California, United States of America
The following excerpt is from Richards v. S.J. Amoroso Constr. Co., A129670, A130837 (Cal. App. 2012):
Sometimes the intent to determine entitlement and amount of costs and fees in a postjudgment proceeding is made explicit in a judgment. (See Colony Hill v. Ghamaty (2006) 143 Cal.App.4th 1156, 1171-1172 [judgment stated, " 'Award of attorney's fees and costs shall be determined by post-judgment application' "].) Where the language of the judgment is ambiguous, courts have taken a holistic view of the case to determine whether the court intended and the parties understood that the issue of entitlement has or has not been settled by the judgment.
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