Appeal from District Court Was Timely: “Posttrial” Rule 52 / 59 Motion Tolled Appellate Deadline

A timely “posttrial” motion in the district court was effectively made under Rule 52 or 59, and thus tolled the time for noticing an appeal. An appeal filed fourteen days after disposition of that motion was timely. Larkin v. Am. Western Ins. Co., No. 2060720 (Ala. Civ. App. Aug. 24, 2007).

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