California, United States of America
The following excerpt is from LA Open Door Presbyterian Church v. Evangelical Christian Credit Union, B246853 (Cal. App. 2013):
A defendant who seeks recovery of costs need not file a proposed judgment after a plaintiff's voluntary dismissal. (Fries v. Rite Aid Corp. (2009) 173 Cal.App.4th 182, 183.) But the defendant, if it chooses, may submit a proposed judgment following a voluntary dismissal, and the trial court may properly enter such a judgment. (See id. at pp. 186-187; Boonyarit v. Payless Shoesource, Inc. (2006) 145 Cal.App.4th 1188, 1192-1194.)
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