Costs: Costs Request Filed Before Judicial Referee Properly Preserved The Issue, Even Though No Costs Memorandum Filed With Superior Court

Parties’ Choice Of Judicial Reference Prevailed.

           In Fitness International, LLC v. Monterey Property Associates Anaheim, LLC, Case No. D071910 (4^th Dist., Div. 1 July 25, 2018) (unpublished), the appellate court sustained a determination that the parties’ judicial reference stipulation was broad such that it allowed a costs request to be filed before the referee, dispending with the need to file a separate costs memorandum at the superior court level by the prevailing party. (Code Civ. Proc., § 664(a).)