California, United States of America
The following excerpt is from Cheatham v. City of Chino, E056850 (Cal. App. 2014):
Similarly, in Passavanti v. Williams, supra, 225 Cal.App.3d 1602, this court construed a postjudgment motion for reconsideration to be a motion for new trial for purposes of determining whether the appeal was timely. (Id. at pp. 1608, 1610-1611.) We even conceded, "[o]ne might argue that in refusing to construe a motion for reconsideration to be a motion for new trial, the appellate court would be elevating form over substance and that if the motion, regardless of its label, arguably would qualify as a
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