v. State Farm Mutual Automobile Insurance
589 F.3d 999 (Ninth Circuit, 2009)
Camacho v. Bridgeport Financial, Inc.
523 F.3d 973 (Ninth Circuit, 2008)
Robertson v. Fleetwood Travel Trailers of California, Inc.
50 Cal. Rptr. 3d 731 (California Court of Appeal, 2006)
Graciano v. Robinson Ford Sales, Inc.
50 Cal. Rptr. 3d 273 (California Court of Appeal, 2006)
Laffey v. Northwest Airlines, Inc.
572 F. Supp. 354 (District of Columbia, 1983)
In Re Marriage of Bonds
5 P.3d 815 (California Supreme Court, 2000)
Ketchum v. Moses
17 P.3d 735 (California Supreme Court, 2001)
Stanger v. China Electric Motor, Inc.
812 F.3d 734 (Ninth Circuit, 2016)
Wohlgemuth v. Caterpillar Inc.
207 Cal. App. 4th 1252 (California Court of Appeal, 2012)

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Bluebook (online)
Emil James Kohan v. Lucid Group USA, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/emil-james-kohan-v-lucid-group-usa-inc-cand-2025.