"\[A] trial court may consider an attorney's pervasive incivility in determining the reasonableness of the requested fees. A court may apply, in its discretion, a positive or negative multiplier to adjust the [[Lodestar|lodestar]] calculation—a reasonable rate times a reasonable number of hours—to account for various factors, including attorney skill. Ketchum v. Moses (2001) 24 Cal.4th 1122, 1131–1134; [[Case Law/K/Karton v. Ari Design & Construction, Inc. (2021) 61 Cal.App.5th 734]], 744–745, 747.] The record before us amply supports the trial court's finding that plaintiff's counsel was repeatedly, and apparently intentionally, uncivil to defense counsel—and to the court—throughout this litigation. We thus find no abuse of discretion and affirm." (Snoeck, at p. 10712.) ![[B321566.PDF]] <!-- citation-library:start --> ## Citation reference Snoeck v. ExakTime Innovations, Inc. (2023) 96 Cal.App.5th 908, 314 Cal.Rptr.3d 569 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end -->