Is prejudgment interest included in a judgment for damages as a result of a motion for a new trial?

There is no reason to depart from the timing rule articulated in North Oakland, supra, 65 Cal.App.4th 824. As noted by the court in North Oakland, prejudgment interest is viewed as "in the element of damages." (Lineman v. Schmid, supra, 32 Cal.2d at p. 209.) As such, logically it should be included in the judgment as part of any damage award, either prior to the entry of the judgment or pursuant to a ruling on a motion for new trial. Plaintiff asserts that the rule in North Oakland is impractical because of the difficulty in having a motion heard prior to the filing of a judgment. But under North Oakland, plaintiff could have brought his motion even after entry of judgment, so long as it was within the time allowed for filing a motion for new trial.