Followed In Unpublished Opinion Issued On April 26, 2016.
On August 21, 2014, we first posted on Kaufman v. Diskeeper Corp., 229 Cal.App.4th 1, 8-9 (2014), which held that a costs memorandum did not have to be filed as a condition precedent for purposes of a litigant being able to seek recovery of attorney’s fees. Instead, CRC 3.1702 only requires the filing of a timely motion. We can now report that the Fourth District, Division 1 has followed Kaufman in an unpublished opinion, Campman v. Neborsky, Case No. D068357 (4th Dist., Div. 1 Apr. 26, 2016) (unpublished), where a litigant won $14,000 in attorney’s fees after a motion for reconsideration brought Kaufman before the lower court’s consideration.