California, United States of America
The following excerpt is from Cont'l E. Fund Iv, LLC v. Crockett, D069652 (Cal. App. 2016):
An order entered after an appealable judgment is itself appealable under section 904.1, subdivision (a)(2). However, not every postjudgment order is appealable. (Lakin v. Watkins Associated Industries (1993) 6 Cal.4th 644, 651 (Lakin).) "To be appealable, a postjudgment order must satisfy two additional requirements. . . . [] The first requirement . . . is that the issues raised by the appeal from the order must be different from those arising from an appeal from the judgment. [Citation.] 'The reason for this general rule is that to allow the appeal from [an order raising the same issues as those raised by the judgment] would have the effect of allowing two appeals from the same ruling and might in some cases permit circumvention of the time limitations for appealing from the judgment.' [Citation.] . . . [] The second requirement . . . is that 'the order must either affect the judgment or relate to it by enforcing it or staying its execution.' [Citation.] Under this rule, a postjudgment order that does 'not affect the judgment or relate to its enforcement [is] not appealable . . . .' " (Id. at pp. 651-652.) In addition, the postjudgment order must not be preliminary to further proceedings and become subject to appeal after a future judgment. (Id. at p. 654.)
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