The Costs Memo Filing 10 Days Past The 15-Day Deadline Was No Problem, Given That The 15-Day Deadline Did Not Start To Accrue.
What caught our eye in Amirtalesh v. Beverly Hills Properties, LLC, Case Nos. B339300 et al. (2d Dist., Div. 2 Aug. 28, 2026) (unpublished) was the discussion on whether prevailing SLAPP defendants in a dismissed case timely filed their memorandum of costs. Several defendants won SLAPP motions resulting in a dismissal of the case as to them, although one more defendant remained in plaintiff’s case. The lower court served an unsigned SLAPP minute order; also, a signed, file-stamped dismissal order was served. SLAPPing defendants served their costs memo 10 days after the 15-days CRC general deadline from the date of the two orders, with plaintiff arguing that the signed dismissal order demonstrated the memo filing was tardy. The lower court denied plaintiff’s motion to tax costs, awarding $3,474.95 in costs to defendants. The appellate court did not have to get into the thicket of whether either order triggered a 15-day filing deadline, because case law established that the memo filing deadline had not yet accrued because there was a remaining defendant, such that the case had not been fully resolved. (Daniels v. Robbins, 182 Cal.App.4th 204, 229 (2010).) Given that no deadline was blown, the costs order was affirmed on appeal.