Pre-Offer Expert Fees Unrecoverable Under § 998.

Toste v. Calportland Constr., No B256946 (D2d6 Mar. 2, 2016)

Plaintiff appeals on a grab-bag of issues after a defense verdict in a wrongful death case. The jury found one defendant negligent but no causation for any of them. There are two procedural issues: a new trial motion based on jury misconduct and the rejection of a § 998 offer.