When must a California prevailing party file a cost memorandum?

Qualifying entry-notice service and actual judgment entry

Retain each notice, its proof and the entry record. Absence of notice does not authorize ignoring the outer entry-based period.

Responsible actor. The prevailing party claiming recoverable costs. Compare qualifying clerk or party entry-notice service with judgment entry and applicable extensions. Default costs use the separate request procedure.

1. Qualifying entry-notice service and actual judgment entry
2. Retain each notice, its proof and the entry record. Absence of notice does not authorize ignoring the outer entry-based period.
3. Resolve all stated events, qualifications and comparisons. This source guide supplies no computed or paid date.
4. Serve and file a verified memorandum of costs. For default judgment, request costs as part of the default-judgment application under subsection (a)(2).

CCP 12 excludes the triggering day for ordinary day periods. CCP 12a supplies the final judicial-holiday adjustment, including Saturdays and the CCP 135 holidays. CCP 12b addresses qualifying whole-day office closures. Court-day periods exclude intermediate Saturdays, Sundays and judicial holidays. Calendar-day periods include intermediate closed days. Rule 1.11 supplies Friday observance of a Saturday judicial holiday and Monday observance of a Sunday judicial holiday. The calendar includes Lincoln Day, March 31, Juneteenth, Native American Day and Thanksgiving Friday. It excludes Columbus Day and Good Friday as ordinary full judicial holidays. The observed New Year holiday on December 31, 2027 is confirmed in the county schedule. Actual additional closures require separate evidence.

Establish the actual service method and legally completed event. The tax-cost preset is confined to personal service; rule 3.1700(b)(1) expressly recognizes CCP 1013 mail and CCP 1010.6 electronic additions. Filing-triggered brief and review-answer clocks do not begin merely with service. CCP 1013 and 1010.6 exclude their stated additions for a notice of appeal. A summons-service event and an appellate filing event have distinct requirements. These presets do not calculate excluded service or combined procedural branches.

Official 2026 Rules of Court were reviewed. Publication coverage begins January 1, 2026 and assumes the reviewed branch still governs the input. Displayed final dates use the independently retained 2026 and 2027 California judicial calendar. Earlier or amended editions, emergency orders and actual additional closures require separate review. A closed backward statement boundary receives no date because its exact adjustment is not implemented. Source guides for combined appeal clocks, stipulated responses, cost memoranda and decision finality supply no computed or paid date. These software coverage boundaries do not establish that an actual filing is late.

A notice served soon after entry and a notice served near the entry-based outer boundary produce different comparisons. A default-judgment cost request uses a different procedural act. One service date cannot determine every branch.

Earlier of the qualifying fifteen-day service clock and the 180-day entry clock, with extensions established separately

Verification

The party, attorney or agent must verify that the listed costs are correct and necessarily incurred.

Written agreement and court extension

Parties may agree to extensions confirmed in writing, specifying the extended service date and filed with the clerk. Without agreement, the court may extend at most thirty days. The rule does not impose that court cap on every party agreement.

Default costs

The default-judgment branch requests costs on the stated Request for Entry of Default form rather than assuming the prevailing-party notice clock.

Service methods and distinct statutory additions

Establish the actual service method and legally completed event. The tax-cost preset is confined to personal service; rule 3.1700(b)(1) expressly recognizes CCP 1013 mail and CCP 1010.6 electronic additions. Filing-triggered brief and review-answer clocks do not begin merely with service. CCP 1013 and 1010.6 exclude their stated additions for a notice of appeal. A summons-service event and an appellate filing event have distinct requirements. These presets do not calculate excluded service or combined procedural branches.

Edition and calendar coverage

Official 2026 Rules of Court were reviewed. Publication coverage begins January 1, 2026 and assumes the reviewed branch still governs the input. Displayed final dates use the independently retained 2026 and 2027 California judicial calendar. Earlier or amended editions, emergency orders and actual additional closures require separate review. A closed backward statement boundary receives no date because its exact adjustment is not implemented. Source guides for combined appeal clocks, stipulated responses, cost memoranda and decision finality supply no computed or paid date. These software coverage boundaries do not establish that an actual filing is late.

• Compare qualifying clerk or party entry-notice service with judgment entry and applicable extensions. Default costs use the separate request procedure.
• Earlier of the qualifying fifteen-day service clock and the 180-day entry clock, with extensions established separately

• Qualifying entry-notice service and actual judgment entry
• Retain each notice, its proof and the entry record. Absence of notice does not authorize ignoring the outer entry-based period.
• The party, attorney or agent must verify that the listed costs are correct and necessarily incurred.
• Parties may agree to extensions confirmed in writing, specifying the extended service date and filed with the clerk. Without agreement, the court may extend at most thirty days. The rule does not impose that court cap on every party agreement.
• The default-judgment branch requests costs on the stated Request for Entry of Default form rather than assuming the prevailing-party notice clock.
• Serve and file a verified memorandum of costs. For default judgment, request costs as part of the default-judgment application under subsection (a)(2).
• Trial court electronic filing follows CCP 1010.6 and rules 2.253 and 2.259. Qualifying court-day electronic receipt receives the stated filing-date treatment, but receipt and accepted filing confirmations are distinct. Preserve both, required fees or waiver and proof of service. Rule 2.259(c) addresses proved court-system failure and excludes complaints and other initial pleadings from that provision. Do not assume a draft upload, service receipt or rejected submission establishes filing. Check the actual court and local requirements.