California, United States of America
The following excerpt is from Kertesz v. Ostrovsky, 115 Cal.App.4th 369, 8 Cal.Rptr.3d 907 (Cal. App. 2004):
Here, the judgment was entered on January 8, 1991. The statute of limitations for an action on a judgment does not accrue until the judgment is final. The judgment is not final until the time within which to appeal the judgment has expired. (Turner v. Donovan (1942) 52 Cal.App.2d 236, 238, 126 P.2d 187.) Because no notice of entry of judgment was filed, the time to appeal was on or before 180 days after entry of judgment. (Cal. Rules of Court,
[8 Cal.Rptr.3d 911]
rule 2(a)(3).) One hundred eighty days after January 8, 1991, was July 7, 1991.
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