Electronic legal research would be awarded as a separate fee since use of online research services likely reduces the number of hours required for an attorney’s manual search, thereby lowering the lodestar. Am. Canoe Ass’n, Inc. v. City of Louisa, 2010 WL 399110 (E.D. Ky. Jan. 27, 2010) Suggested by Howard Solender, West Principal Attorney Editor
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Electronic legal research would be awarded as a separate fee since use of online research services likely reduces the number of hours required for an attorney’s manual search, thereby lowering the lodestar.
