“In the modern world of legal practice, the delegation of repetitive legal tasks to paralegals has become a necessary fixture. Such delegation has become an integral part of the struggle to keep down the costs of legal representation. Moreover, the delegation of such tasks to specialized, well-educated non-lawyers may well ensure greater accuracy…” (Pincay v. Andrews (2004) 389 F. 3rd 853).

It is well settled that “secretarial and paralegal services” are “necessary support services for attorneys” (Salton Bay Marina, Inc. v. Imperial Irrigation Dist. (1985) 172 Cal. App. 3rd 914; see also Missouri v. Jenkins 491 U.S. 274; Trustees of Const. v. Redland Ins. Co. (9th Cir. 2006) 460 F. 3rd 1253; Otay Ranch, L.P. v. County of San Diego (2014) 230 Cal. App. 4th 60; No Toxic Air, Inc. v. Lehigh Southwest Cement Company (2016) 1 Cal. App. 5th 1136).

It appears to be without dispute that paralegals result in a net cost savings.  It may even be improper for an attorney to complete tasks that would better be assigned to a paralegal.  For example, in Carver v. Chevron U.S.A., Inc. (2002) 97 Cal. App. 4th 132, the trial court properly reduced payment to the attorney because the court found “that some charges could have been reduced had a paralegal performed the tasks…”