A practical roadmap for building a fee-ready trial record, prevailing on fee motions, and using motions in limine and closing argument to support entitlement, lodestar and enhancements.
In many civil cases, the attorneys’ fee motion is the real “damages phase.” Courts scrutinize entitlement, reasonableness, billing judgment, and the link between results obtained and the hours claimed. Yet fee outcomes are often decided long before judgment, based on how counsel builds the record during motion practice, evidentiary rulings, and trial presentation.
This program focuses on the mechanics of winning fee motions in U.S. civil litigation, with particular attention to how motions in limine and closing argument shape the record that supports fees. We will address the procedural pathways for seeking fees, evidentiary foundations for time and rate proof, opposition playbooks, and the common reasons courts cut or deny fee requests.
The session also connects fee strategy to judicial review matters, including writ practice and agency challenges, where the record, standard of review, and issue framing can determine whether fee recovery is available and defensible. The approach is courtroom-driven and designed for litigators who want repeatable tools rather than abstract standards.
Lead Trial Attorney at Thigpen Legal, P.C.
Jordanna Thigpen is the lead trial attorney at Thigpen Legal in Beverly Hills, California, where she prosecutes civil disputes including intellectual property litigation, business litigation, entertainment industry disputes, real estate disputes, and labor and employment disputes. A skilled litigator with 16 years of experience, Ms. Thigpen is dedicated to helping her clients resolve issues permanently with pragmatic solutions. When litigation is necessary, she is a fearless advocate in the courtroom. She is adept at resolving complex and difficult disputes, especially those involving unique issues in civil litigation. Over the course of her career, Ms. Thigpen has been involved in several major cases that have set legal precedents and resulted in millions of dollars in verdicts and settlements on behalf of her clients. In 2013, one of her cases in the Central District of California resulted in the then-largest recovery against an indenture trustee in the nation’s history ($219 million). In February 2020, she achieved the largest standing right of publicity verdict in history, with a total judgment of nearly $17 million. After earning a bachelor’s degree in history from the University of California, Davis, Ms. Thigpen graduated from the University of San Francisco School of Law. She began her legal career by clerking for Hon. Ronald E. Quidachay (Ret.) in the San Francisco Superior Court's Law & Motion Department. From there, she served in several prominent roles for the City and County of San Francisco, including as executive director of the San Francisco Taxi Commission, and as a Commissioner for the San Francisco Small Business Commission. Since 2009, she has been in private practice as a trial attorney, including work at notable litigation firm Cotchett, Pitre & McCarthy, where she worked alongside one of the greatest trial attorneys of all time, Joe Cotchett. Ms. Thigpen is also a former successful small business owner, having operated and eventually selling a small business that she built while attending law school full time. Ms. Thigpen belongs to the Consumer Attorneys Association of Los Angeles. She is currently serving a two-year term as an Executive Committee Member for the California Lawyers Association's Litigation Section, where she advocates for legislation to enhance the profession and practice of law for the public's benefit. She is licensed in California, New York, and the District of Columbia.
