Attorney fees on appeal must be sought in the trial court within 40 days after issuance of the remittitur. This decision holds that the 40-day deadline runs from the date the remittitur is entered in the Court of Appeal’s records. There is no extension of the 40 day deadline for service by electronic means or by mail because the remittitur is not “served” on the parties, but merely sent to them as a courtesy.