Fee petition mechanics · Updated July 2026
California FEHA Fair Housing Act attorney fee petition mechanics: date of discriminatory housing practice as primary Welch anchor, Gov. Code § 12955 attorney fees — § 12965(b) Christiansburg strong-plaintiff-presumption framework; Ketchum/Dague split when FHA concurrent; THE ONLY fee-petition-mechanics page where the primary defendant is a residential landlord or property management company in a housing discrimination context
California Fair Employment and Housing Act housing discrimination enforcement (Gov. Code § 12955 — enacted 1980, continuously amended; § 12955(a): it shall be unlawful for the owner of any housing accommodation to discriminate against or harass any person because of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, or genetic information; § 12955(c): it shall be unlawful to discriminate against any person who opposed any practice forbidden under this part; § 12955(f): it shall be unlawful to deny, restrict, or condition the use or enjoyment of any housing accommodation because of any listed protected characteristic; § 12955 is enforced through § 12987 civil action and the § 12965(b) FEHA attorney fees framework — 'in actions brought under this part, the court, in its discretion, may award to the prevailing party... reasonable attorney's fees and costs, except that a prevailing defendant shall not be awarded fees and costs unless the court finds the action was frivolous, unreasonable, or without foundation' — Christiansburg Garment Co. v. EEOC (1978) 434 U.S. 412 strong plaintiff presumption; the ONLY fee-petition-mechanics page where the primary defendant is a RESIDENTIAL LANDLORD, PROPERTY MANAGER, or HOMEOWNERS ASSOCIATION in a HOUSING DISCRIMINATION context; the DATE OF DISCRIMINATORY HOUSING PRACTICE is the primary Welch anchor — in the PROPERTY MANAGEMENT COMPANY'S OWN RESIDENTIAL LEASING MANAGEMENT AND APPLICANT TRACKING SYSTEM CALENDAR DATE [Yardi Voyager Residential, AppFolio Property Management, RealPage OneSite Residential, Entrata, MRI Software Residential, Buildium, ResMan, DoorLoop — each records the rental application date, application screening outcome, adverse action notice date, and lease offer or denial date on the property manager's own institutional calendar entirely outside plaintiff attorney's scheduling control]; the Fair Housing Act 42 U.S.C. § 3601 et seq. is a concurrent federal cause of action: § 3613(c)(2) mandatory attorney fees to the prevailing party — federal FHA hours subject to City of Burlington v. Dague (1992) 505 U.S. 557 no-positive-contingency-multiplier under 42 U.S.C. § 1988(b); California § 12955 FEHA-only hours subject to pure Ketchum positive multiplier — Hensley task-level segregation required for the Ketchum/Dague split; DISTINCT from Unruh Civil Rights Act § 51 [§ 51 prohibits discrimination in public accommodations — restaurants, retail, hotels — not housing; § 12955 specifically governs residential housing sales, rental, and terms of tenancy]; DISTINCT from FEHA employment discrimination § 12940 [§ 12940 governs the employer-employee relationship; § 12955 governs the housing provider-tenant relationship — entirely different defendant class]; DISTINCT from § 51.3 [senior citizen housing exemption; § 51.3 governs age-restricted senior housing under the Housing for Older Persons Act]; Ketchum v. Moses 24 Cal.4th 1122 (2001); PLCM Group Inc. v. Drexler 22 Cal.4th 1084 (2000); Hensley v. Eckerhart 461 U.S. 424 (1983) lodestar from DATE OF DISCRIMINATORY HOUSING PRACTICE; Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees) — solos billing hourly on attorney fee recovery — in actions where the primary Welch temporal anchor is the DATE OF DISCRIMINATORY HOUSING PRACTICE (in the PROPERTY MANAGEMENT COMPANY'S OWN RESIDENTIAL LEASING MANAGEMENT AND APPLICANT TRACKING SYSTEM: Yardi Voyager Residential/AppFolio/RealPage OneSite/Entrata/MRI Software/Buildium/ResMan/DoorLoop — rental application date, screening outcome, adverse action notice date, lease denial date entirely outside plaintiff attorney's scheduling control; § 12965(b) Christiansburg strong-plaintiff-presumption attorney fee framework; HUD FHEO complaint investigation calendar as second institutional calendar; CRD FEHA housing complaint calendar as third; Ketchum/Dague split when FHA 42 U.S.C. § 3613(c)(2) concurrent; DISTINCT from Unruh § 51 [public accommodation]; DISTINCT from § 12940 employment) — generate three billing gaps driven by § 12955 housing discrimination eligibility and adverse action documentation advisory calls, the concurrent property management leasing system calendar and HUD FHEO investigation calendar and CRD FEHA housing complaint calendar advisory calls on external institutional calendars entirely outside attorney control, and the § 12965(b) attorney fee petition and Ketchum/Dague split advisory calls: § 12955 housing discrimination eligibility and adverse action documentation advisory calls (7 clients × 2 calls × 42 min × 55% untracked ≈ 5.39 hrs = $1,617–$2,695/year at $300–$500/hr), property management leasing system calendar advisory and HUD FHEO investigation calendar advisory and CRD FEHA housing complaint calendar advisory (6 clients × 3 calls × 44 min × 55% ≈ 7.26 hrs = $2,178–$3,630/year), and § 12965(b) attorney fee petition and Ketchum/Dague split analysis advisory calls (5 clients × 2 calls × 44 min × 55% ≈ 4.03 hrs = $1,210–$2,017/year). For a solo California § 12955 FEHA housing discrimination practice, the annual billing gap from advisory call underlogging is $5,005–$8,342.
TL;DR
ClaimHour captures every § 12955 housing discrimination eligibility and adverse action documentation advisory call that starts the § 12965(b) fee documentation period from the DATE OF DISCRIMINATORY HOUSING PRACTICE (in the PROPERTY MANAGEMENT COMPANY'S OWN RESIDENTIAL LEASING MANAGEMENT AND APPLICANT TRACKING SYSTEM: Yardi Voyager Residential/AppFolio/RealPage OneSite/Entrata/MRI Software/Buildium/ResMan/DoorLoop — rental application date, screening outcome, adverse action notice, lease denial date entirely outside plaintiff attorney's scheduling control; § 12965(b) Christiansburg strong-plaintiff-presumption attorney fee framework; ONLY fee-petition-mechanics page where primary defendant is a residential landlord or property manager in a housing discrimination context; Ketchum/Dague split: FHA § 3613(c)(2) hours Dague-constrained, California § 12955-only hours pure Ketchum; DISTINCT from Unruh § 51 [public accommodation] and § 12940 [employment]), every concurrent property management leasing system calendar advisory and HUD FHEO investigation calendar advisory and CRD FEHA housing complaint calendar advisory call on external institutional calendars entirely outside attorney control, and every § 12965(b) attorney fee petition and Ketchum/Dague split analysis advisory call on the post-judgment fee petition calendar — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.
§ 12955 housing discrimination eligibility and adverse action documentation: calls on the property management company's institutional leasing calendar
The DATE OF DISCRIMINATORY HOUSING PRACTICE is the primary Welch temporal anchor for § 12955 FEHA housing attorney fee billing documentation. This date is in the PROPERTY MANAGEMENT COMPANY'S OWN RESIDENTIAL LEASING MANAGEMENT AND APPLICANT TRACKING SYSTEM CALENDAR DATE. The Hensley lodestar starts from this date for five reasons: (1) Yardi Voyager Residential, AppFolio Property Management, RealPage OneSite Residential, Entrata, MRI Software Residential, Buildium, ResMan, and DoorLoop each record the rental application receipt date, application screening completion date, adverse action decision date, and lease denial or withdrawal date on the property manager's own institutional leasing calendar entirely outside plaintiff attorney's scheduling control; (2) the application screening date appears simultaneously in two system sub-modules: the applicant tracking module (recording application receipt, document submission deadlines, and screening initiation on the property manager's leasing calendar) and the credit/background screening integration (recording the consumer report authorization date, screening completion date, and score/decision on the tenant screening service's calendar — TransUnion SmartMove, RealPage LeasingDesk, AppFolio Screening, CoreLogic SafeRent, Entrata ID Verify — each on the screening provider's own institutional calendar); (3) the Adverse Action Notice required by the Fair Credit Reporting Act 15 U.S.C. § 1681m is generated on the property manager's leasing system calendar: if the housing denial was based in whole or part on information in a consumer report, the FCRA adverse action notice date is on the property manager's institutional leasing system calendar — creating a concurrent FCRA § 1681m claim with its own calendar; (4) the source of income discrimination anchor is unique: if the housing denial is based on the applicant's use of a Section 8 Housing Choice Voucher (HCV), the Housing Authority's voucher issuance date (on the Housing Authority's own institutional calendar — KOFAX/Tyler Technologies/Emphasys Elite HCV management system) establishes the date the applicant held a valid voucher — which is entirely outside both the plaintiff attorney's and property manager's scheduling control; (5) the habitability denial date is in the property manager's work order system: if the § 12955 claim involves discriminatory refusal to make repairs for a person with a disability (reasonable accommodation claim), the property manager's work order submission date and refusal date are on the property manager's maintenance management calendar (Yardi Voyager Maintenance, AppFolio Maintenance, MRI Software Work Orders, BuildingLink, FixingMatters).
Three initial advisory call types generate untracked billing from the adverse action date: (1) § 12955 housing discrimination eligibility and protected class analysis advisory — arrives when tenant retains counsel for housing discrimination (eligibility analysis: [a] confirm the covered housing accommodation under § 12927: the unit must qualify as a "housing accommodation" — single family homes, apartments, condominiums, mobile homes, and HOA units are covered; temporary lodging (hotels, motels, tourist camps) may be partially exempt; [b] confirm the protected characteristic: race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, or genetic information under § 12955(a) — document which protected characteristic applies and how the discriminatory conduct was linked to that characteristic; [c] confirm the adverse housing action: rental application denial, lease termination, discriminatory rental terms, refusal of reasonable accommodation, failure to provide accessible features, discriminatory advertising (§ 12955(c)), or harassment of a person exercising § 12955 rights; [d] assess the source of income discrimination issue: California's § 12955(p) extends protection to "source of income" — landlords who refuse Section 8/HCV vouchers face § 12955 liability regardless of whether the tenant's race or national origin was also a factor; [e] assess the familial status claim: § 12955 prohibits discrimination based on familial status — families with children under 18; this includes both the actual presence of children and pregnancy; the FHA familial status exemption for senior housing communities under 42 U.S.C. § 3607 must be verified in any case involving a senior housing development; 42–48 min per call); (2) § 12955 disability reasonable accommodation and reasonable modification analysis advisory — arrives when disability claim involves a physical accommodation or modification (reasonable accommodation analysis: [a] confirm the disability under § 12926 and 42 U.S.C. § 3602(h): the disability must be a physical or mental impairment that substantially limits one or more major life activities; [b] confirm the reasonable accommodation request was made in writing or verbally: the property manager's response date to the accommodation request is on the property manager's leasing calendar — a failure to respond within a reasonable time (typically 10 business days under HUD guidance) is itself a § 12955 violation; [c] assess the reasonableness standard: the accommodation must be reasonable — it does not require the housing provider to make fundamental alterations or incur undue hardship; [d] confirm the interactive process: § 12955 requires the housing provider to engage in an interactive process with the applicant or tenant to identify and implement a reasonable accommodation — the interactive process dates are on the property manager's correspondence calendar; [e] assess the service animal and assistance animal documentation issue: a landlord may only request documentation of disability-related need for an assistance animal if the disability is not apparent — the documentation request date and response deadline are on the property manager's institutional calendar; 42–48 min per call); (3) § 12955 vs. Unruh Act and FHA concurrent claim analysis advisory — arrives before filing (strategic analysis: [a] assess whether a concurrent Unruh Act § 51 claim is available: Unruh Act § 51 covers public accommodations; housing providers are generally covered under § 12955 FEHA rather than § 51 Unruh — but some California courts have found that landlords who operate housing as a business accessible to the public may also be subject to § 51 analysis; [b] assess the FHA 42 U.S.C. § 3604 concurrent claim: FHA § 3604(a) prohibits refusing to sell or rent a dwelling because of race, color, national origin, religion, sex, familial status, or handicap; FHA § 3613(c)(2) allows reasonable attorney fees to a prevailing party — but FHA hours are Dague-constrained, California § 12955 FEHA hours are pure Ketchum; Hensley task-level segregation is required to maximize the fee petition; [c] assess the FEHA Right-to-Sue notice requirement: the plaintiff must exhaust CRD administrative remedies and obtain a Right-to-Sue notice before filing a civil action; the Right-to-Sue issuance date starts the 1-year civil action filing deadline; [d] assess the HUD election: a complainant who files a HUD § 3610 complaint may elect to pursue a civil action in federal court under § 3613 instead of the HUD administrative process — the HUD election date is on HUD's institutional calendar; 42–48 min per call). At 55% untracked: 7 clients × 2 calls × 42 min × 55% = 323.4 min / 60 = 5.39 hours = $1,617–$2,695/year at $300–$500/hr.
Property management leasing system calendar and HUD FHEO investigation calendar and CRD FEHA housing complaint calendar: calls on three institutional calendars entirely outside attorney control
A California Gov. Code § 12955 FEHA housing discrimination case involves three concurrent external institutional calendars entirely outside the plaintiff attorney's scheduling control: the property management company's own residential leasing management and applicant tracking system calendar [Yardi Voyager Residential, AppFolio Property Management, RealPage OneSite Residential, Entrata, MRI Software Residential, Buildium, ResMan, DoorLoop each record: (a) the rental application receipt date (the date the applicant submitted a completed rental application through the property manager's online portal — on the property manager's institutional leasing calendar); (b) the application screening completion date (the date the property manager's leasing system received back the completed tenant screening report from the screening provider — TransUnion SmartMove, RealPage LeasingDesk, AppFolio Screening, CoreLogic SafeRent, Entrata ID Verify — on the property manager's institutional leasing calendar); (c) the adverse action decision date (the date the property manager's leasing system recorded the application denial decision — on the property manager's institutional leasing calendar); (d) the adverse action notice date (the date the property manager generated and sent the Adverse Action Notice under FCRA § 1681m — on the property manager's institutional leasing calendar); (e) the reasonable accommodation request receipt date and response date (the date the property manager's system recorded receipt of a disability accommodation request and the response — on the property manager's institutional correspondence calendar); (f) the lease termination notice date (if the § 12955 claim involves discriminatory lease termination, the notice date is on the property manager's institutional leasing calendar)]; the U.S. Department of Housing and Urban Development Fair Housing and Equal Opportunity (HUD FHEO) administrative complaint investigation calendar [if the complainant filed a HUD § 3610 administrative complaint before filing a civil action: (a) HUD FHEO complaint intake date (the date HUD received and docketed the complaint — on HUD FHEO's own case management system calendar entirely outside plaintiff attorney's scheduling control); (b) HUD FHEO investigation initiation date (the date HUD assigned an investigator and initiated investigation — on HUD FHEO institutional calendar); (c) HUD FHEO cause/no cause determination date (the date HUD issued its Letter of Findings determining whether reasonable cause exists to believe that a discriminatory housing practice occurred — on HUD FHEO institutional calendar); (d) HUD election date (the date the complainant elected under § 3612(a) to have a charge of discrimination heard before an administrative law judge or to bring a civil action in federal court — on HUD FHEO institutional calendar); (e) HUD conciliation agreement date (if HUD attempts to negotiate a conciliation agreement, the conciliation conference date is on HUD FHEO institutional calendar)]; and the California Civil Rights Department (CRD) FEHA housing complaint investigation calendar [(a) CRD complaint intake date (the date CRD received the § 12955 FEHA housing complaint — on CRD's institutional complaint management calendar entirely outside plaintiff attorney's scheduling control); (b) Right-to-Sue notice issuance date (the date CRD issued the Right-to-Sue notice — starts the 1-year civil action filing deadline under § 12965(f)(1) — on CRD's institutional calendar); (c) CRD dual-filing coordination date (if the case is dual-filed with HUD under the FEPA/FEHC worksharing agreement, the CRD-HUD referral date is on both agencies' institutional calendars); (d) CRD mediation scheduling date (if CRD's dispute resolution division schedules a mediation, the mediation date is on CRD's institutional calendar); (e) CRD investigation completion date (if CRD investigates the complaint, the investigation completion date is on CRD's institutional calendar)]. Ketchum v. Moses 24 Cal.4th 1122 (2001). PLCM Group 22 Cal.4th 1084 (2000). Hensley v. Eckerhart 461 U.S. 424 (1983). Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees.
Three concurrent external institutional calendar advisory call types generate untracked billing: (1) property management leasing system calendar monitoring advisory — arrives when leasing system records are needed for discriminatory practice documentation (leasing system calendar analysis: [a] request the property manager's leasing system application records: the application receipt date, screening completion date, adverse action decision date, and adverse action notice date in Yardi/AppFolio/RealPage/Entrata establish the temporal sequence of the § 12955 violation; [b] request the tenant screening report from the screening provider: the credit/background check authorization date, screening initiation date, and adverse information identification date in TransUnion SmartMove/RealPage LeasingDesk/AppFolio Screening are on the screening provider's institutional calendar — entirely outside both the applicant's and plaintiff attorney's scheduling control; [c] identify the FCRA adverse action notice compliance: if the property manager generated an FCRA adverse action notice, the notice date on the property manager's leasing calendar creates a concurrent FCRA § 1681m claim; [d] identify the source of income documentation in the leasing system: if the § 12955 claim involves refusal of a Section 8/HCV voucher, the housing authority's voucher issuance date, voucher expiration date, and property manager's acknowledgment date in the leasing system are all on institutional calendars; 44–50 min per call); (2) HUD FHEO investigation calendar monitoring advisory — arrives when HUD administrative timeline affects the civil action strategy (HUD calendar analysis: [a] monitor the HUD cause/no cause determination date: if HUD issues a Letter of Findings finding no reasonable cause, the determination date starts the civil action statute of limitations clock; [b] monitor the HUD election deadline: once HUD issues a charge of discrimination under § 3612, the complainant has 20 days to elect a civil action in federal district court — this election date is a critical deadline on HUD FHEO's institutional calendar; [c] assess HUD/state coordination: if both HUD and CRD have active complaints, the worksharing agreement between HUD and California under the Fair Employment Practices Agency (FEPA) agreement determines which agency has primary jurisdiction and which will defer — the jurisdictional determination date is on both agencies' institutional calendars; [d] assess concurrent FHA § 3614 DOJ pattern-or-practice investigation: if HUD refers the case to DOJ for pattern-or-practice investigation, the DOJ investigation initiation date is on DOJ's institutional calendar — a concurrent DOJ investigation affects the fee petition strategy because DOJ pattern-or-practice cases may create collateral estoppel on liability; 44–50 min per call); (3) CRD FEHA housing complaint calendar monitoring advisory — arrives when CRD administrative calendar controls civil action timeline (CRD calendar analysis: [a] monitor the Right-to-Sue notice issuance date: the Right-to-Sue issuance date on CRD's institutional calendar starts the 1-year civil action filing deadline under § 12965(f)(1); [b] monitor CRD mediation: if CRD schedules a mediation, the mediation date is a critical external calendar date — pre-mediation advisory calls and post-mediation assessment calls are generated on CRD's institutional calendar; [c] assess concurrent EEOC dual-filing if the discrimination is employment-related alongside housing: if the same defendant employs the plaintiff in a different context, a concurrent FEHA § 12940 employment claim creates a second institutional calendar (employer HRIS) alongside the property management leasing calendar; [d] assess Gov. Code § 12989.1 administrative enforcement: CRD may initiate its own § 12989.1 investigation of systemic § 12955 violations — a CRD administrative investigation date is on CRD's institutional calendar and may create collateral estoppel on liability in the plaintiff's civil action; 44–50 min per call). At 55% untracked: 6 clients × 3 calls × 44 min × 55% = 435.6 min / 60 = 7.26 hours = $2,178–$3,630/year at $300–$500/hr.
§ 12965(b) attorney fee petition and Ketchum/Dague split analysis: calls on the post-judgment fee petition calendar
Fee recovery for § 12955 FEHA housing discrimination is through Gov. Code § 12965(b): 'in actions brought under this part, the court, in its discretion, may award to the prevailing party, including the department, reasonable attorney's fees and costs, except that, notwithstanding Section 998 of the Code of Civil Procedure, a prevailing defendant shall not be awarded fees and costs unless the court finds the action was frivolous, unreasonable, or without foundation.' Under Christiansburg Garment Co. v. EEOC (1978) 434 U.S. 412, prevailing plaintiffs are presumed entitled to fees and the presumption is overcome only in extraordinary circumstances. The § 12965(b) fee petition requires a Hensley lodestar from the DATE OF DISCRIMINATORY HOUSING PRACTICE through § 12955 eligibility analysis, protected class documentation, property management leasing system calendar monitoring, HUD FHEO and CRD administrative processing, litigation, and fee petition. When the FHA 42 U.S.C. § 3613(c)(2) is concurrently alleged, the fee petition requires Hensley task-level segregation: federal FHA hours are Dague-constrained (no positive contingency multiplier); California § 12955 FEHA-only hours are subject to pure Ketchum positive multiplier. Ketchum v. Moses 24 Cal.4th 1122 (2001). PLCM Group 22 Cal.4th 1084 (2000). Hensley 461 U.S. 424 (1983). Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees.
Two § 12965(b) post-judgment advisory call types generate untracked billing: (1) § 12955 damages and § 12965(b) fee petition component assembly advisory — arrives at judgment (damages and fee components: [a] out-of-pocket losses: application fees paid, security deposits forfeited if the tenant was constructively displaced, moving costs, increased rent at comparable units — all documented from the property manager's institutional leasing calendar and the tenant's financial records; [b] emotional distress damages: housing discrimination causes particularly severe emotional distress — the discriminatory denial affects not just housing but stability, family safety, and community belonging; [c] punitive damages under Gov. Code § 3294: if the housing provider's discrimination was malicious, oppressive, or fraudulent, punitive damages are available — the property manager's training records and prior discrimination complaints (on the property manager's institutional records management calendar) establish the willfulness element; [d] § 12965(b) fee petition lodestar: from the adverse action date through all § 12955/FEHA housing work and fee petition, including CRD administrative hours; [e] Missouri v. Jenkins fees-on-fees: attorney fees for preparing the § 12965(b) fee petition are themselves recoverable; 44–50 min per call); (2) Ketchum/Dague split analysis advisory — arrives at fee petition (split analysis: [a] identify all hours worked on FHA federal claims exclusively: any hours spent on FHA § 3604, § 3605, or § 3617 claims that are not also addressed by California § 12955 must be segregated as FHA-only hours — these hours are Dague-constrained and cannot receive a positive contingency multiplier; [b] identify § 12955 California FEHA-only hours: any hours worked on California-specific § 12955 protected characteristics that have no FHA equivalent (source of income, marital status, gender identity, gender expression under California law) are pure § 12955 hours — subject to pure Ketchum positive multiplier with no Dague constraint; [c] identify shared hours: hours spent on claims that overlap between FHA and § 12955 (race, color, religion, sex, national origin, familial status, disability) require Hensley proportional allocation between Dague-constrained FHA hours and pure Ketchum California hours; [d] apply the five Ketchum multiplier factors to the § 12955-only hours: (i) source of income discrimination uncertainty (Section 8 voucher refusal cases involve factual uncertainty about the property manager's stated reasons for denial); (ii) disability reasonable accommodation scope uncertainty (the reasonable accommodation obligation's limits were uncertain at case inception); (iii) disparate impact vs. disparate treatment uncertainty (whether the § 12955 claim requires proof of discriminatory intent or only a discriminatory policy's effect was uncertain); (iv) property manager's source of income policy documentation availability uncertainty; (v) tenant screening service's adverse information reliability uncertainty; 44–50 min per call). At 55% untracked: 5 clients × 2 calls × 44 min × 55% = 242 min / 60 = 4.03 hours = $1,210–$2,017/year at $300–$500/hr.
How ClaimHour fits California § 12955 FEHA housing discrimination practice
California FEHA housing discrimination Gov. Code § 12955 solos billing hourly on attorney fee recovery — with § 12955 housing discrimination eligibility and adverse action documentation advisory calls arriving when tenant retains counsel for discriminatory rental denial (DATE OF DISCRIMINATORY HOUSING PRACTICE = primary Welch anchor; in the PROPERTY MANAGEMENT COMPANY'S OWN RESIDENTIAL LEASING MANAGEMENT AND APPLICANT TRACKING SYSTEM CALENDAR DATE: Yardi Voyager Residential/AppFolio/RealPage OneSite/Entrata/MRI Software/Buildium/ResMan/DoorLoop — rental application date, screening outcome, adverse action notice, lease denial date entirely outside plaintiff attorney's scheduling control; § 12965(b) Christiansburg strong-plaintiff-presumption attorney fee framework; ONLY fee-petition-mechanics page where primary defendant is a residential landlord or property manager in a housing discrimination context; Ketchum/Dague split when FHA § 3613(c)(2) concurrent; DISTINCT from Unruh § 51 [public accommodation] and from employment FEHA § 12940 [employer-employee relationship]), property management leasing system calendar monitoring advisory calls on the property manager's own institutional leasing calendar entirely outside plaintiff attorney's scheduling control, HUD FHEO investigation calendar monitoring advisory calls on HUD's own institutional calendar entirely outside plaintiff attorney's scheduling control, CRD FEHA housing complaint investigation calendar monitoring advisory calls on CRD's own institutional calendar entirely outside plaintiff attorney's scheduling control, and § 12965(b) attorney fee petition and Ketchum/Dague split analysis advisory calls arriving at judgment — and if your § 12965(b) FEHA lodestar documentation must satisfy the Hensley contemporaneous-record standard with Ketchum/Dague split analysis from the DATE OF DISCRIMINATORY HOUSING PRACTICE through leasing system monitoring, HUD/CRD administrative processing, litigation, and fee petition, ClaimHour was built for that gap.