California, United States of America
The following excerpt is from Foster v. Old Republic Default Mgmt. Servs., B280006 (Cal. App. 2018):
A prevailing party is entitled to recover costs in any action or proceeding, "[e]xcept as otherwise expressly provided by statute." (Code Civ. Proc., 1032, subd. (b).) These costs, however, do not include the attorney fees the prevailing party has incurred in the litigation unless (1) an agreement between the parties provides for the recovery of those fees, or (2) a statute creates a right of recovery. (Code Civ. Proc., 1021, 1033.5, subd. (a); Butler-Rupp v. Lourdeaux (2007) 154 Cal.App.4th 918, 923.)
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