Is a motion for attorney's fees made after a judgment?

California, United States of America


The following excerpt is from Ultimo v. City Lights Fin. Express Inc., B270329 (Cal. App. 2018):

2. In his statement of appealability (see Cal. Rules of Court, rule 8.204, subd. (a)(2)(B)), Ultimo asserts that the trial court's attorney's fees order is appealable as an "order made after judgment" (Code of Civil Proc., 904.1, subd. (a)(2)). Although "postjudgment orders granting or denying motions for attorney's fees are deemed to be appealable" (Apex LLC v. Korusfood.com (2013) 222 Cal.App.4th 1010, 1015 (Apex)), there is no indication in the record that the trial court ever entered a judgment.

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