10% Per Annum Rate Governed Costs Award.
In our June 19, 2014 post, we discussed Chodos v. Borman, 227 Cal.App.4th 76 (2014) (Chodos I), where the appellate court refused to sustain a multiplier were the attorney had no retainer agreement with the client such that the lodestar, with two stipulated adjustments, adequately compensated the attorney. That was not the end of the story, though. The lower court entered a new final judgment following the first appellate remittitur, but apparently did not award trial costs from Chodos I or interest on the requested costs.
Those omissions were cured in Chodos v. Borman, Case No. B260326 (2d Dist., Div. 5 Aug. 18, 2015) (published) (Chodos II).
The appellate court determined that attorney was entitled to routine trial costs of $12,983.99 as a matter of right under an unopposed costs memorandum. Also, attorney was entitled to interest at 10% per annum on the costs award running from the date of the original judgment. (Code Civ. Proc., § 685.020(a).)