The fees and expenses of a receiver appointed as a provisional remedy may, in the trial court’s discretion, be awarded in whole or part as costs to the prevailing party in the litigation under CCP 1033.5(c)(4).  The award of those costs is properly left to the conclusion of the litigation after entry of final judgment and is not determined by the order appointing the receiver or the order approving the receiver’s final accounting.

California Court of Appeal, Fourth District, Division 3 (O’Leary, P.J.); January 19, 2017 (published February 16, 2017); 2017 WL 222723