All too often, attorneys record time in a haphazard, uninformative fashion. Time entries that simply reflect "research" or "consult with opposing counsel" provide little guidance as to what was actually accomplished. Consequently, the Arizona courts have roundly criticized vague, general time entries. Time should be recorded in sufficient detail so the work performed or task accomplished is clearly described and identified. The key is whether the description will assist the court in assessing and evaluating the reasonableness of the work performed and time expended. See Fuddrucker's, Inc. v. Doc's B.R. Others, Inc., 623 F. Supp. 21, 24 (D. Ariz. 1985). Keep in mind the fee claimant bears the burden of submitting evidence that would allow the court to determine a reasonable fee award.
Because it may ultimately be necessary to substantiate the fees claimed, Arizona courts have encouraged, although not required, the parties to maintain contemporaneous time records. Geller v. Lesk, 230 Ariz. 624, 629, ¶ 14, 285 P.3d 972, 977 (App. 2012) ("When dealing with a contingency agreement, the prevailing way to show reasonableness is through...
