Plaintiff Failed To Timely File A Fee Motion 60 Days After Dismissal Was Entered.
With no need to go through the details, Animal Protection and Rescue League, Inc. v. Marengo, Case No. D082607 (4th Dist., Div. 1 Dec. 16, 2024) (unpublished) should remind practitioners filing a dismissal without prejudice on behalf of a plaintiff that they must file their fee motion within 60 days after service of a notice of entry of the dismissal. (Sanabria v. Embrey, 92 Cal.App.4th 422, 427 (2001).) In this case, failure to do so sustained a lower court’s conclusion that the fee motion was untimely filed.