In In re Marriage of Wallace Loy Tim and Amy Ju Wong, the Fourth Appellate District reiterated that a postjudgment order is only appealable if it passdx three additional tests: (1) the issue is different from the issues decided in the judgment; (2) the order affects the judgment or relates to its enforcement; and (3) the order is not “preliminary to a later judgment.” Here, the respondent appealed orders pertaining to discovery referee reports and recommendations regarding discovery and related issues. The court noted that the appeal of postjudgment discovery orders is difficult, collecting cases that considered that issue, but denied the appeal of the orders at issue because it found that those discovery orders would be appealable from the determination of the request for order.
