1. Compare and contrast Missouri v. Jenkins, 491 U.S. 274, 109 S.Ct. 2463, 105 L.Ed. 2d 229 (1989) and Role Models American, Inc. v. Brownlee, 353 F.3d 962 (C.A.D.C., 2004), which allowed recovery of paralegal fees, with Joerger v. Gordon Food Service, Inc., 224 Mich. App. 167, 568 N.W.2d 365 (Mich.App., June 13, 1997), which did not allow recovery.