Said It Before, Will Say It Again ... Separately Appeal, Separately Appeal.
Acting Presiding Justice Rylaarsdam, on behalf of a 3-0 panel, in Nellie Gail Ranch Owners Assn. v. Colombo, Case No G047064 (4th Dist., Div. 3 Dec. 3, 2013) (unpublished), reinforced a message we have said a lot during our blog--separately appeal fee awards, because it cannot hurt even if you have an argument to the contrary.
In this one (which unfortunately involved a long-standing feud between a homeowner and a homeowner association [HOA]), there was a fuss about some fee requests during this protracted litigation. However, homeowner failed to timely appeal certain fee awards--yes, even under the longer 180 day period--a couple of postjudgment fee awards adverse to homeowner. This was fatal to a consideration of the merits. (Taper v. City of Long Beach, 129 Cal.App.3d 590, 606-607 (1982).)