The First District, Division 5 in Lucky Unified Properties Investments, Inc. v. Lee, Case No. A132914 (1st Dist., Div. 5 Feb. 4, 2013) (partially published) provided clarity on the issue of when interest begins to run on postjudgment fee/costs awards where the fees/costs were incurred postjudgment or on appeal. The appellate court determined that, in both cases, interest began to run from the date of “fixing” of the postjudgment cost/fee awards, not earlier. Although determining that a trial court award of fees and costs for appellate work is incorporated into the original judgment for enforcement purposes, interest does not begin to run until the date that the appellate costs/fees are “fixed” by the lower court.