No Per Page Charge Is A Mandatory Requirement.
In Moving Oxnard Forward, Inc. v. City of Oxnard, Case No. B338323 (2d Dist., Div. 6 July 14, 2026) (unpublished), City was awarded $26,489.42 in costs under CCP § 1094.5(a) for lawyer and paralegal time in preparing an administrative record even though the costs memorandum was filed 4 days too late. Appellant Moving Oxnard Forward argued that it an abuse of discretion to allow the late filing of the costs memorandum and that the requested costs were excessive. Neither of those arguments was persuasive on appeal. With respect to the late memorandum filing, CRC 3.1700(b)(3) allows the trial court to extend the time for another 30 days in its discretion, with no requirement that a party expressly requests the extension or that the court specifically states that it granted the extension (Cardinal Health 301, Inc. v. Tyco Electronics Corp., 169 Cal.App.4thy 116, 155 (2008))—and the trial court did not abuse its discretion given the memorandum was only filed 4 days late. On the excessiveness contention, given that lawyer and paralegal time for preparing an A/R is recoverable under section 1094.5(a), the time spent was documented well and not excessive in light of the length of the record—with no per page charge limitation being mandatory in nature, even though at least one other court had applied such a limitation in its analysis of the issue. (Contrast Wagner Farms, Inc. v. Modesto Irrigation Dist., 145 Cal.App.4th 765, 775 (2006) [per page charge considered in the analysis] with River Valley Preservation Project v. Metropolitan Transit Development Bd., 37 Cal.App.4th 154, 180-181 (1995) [costs awarded with no mention of a per page charge limitation].)