Elysian Care Corp. v Lawndale Healthcare
This lawsuit has several distinct components. The first involves voluminous and complex billing issues that arose after plaintiffs sold their skilled nursing facility to defendants; these issues were the subject of a special reference. The trial court eventually adopted the special master’s “Determinations and Findings” in plaintiffs’ favor, but declined to hold any hearings before doing so. The second aspect concerns attorney fees incurred by plaintiffs to ensure a promissory note, personally guaranteed by their principals, did not go into default. Over defendants’ objections the trial court awarded plaintiffs these attorney fees as damages. Postjudgment, plaintiffs were awarded prevailing party attorney fees and costs. For the reasons that follow, we reverse and remand with directions.
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