What is the test for an order requiring attorney fees in a separate action?
California, United States of America
The following excerpt is from California Licensed Foresters Assn. v. State Bd. of Forestry, 30 Cal.App.4th 562, 35 Cal.Rptr.2d 396 (Cal. App. 1994):
1 An order awarding attorney fees is collateral to the main action and separately appealable. (Henneberque v. City of Culver City (1985) 172 Cal.App.3d 837, 841-842, 218 Cal.Rptr. 704.)
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