Variations of attorney's fees
How many variations of "attorney's fees" do you see? Four different variations, according to the Illinois Bill Drafting Manual of the Legislative Reference Bureau and Bryan A. Garner. Attorney's fees, attorneys' fees, attorney fees, and attorneys fees all appear in the Illinois Compiled Statutes.(Manual, page 282) Both Garner and the Manual agree on recommended usage. (1) "Attorney's fees" appears most frequently in the Illinois statutes, and Garner agrees that it is the most prevalent. (A Dictionary of Modern Legal Usage) (2) "Attorneys' fees" is fine for plural possessive (more than one attorney). (3) "Attorney fees" is not recommended by either but is used frequently. (4) "Attorneys fees" is not to be used at all.
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