California, United States of America
The following excerpt is from Colachis v. Salazar, B205057 (Cal. App. 2/3/2009), B205057 (Cal. App. 2009):
Appellant also contends that the trial court erred in not allowing an offset to the amount of attorney fees awarded to respondents. But appellant's failure to appeal from the postjudgment order granting respondents' motion for attorney fees has deprived us of jurisdiction to consider this issue. "`An appellate court has no jurisdiction to review an award of attorney fees made after entry of the judgment, unless the order is separately appealed.' [Citation.] `"[W]here several judgments and/or orders occurring close in time are separately appealable (e.g., judgment and order awarding attorney fees), each appealable judgment and order must be expressly specifiedin either a single notice of appeal or multiple notices of appealin order to be reviewable on appeal."'" (Colony Hill v. Ghamaty (2006) 143 Cal.App.4th 1156, 1171.)
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