Can a postjudgment award of expert witness fees pursuant to section 998 be reviewed on an appeal from the judgment?

In Fish v. Guevara (1993) 12 Cal.App.4th 142, the court applied a similar analysis to a postjudgment award of expert witness fees pursuant to section 998. In that case, the judgment "provided that defendants could recover from plaintiffs 'all costs, expenses and disbursements allowed by law . . . .' " (Id. at p. 144.) In their subsequent memoranda of costs, the defendants sought expert witness fees pursuant to section 998, which the court granted. (Ibid.) The appellate court held the case did not fall within the rule of Grant because the award of expert witness fees under section 998 was discretionary and thus the judgment for the defendant (and the allowance of costs) did not necessarily establish the defendants' entitlement to such discretionary fees. (Id. at pp. 147-148.) "An award of expert witness fees pursuant to section 998 is not incidental to the judgment but is instead a separately litigated issue. [Citation.] . . . [Therefore,] the propriety of a postjudgment award of expert witness fees cannot be reviewed on an appeal from the judgment." (Id. at p. 148.)