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The application of the doctrine of unfinished business to matters billed on an hourly basis1 continues to generate interesting and sometimes controversial case law. Two cases this year from California, the proverbial home of unfinished business law, further elucidate the scope of liability for unfinished business claims as well as the procedure used in unfinished business cases, which often arise in the bankruptcy context. While these recent decisions evidence California’s embrace of the application of unfinished business to law firms that bill on an hourly basis, in New York, we await the result of the certification of two conflicting decisions regarding unfinished business in the hourly billing context.

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