Czura v. Siegel

In Czura v. Siegel, 296 N.J. Super. 187, 686 A.2d 390 (App.Div.1997), the Court considered the significance of R. 4:42-9(d), which provides that "an allowance of attorney's fees made on the determination of a matter shall be included in the judgment or order stating the determination." That panel said "the necessary implication of that rule is that an application for the allowance of attorneys' fees . . . has to be presented before the entry of the final judgment or, possibly, at the latest, within ten days thereafter by a motion to alter or amend the judgment under R. 4:49-2." In 1998, the ten-day period of that rule was changed to twenty days. Pressler, Current N.J. Court Rules, comment on R. 4:49-2 (2001).