In Pellegrini v. Weiss (2008) 165 Cal.App.4th 515, the court held that construing California Rules of Court, rule 3.1802, to require the imposition of interest between the verdict and judgment would conflict with Code of Civil Procedure section 685.020, subdivision (a). Rule 3.1802 states: "The clerk must include in the judgment any interest awarded by the court and the interest accrued since the entry of the verdict." Effective January 2007, rule 3.1802 was modeled after former rule 875, which provided: "The clerk shall include in the judgment any interest awarded by the court and the interest accrued since the entry of the verdict." In turn, Code of Civil Procedure section 685.020, subdivision (a) provides: "Except as provided in subdivision (b), interest commences to accrue on a money judgment on the date of entry of the judgment." To reconcile these provisions to resolve the question of whether interest began to run at the time of the verdict or entry of judgment, the Pellegrini court explained: "We read rule 3.1802 of the California Rules of Court as directing the clerk to calculate the continuation of any prejudgment interest that may have been awarded from the date of the verdict through the date of the judgment. Were we to construe California Rules of Court, rule 3.1802 as providing that postjudgment interest accrues between verdict and judgment, it would conflict with Code of Civil Procedure section 685.020. A rule of court cannot take precedence over a statute, however, so we decline to construe California Rules of Court, rule 3.1802 in that fashion." (Pellegrini, supra, 165 Cal.App.4th at pp. 532-533.) The court further declined to apply prior decisional law requiring that a damages award bear interest during the period following rendition of the verdict or decision and until entry of judgment. (Id. at p. 533.) It reasoned that prior case law was based on a requirement in former Code of Civil Procedure section 1033 and determined there was no equivalent statutory provision currently in effect. (Pellegrini, supra, at p. 533.)