29.17 Allocation of Attorneys' Fees Among Separate Counsel

• Jurisdiction: Arizona

29.17 Allocation of Attorneys’ Fees Among Separate Counsel. In the appropriate case, the common fund doctrine can apply to the distribution of attorneys’ fees between different counsel representing different beneficiaries in a wrongful death claim.¹⁰⁹ But in the only Arizona case to consider the issue, the Court of Appeals declined to apply the doctrine because, in that case, the attorneys opposing application of the doctrine had not actively participated in proving damages and the determination of the...