That argument does not hold water. It is the abstractor's time expended in the search for which he is paid, and which also is an expense to the employer. The above argument only works if you allow the client to get away with it.

If the employer has the nerve to stand firm in his demand, he will succeed. There is the unconditional written order for the search that establishes the request for service. There is the abstractor's notes and completed abstract which establishes the performance to the requested service. There are the payroll records which establish the employer's expenses. The employer is also entitled to the recovery of his lost profits. I litigate cases like this all the time. Winning is like shooting fish in a barrel.