Also, Appellant’s Apportionment Argument Based On Relative Successes Had No Factual Analysis, So It Was Rejected.
In Mileck v. Mileck, Case No. A170748 (1st Dist., Div. 3 Mar. 27, 2026) (unpublished), appellant/non-prevailing party filed a motion to tax costs against the prevailing party, with the lower court only taxing $520 out a requested $29,238.98 in costs. On appeal, appellant argued that the costs memorandum was untimely filed, but that challenge failed because the prevailing party did file timely when the judgment on retrial was entered (given that the new trial grant did reset the deadlines, keyed to the judgment after retrial). Appellant also argued that costs had to be apportioned for relative successes (because he and a noninvolved party were successful on a quiet title cross-claim), but the lack of factual development of the relative successes and description of the amounts to be apportioned resulted in a forfeiture of the argument.