Maryland Rules of Civil Procedure|Rule 2-701 - Definitions

In this Chapter, except as otherwise provided or necessary implication requires:

(a) "Attorneys' fees includes related expenses; and

(b) "Related expenses means expenses related to and incurred as part of the provision of legal services, including compensation for the services of paralegals and law clerks.

Md. R. Civ. P. Cir. Ct. 2-701

This Rule is new.

Adopted Oct. 17, 2013, eff. Jan. 1, 2014.

Committee note: In Friolo v. Frankel, 373 Md. 501, 530 (2003), the Court held, for purposes of a claim under the Wage Payment Law, which allowed an award of reasonable "counsel fees, that charges for paralegals and law clerks were subsumed within the attorneys' fees and should not be separately charged as attorneys' fees. It appears that most courts do allow compensation for paralegals and law clerks to be included in a statutory fee-shifting claim. The intent of this Rule is to allow the compensation paid to paralegals and law clerks for work done in connection with a claim permitting the recovery of attorneys' fees to be included as a separately identified related expense. This is intended to reduce the amounts claimed for attorneys' fees by encouraging attorneys to permit lower-paid paralegals and law clerks to perform tasks they properly can perform that otherwise would have to be done by the attorneys and would avoid the anomaly of labeling compensation paid to non-attorneys as attorneys' fees.