In re Marriage of Gray

In In re Marriage of Gray (2002) 103 Cal.App.4th 974, the court observed "the eight-hour rule in Code of Civil Procedure section 632 requires a simple and obvious mode of timekeeping that everyone, including attorneys, can keep track of. This means that, for purposes of keeping time of trial under Code of Civil Procedure section 632 in civil proceedings other than administrative mandamus (an issue not before us), the time of trial means the time that the court is in session, in open court, and also includes ordinary morning and afternoon recesses when the parties remain at the courthouse. It does not include time spent by the judge off the bench without the parties present -- lunch, for example -- except for such routine recesses as occur during the day." (Id. at pp. 979-980.)