Gotta Separately Appeal the Postjudment Order.
Albert v. Baccouche, Case No. B249798 (2d Dist., Div. 5 Sept. 2, 2014) (unpublished) is yet another reminder of what we have harped on in many posts: separately appeal a postjudgment costs/fee order in order to preserve a challenge to the order. Here, litigant hit with some cost-shifting under CCP § 998 failed to appeal the order denying a motion to tax costs. That was fatal, because the absence of an appeal meant the appellate court was without jurisdiction to consider a challenge to the postjudgment order.