In Becker v. Halliday, 218 Mich App 576, 578; 554 NW2d 67 (1996), the plaintiff was awarded $ 200,000. She subsequently filed a motion for costs and attorney fees, which was denied following a hearing. Between the hearing and the release of the trial court's order denying the motion, the plaintiff and her counsel signed a satisfaction of judgment which expressly provided that all "interests, costs, and attorney fees" were included. In response to the plaintiff's subsequent appeal of the trial court's denial of attorney fees, the defendant argued that the satisfaction precluded an award of further fees. The Court first indicated that the action fell directly within the Wohlfert exception, noting that the amount already received by the plaintiff was not to be relitigated, and that the plaintiff's appeal addressed only whether the plaintiff was entitled to additional costs and fees provided by court rule. Becker, supra at 578. Nevertheless, the Court found that because the satisfaction did not include any limiting language evidencing an intent to maintain the pending action for fees, the plaintiff had waived her right to any additional costs or fees she may have been entitled to under the court rules. Id. at 579-580.