Under Penal Code section 1202.4, subdivision (f)(3)(H), actual and reasonable attorney fees incurred by a victim as a result of the defendants criminal conduct are recoverable as restitution, but they are limited to reasonable attorney fees incurred to collect restitution otherwise permitted under the statute. It was also permissible to include the $25,000 attorney fees even though some portion of it was incurred to recover non-economic losses, where there was no basis for apportionment between economic and non-economic losses for attorneys fees incurred.
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