We need answer user's legal deadline calculation question. Need produce ordered preservation plan. Must analyze carefully. Need likely use assumed rules, facts. Need compute dates with day excluded, weekends/holidays? No holidays specified except maybe court holiday? May 1 2026 Friday. Need know 2026 calendar? Need calculate dates. Let's verify days. 2026 May 1 is Friday given. Need deadlines:

1. Rule-1 motion (new trial/alter/amend) no later than 28 calendar days after entry judgment. Exclusion day May 1. Count May 2 day 1. 28 days after May 1? Let's compute: May has 31 days. Excluding May 1, May 2-29 = 28 days? Let's count: May 2 (1), 3 2, 4 3, 5 4, 6 5, 7 6, 8 7, 9 8, 10 9, 11 10, 12 11, 13 12, 14 13, 15 14, 16 15, 17 16, 18 17, 19 18, 20 19, 21 20, 22 21, 23 22, 24 23, 25 24, 26 25, 27 26, 28 27, 29 28. So deadline May 29, 2026. Friday? Let's check: May 1 Friday, May 8 Friday, May 15 Friday, May 22 Friday, May 29 Friday. Not weekend. So file by 11:59 May 29. If filed May 8? May 8 is within 28. Planned motion likely must be filed by May 29. But current counsel plans? If filed now? The question asks when it must be filed. Since facts say current counsel plans to file, maybe need specify by May 29, 2026. If not yet filed, it's critical. If filed on/after May 30, late and no toll? Need preserve. Also substance must request rule-1 relief: alter/amend judgment to add prejudgment interest and, in alternative, new trial based on witness exclusion. It can identify relief and grounds. Need note if merely reconsider evidentiary ruling doesn't toll. The May 8 motion titled reconsider evidentiary ruling asks only witness exclusion, does not request alteration/new trial/other rule-1 relief. Rule 4 says local reconsideration interlocutory evidentiary ruling within 10 days, does not alter judgment and does not toll appeal period. Rule 8 says wrong label doesn't toll unless substance requests relief available under rule1 and timely. Here substance only reconsider exclusion, no rule1 relief, so no toll. Even if it was filed within 28 days? It doesn't count as rule-1 motion. Does it toll? No. Does it toll appeal? No. Does it affect fee? No.

2. Fee motion deadline: no later than 14 calendar days after entry judgment unless statute/order otherwise. Statute applies but no special deadline ordered. Does fee-shifting statute provide otherwise? Fact: fee-shifting statute applies, no special fee deadline ordered. Under rule 3: 14 days unless statute or order provides otherwise. Need determine if statute provides otherwise? It says fee-shifting statute applies, no special fee deadline ordered. Probably use 14 days. Exclude May 1; May 2 day1; May 15 day14? May 2 +13 = May 15. May 15 Friday. File by 11:59 May 15. Need note cannot wait until merits motion decided. It does not toll appeal from merits judgment. If missed, likely waiver of fees? Exact consequence: failure to timely file fee motion = cannot seek attorney fees? Need state: loses/waives claim to recover attorney fees (subject to possible excusable neglect? But assignment asks exact consequence of missing each separate deadline; maybe: fee claim lost, no fees awarded; if not filed timely, cannot recover fees. But there may be later motion? We should be precise based on assumptions. If no special deadline, 14 days jurisdictional? The rule says must be filed no later than. So missing = untimely, cannot recover fees; cannot file after? It may be denied as untimely. Need maybe state: waiver of fee claim; cannot raise on appeal? Need careful: Rule says motion for attorney fees must be filed no later than 14 days after judgment unless...; fee motion does not toll time to appeal. Consequence missing: claim for fees lost, court lacks discretion? Since no extension? It doesn't say court may not extend; only rule1 may not extend. But "must be filed no later than" suggests mandatory. Could be nonjurisdictional but strong. We can state absent tolling/extension or statutory exception, a fee motion filed after May 15 is untimely and the client likely forfeits/waives fees. The exact consequence: no award of $185,000 fees (or any fees) based on that motion; if not timely, cannot later seek fees. But maybe could seek as part of rule1 motion? Rule1 motion for new trial or alter amend judgment. Can attorney fees be added to judgment by motion to alter/amend? Hmm. In civil rights, attorney fees are separate? Rule 3: motion for attorney fees must be filed 14 days after judgment unless otherwise. A motion to alter or amend judgment to add prejudgment interest maybe also could request fees? But rule says fee motion separate. We need not overcomplicate. The plan: file fee motion by May 15, don't wait. Could include in or separate? It says motion for attorney fees must be filed. Need preserve by filing separate fee motion by May 15. If also file rule-1 motion by May 29, can include fee request? But to be safe, file dedicated fee motion by May15. If filed as part of rule1 after May15, likely untimely under rule3. Need note.

3. Original notice of appeal deadline if no tolling motion filed: 30 calendar days after entry judgment. Exclude May 1; 30 days: May 2 day1, May31 day30? Let's count. May has 31 days. From May 2 to May 31 inclusive = 30 days. So May 31, 2026. What day of week? May 29 Friday, May 30 Saturday, May31 Sunday. Rule 6: if last day Saturday/Sunday/holiday moves to next day clerk's office open. So deadline moves to Monday, June 1, 2026. Need note electronic by 11:59 local court time June 1. Is June 1 a holiday? Not specified. Assume clerk open. If court holiday? Could be? Need maybe note if June 1 holiday, next open day. But given no holidays, assume open. So original NOA due June 1 (due to weekend shift). Wait: rule 6: day of triggering event excluded; every later calendar day counted. If last day falls Sat/Sun/holiday, moves to next open. Counting 30 days: May 31 Sunday -> June 1 Monday. Yes.

But wait: If no rule-1 motion filed, appeal period starts from judgment? Yes. Original notice due 30 days after entry, extended to June 1. If a timely rule-1 motion filed, it tolls. Need calculate new notice deadline if rule-1 motion decided July 10, 2026. A new 30-day appeal period begins when court enters order disposing of last timely rule-1 motion. Exclude disposition date? Rule 6: day of triggering event excluded; every later calendar day counted. Triggering event is entry of order disposing last timely rule1 motion on Friday July 10. Exclude July 10; July 11 day1. Need 30 days after July 10. July 2026 has 31 days. Count July 11 (1) ... July 40? Let's compute: July 11 +29 = July 40? Since July 31 day21? Let's count: July 11=1, 12=2, 13=3, 14=4, 15=5, 16=6, 17=7, 18=8, 19=9, 20=10, 21=11, 22=12, 23=13, 24=14, 25=15, 26=16, 27=17, 28=18, 29=19, 30=20, 31=21. August 1=22, 2=23, 3=24, 4=25, 5=26, 6=27, 7=28, 8=29, 9=30. So August 9, 2026. Day of week? Need know. July 10 Friday. July 11 Saturday, 12 Sunday, 13 Monday, 20 Monday, 27 Monday, Aug 3 Monday, Aug 9 Sunday. Let's verify: If July 10 Friday, July 17 Friday, July 24 Friday, July 31 Friday, Aug 7 Friday, Aug 9 Sunday. So last day Aug 9 Sunday -> moves to next open day Aug 10 Monday (assuming no holiday). So new NOA due Monday, August 10, 2026 by 11:59. Need note if court decides before July 10? The expected July 10. Need if court's order entered July 10. If last timely rule-1 motion includes planned motion. What about May 8 motion? It is not rule1, does not toll, and if it is disposed? It might be local reconsideration within 10 days? Judgment May1, May8 within 10? Exclude May1, May2=1, May8=7? Yes within 10. It doesn't toll appeal. But if not disposed? It's interlocutory evidentiary ruling; likely may be decided separately. Does it affect "last timely rule-1 motion"? No, not rule1. If no planned rule1 motion filed timely, no tolling; original June1. If planned filed timely and denied July10, new deadline Aug10.

Need consider if the May 8 motion (reconsider evidentiary ruling) is filed after judgment and could be treated as a motion for new trial? It asks only that trial judge reconsider witness exclusion. Does not request alteration/new trial. Rule 8 says wrong label does not toll unless substance requests relief available under rule1 and timely. It doesn't. So no. If it had requested new trial, then timely? Filed May8 within 28. It would toll. But it didn't.

Need maybe mention the planned rule-1 motion must be filed by May 29, 2026. Since today? The question doesn't state current date, but facts: judgment May1; May8 filed; expected July10. It asks prepare deadline sequence so no right lost. Need assume counsel can file by May29? If current date maybe after May29? Not given. We can state: To obtain tolling, the rule-1 motion must be filed no later than May 29, 2026. If not filed by then, no tolling from it; only original appeal deadline June 1 remains. Since current counsel plans to file; if filing now (within scenario?) must be by May29. Need maybe note if May 29 has passed? The assignment probably wants calculation, not actual current. But "Current counsel plans" suggests before? We need maybe state: if not already filed, file immediately but no later than May29. If after May29, cannot rely on it to toll; file NOA by June1 (unless some other extension? no).

Need maybe discuss attorney fee motion deadline and whether can wait until merits motion decided. No: fee motion deadline is May15, independent, does not toll merits appeal. It must be filed by May15. It may be pending while rule1 motion decided; it does not extend appeal. If fee motion is filed timely, it may be decided later; does it toll? Rule3 says does not toll time to appeal from merits judgment. So no.

Need ordered preservation plan: maybe step-by-step chronology. Need include:

- May 1, 2026 judgment entered (Friday). Day 0 excluded.
- May 8: former counsel filed evidentiary reconsideration (timely local under 10-day rule? maybe yes) but no rule1 relief; no toll.
- By May 15, 2026 (Friday): file attorney-fee motion. Include requested fees, statute, amount, maybe request award of $185k, costs. Consequence of missing: fees claim lost/untimely; cannot recover fees; cannot wait until July10.
- By May 29, 2026 (Friday): file rule-1 motion to alter/amend judgment to add $42k prejudgment interest and in alternative new trial on witness exclusion. Must identify relief and grounds. If filed timely, tolls appeal. Consequence of missing: no tolling; NOA deadline reverts to June1 (or if fee motion? no). If missed, interest correction? Maybe motion untimely; court may not consider? Rule1 says must be filed no later than 28 days; court may not extend. Missing = no alteration/new trial? It might lose post-trial relief and appeal tolling; appeal only from May1 judgment, and issue maybe preserved? Need exact: failure to timely file rule1 motion means cannot use it to correct interest or get new trial, and appeal period not tolled; must appeal by June1. On appeal, can challenge interest omission? If issue not raised in timely post-trial motion? Maybe appellate issue? But the rule says motion to alter/amend must be filed; to preserve? The assignment: identifies exact consequence of missing each separate deadline. For rule1 deadline: loss of right to seek new trial/alter amendment? and loss of tolling; appeal clock not extended. Also if not filed, cannot rely on May8 to toll. The court may not extend deadline. So missing = post-trial relief unavailable/untimely and appeal deadline remains June 1.

- Original NOA if no tolling: June 1, 2026 (Monday, extended from May31 Sunday). Consequence of missing: appeal from judgment lost; judgment final; no appellate review of merits or evidentiary exclusion? But can maybe seek cert? No. Need exact: failure to file timely notice = loss of right to appeal the judgment; final and unreviewable (except extraordinary remedies). If fee motion filed, does not toll; missing NOA = no appeal.

- If planned rule1 motion timely filed and decided July10: new NOA deadline: 30 days after July10 order, count excluded July10 -> August 9 Sunday -> August10 Monday. Consequence missing: loss of appeal from final judgment/disposition of rule1 motion; no appellate review.

- Should notice be filed before or after disposition? Rule 5: notice within 30 days after judgment unless tolled. A premature notice filed after judgment but before disposition of timely rule1 motion becomes effective upon disposition, but filing proper later notice is safer. Need answer: Best practice: after disposition? The question asks states whether a notice should be filed before or after disposition. We need decide. Under rule 5, premature notice filed after judgment but before disposition becomes effective upon disposition, but later notice is safer. If planned rule1 motion is timely filed and expected to be decided July10, and appeal deadline after disposition Aug10. Could file notice before disposition? It would become effective upon disposition, preserving? But "filing a proper later notice is safer." The assignment likely wants: Do not rely on premature notice; wait until after the court disposes of the timely rule-1 motion, then file by August 10. Or if you want belt-and-suspenders, you could file a protective notice after judgment but before disposition; it becomes effective upon disposition, but a later proper notice is safer. The prompt: "States whether a notice should be filed before or after disposition." Need likely answer: After disposition (or at least the safest and recommended is to file a proper notice after disposition, by Aug 10). But also mention protective premature notice is permissible and becomes effective upon disposition, but not necessary and less safe? Let's parse: Rule 5: "A notice of appeal must be filed within 30 calendar days after entry of judgment unless rule 2 tolls the period. A premature notice filed after judgment but before disposition of a timely rule-1 motion becomes effective upon disposition, but filing a proper later notice is safer." They may expect: If rule1 motion timely filed, you may file notice either before disposition (it will become effective when motion disposed) or after disposition by Aug10; safest is to file proper notice after disposition. Need maybe say: Because the motion is expected to be decided July10 and new period runs to Aug10, file after disposition, no later than Aug10. Do not file before unless protective; if filed before, it won't be effective until July10, but still within 30 days? Actually if premature notice becomes effective upon disposition, it would trigger 30 days? It says becomes effective upon disposition. If filed before disposition, it becomes effective on July10, so deadline would be? If effective July10, then 30 days after? But the rule says new 30-day appeal period begins when court enters order disposing. A premature notice becomes effective upon disposition; perhaps it is treated as filed then, so due by Aug10? Wait if notice filed before, becomes effective upon disposition; but if it becomes effective July10, is that timely? It would be effective at start of 30-day period? That seems odd. Maybe means a premature NOA filed while rule1 motion pending is not effective until disposition, so it starts running? But "filing a proper later notice is safer" suggests not rely. We need not overanalyze; answer: safest after.

Need maybe mention if the planned rule1 motion is filed and pending, no NOA is due until after disposition if relying on tolling. But if motion not timely, original NOA due June1. If motion timely filed but then granted? If granted, judgment altered/amended, maybe appeal from new judgment? Rule2: new 30-day appeal period begins when court enters order disposing of last timely rule1 motion. Whether granted or denied? It says disposing. So if granted, new judgment/order disposition triggers. If denied, also. If partially granted? last timely rule1 motion. Need maybe if court denies without prejudice? But assume denied July10. Need note if the court issues any later order? The expected July10; if later, recalc from actual disposition. If there are multiple timely rule1 motions, last one controls. The May8 motion not rule1. The fee motion not rule1 and doesn't toll. If fee motion is decided later? Does that count? No, not rule1. If fee motion is part of judgment? Rule3 says no toll. So no.

Need maybe check 10-day local reconsideration: May8 within 10 days? Excluding May1, May2 day1, May8 day7. Deadline May11? Let's count 10 days: May2-11 = 10 days. May11 Monday? May1 Friday, May2 Sat, May3 Sun, May4 Mon, May5 Tue, May6 Wed, May7 Thu, May8 Fri, May9 Sat, May10 Sun, May11 Mon. So May8 timely local. But not toll. It may be moot if rule1 motion includes new trial on same witness exclusion? But could preserve? It asks reconsider exclusion; maybe it preserves issue? For appeal, to appeal evidentiary ruling, must be preserved in judgment? It is excluded witness; maybe can be appealed if part of final judgment. The local motion doesn't toll but may be considered? The question focuses tolling. Need maybe mention May8 motion does not toll appeal, but it may be a local attempt to preserve the issue; however, it does not alter judgment and does not start appeal clock. It may not preserve for appeal? In federal practice, objection on record may be enough; but under assumed rules, appeal from merits judgment. The exclusion was at trial, presumably preserved by objection? Not given. We need only answer assigned items.

Need maybe compute exact dates with day names and e-filing cutoff.

Need maybe mention court holidays: no specified holidays; if deadline falls holiday, shift to next open. We should note assumptions: no court holidays on May 15, May 29, June 1, Aug 10? Actually deadlines: May15 Friday, May29 Friday, June1 Monday, Aug10 Monday. If any are holidays, shift. Need maybe note Memorial Day? May 25 2026? Memorial Day is last Monday May: May 25, not deadline. Juneteenth June 19? Not. Columbus Day Oct. No. Independence Day Jul4? Not. Labor Day Sep. So no conflict. But if local court holidays? Not given. Could mention assuming clerk open on indicated days; if holiday, next open day.

Need maybe verify 2026 day-of-week: Given May 1 Friday. Let's ensure Aug 9 Sunday. May 1 Friday. Let's calculate using known? 2026 Jan 1 Thursday? But given May1 Friday. Let's verify: 2026 not leap. Jan1 Thursday? Jan31 Sat, Feb28, etc. May1? 2026 May 1 is Friday indeed. July 10? May1 Friday, May31 Sunday, Jun30 Tuesday? Let's compute: May has 31 days; May31 Sunday. June 1 Monday. June 30? 30 days later: June 30 Tuesday? If June1 Monday, June30 Tuesday (since 29 days later? June 1 Mon, June 8 Mon, 15 Mon, 22 Mon, 29 Mon, so June30 Tue). July 1 Wednesday, July 10 Friday yes. July31 Friday, Aug1 Saturday, Aug9 Sunday, Aug10 Monday. Good.

Potential nuance: Rule 1: "motion for a new trial or to alter or amend the judgment must be filed no later than 28 calendar days after entry of judgment. The court may not extend that deadline." If planned motion includes both alter/amend and alternative new trial, it's a rule1 motion. It must request relief available under rule1. It must be timely. Does filing alternative new trial based on witness exclusion and request alter amend to add interest satisfy? Yes. Must identify requested relief and grounds. Need maybe include: request: (1) alter/amend judgment to add $42,000 prejudgment interest; (2) alternatively, grant new trial or remand for retrial due to erroneous exclusion of witness; maybe also request costs? But not necessary. Need maybe if it only asks "reconsider evidentiary ruling" no. Need maybe if it asks to "vacate and enter correct judgment"? That's alter/amend. If it requests "reconsider" but includes rule1 relief? Rule8 says substance controls. The May8 doesn't.

Need maybe mention if May8 motion could be amended? To preserve tolling, could file supplemental rule1 motion by May29; if May8 motion already filed, maybe amend to add rule1 relief by May29? But if amendment adds new relief, is it timely? Rule8 says filing document under wrong label does not toll unless its substance requests relief and it is timely. If May8 document substance not, cannot later amend to toll? Could file a separate rule1 motion by May29. If May8 motion was intended but missing, maybe an amended motion by May29 that includes all relief could be timely as to added relief? The rule says must be filed no later than 28 days; an amended motion seeking rule1 relief filed by May29 might be timely if it is filed by then. But if original didn't, not relevant. We can recommend: If not already filed, file a separate, properly scoped rule-1 motion by May29; do not rely on May8. If a May8 motion exists, don't rely; file timely rule1 motion. Could maybe file on May29. Need maybe if current counsel's planned motion is filed after May29? Then no tolling; must file NOA by June1. But the prompt says court expected to decide July10; that suggests planned motion must be filed by May29. We need maybe state: The July10 decision only produces a new appeal deadline if the motion was timely filed by May29. If it is not filed by May29, the July10 order does not toll the appeal clock; NOA still due June1. This is important.

Need maybe consider whether a fee motion can be filed after May15 as part of rule1 motion to alter/amend judgment? Rule3 says motion for attorney fees must be filed 14 days. If the planned rule1 motion to alter/amend judgment is timely and requests adding interest, could it also request attorney fees as part of altering judgment? It might be a motion to alter/amend judgment to add fees. But Rule3 specifically says motion for attorney fees must be filed by 14 days. If the fee request is included in a rule1 motion filed within 14 days, maybe timely? But planned motion likely after May15? Need maybe say: To be safe, file a separate attorney-fee motion by May15. If you include a fee request in a rule1 motion filed after May15, it likely violates rule3. If the rule1 motion is filed before May15 and requests fees, maybe it could be considered timely fee motion? But the prompt says current counsel plans to file motion to alter/amend judgment to add interest and alternative new trial; not mention fees. Fee deadline earlier. Need answer client asks whether fee motion can wait until merits motion decided: No. It must be filed by May15. It does not toll appeal. It can be pending while merits motion is decided. It doesn't affect NOA deadline.

Need maybe "ordered preservation plan" could be a table with deadlines, actions, consequences. Need final answer with ordered sequence. We should be thorough.

Need maybe include calculations explicitly:
- Day 0 excluded. For 14 days: May 1 excluded, day 1 May 2, day 14 May 15.
- For 28 days: May 29.
- For 30 days original: May 31 Sunday -> June 1 Monday.
- For 30 days after July10: July 10 excluded, day1 July11, day30 Aug9 Sunday -> Aug10 Monday.
Need maybe note if last day holiday: shift. For May 29 Friday, May 15 Friday. If court closed? not specified.

Need maybe include "Electronic filing timely by 11:59 p.m. local court time on deadline".

Need maybe include "Consequences missing each separate deadline":
1. Fee motion deadline May15: missing = fee claim untimely; cannot recover attorney fees (assuming no other statutory/order exception). Could also mean no basis to appeal fee denial? If denied as untimely, no fees. Maybe if not filed, no fee award. It does not affect merits appeal.
2. Rule1 motion deadline May29: missing = no timely post-trial motion; no tolling of appeal; interest/new-trial relief unavailable (or motion denied as untimely; court may not extend). Must appeal original judgment by June1 if wanting appellate review; cannot rely on July10 decision to extend. Also if issue not raised in timely post-trial motion, appellate review may be limited/forfeited? But rule says motion must be filed to alter/new trial. The exact consequence: lose right to seek that post-trial relief and lose tolling. Need maybe if the planned motion is not timely, it cannot be the "timely rule-1 motion" that tolls, even if court decides July10. The appeal period remains original.
3. Original NOA deadline June1 if no tolling: missing = no appeal from May1 judgment; judgment becomes final and unreviewable (ordinary appeal lost). If a timely rule1 motion pending, the original deadline is tolled; but if no timely motion, missing loses appeal.
4. New NOA deadline Aug10 (if timely rule1 motion decided July10): missing = no appeal from final judgment/order disposing rule1 motion; final. Also if fee motion pending? No toll; missing NOA loses merits appeal. Fee appeal? If fee motion decided later? Maybe if fees are part of final judgment? But rule says fee motion doesn't toll merits appeal. Could appeal fees separately? Not specified. Need not.
5. Maybe May8 local reconsideration deadline? It was filed timely. If not filed by May11, lose local reconsideration of evidentiary ruling. But it was filed. Could mention it does not toll and is separate. The question asks determine whether May8 motion tolls anything. Could mention its deadline was May11? Local motion within 10 days. It was filed May8, so timely. But no toll. If it had not been timely, no local reconsideration? But no need? It asks exact consequence missing each separate deadline. Separate deadlines include fee, rule1, original NOA, new NOA. May8 is not a deadline to meet now (already filed). But maybe include local reconsideration deadline May11 and consequence missing: lose local reconsideration; no toll anyway. But assignment doesn't explicitly ask calculate local deadline, but asks determine whether May8 motion tolls anything. Could mention it was within 10-day local deadline (May11) but its consequence is no toll. Missing it would forfeit local reconsideration only.

Need maybe address "The client asks whether the May 8 motion already tolled the appeal clock" -> No. "whether the fee motion can wait until the merits motion is decided" -> No. "and when the notice of appeal will be due if the planned post-trial motion is timely filed and denied on July 10" -> August 10, 2026.

Need maybe produce final as a plan: "Do this now/in order". Since dates in 2026 future? The current date in conversation? System date 2026? Current date is 2026? Actually system current date 2026? It says current date? The user question uses 2026. We should not say "today" unless known. We can phrase "Assuming the filings have not yet been made". The plan should be ordered: 1) File fee motion by May15. 2) File rule1 motion by May29. 3) If rule1 motion not timely, file NOA by June1. 4) If timely and decided July10, file NOA by Aug10. 5) Do not rely on May8. Maybe if fee and rule1 motions can be filed simultaneously? Fee by May15, rule1 by May29. Need maybe if rule1 motion filed before May15 and includes fee? No, better separate.

Need maybe include "The May 8 motion does not alter judgment and does not toll appeal; it is not a rule-1 motion because it only asks reconsideration of evidentiary ruling. Its substance does not request new trial/alter amend. Even if titled wrong, substance controls; here substance lacks rule1 relief."

Need maybe mention "A premature notice of appeal filed after judgment but before disposition of a timely rule1 motion becomes effective upon disposition, but a proper later notice is safer. Therefore, if the rule1 motion is timely filed and pending, do not treat a pre-disposition notice as required; file after the July10 order by Aug10. If you want extra protection, you may file a protective notice after judgment but before disposition, but it is not necessary and could create complexity; the safer course is after." Need be careful: If you file premature before disposition, it becomes effective upon disposition. But if it becomes effective upon disposition, is it timely? It likely is, but later safer. Maybe the answer: "If a rule-1 motion has been timely filed, a notice may be filed before disposition as a protective measure; it will become effective on July 10. However, the cleanest and safest plan is to file a proper notice after disposition, by August 10. Do not rely solely on a premature notice if you can wait." The question says "States whether a notice should be filed before or after disposition." We can say "After disposition is the recommended/safer; before is permissible only as protective and becomes effective upon disposition." Maybe they expect "after" because rule says safer. Need phrase clearly: "File after the court disposes of the timely rule-1 motion—no later than August 10—rather than before." But also note premature is allowed.

Need maybe consider if the fee motion must be filed before the rule1 motion? Fee deadline May15, rule1 May29. So fee first. Need maybe if fee motion filed by May15 but decided after July10, does it affect NOA? No. If fee motion is a "post-trial motion" that is not rule1, it does not toll. So no.

Need maybe mention "last timely rule-1 motion" if there are multiple. If the planned motion is the only timely rule1, its disposition July10 controls. If another timely rule1 motion is filed later (by May29) and decided after July10, that later disposition controls. The May8 motion not counted. Need maybe if fee motion is also a motion to alter/amend? If it requests fees as part of judgment? But rule3 separate. Could be counted? No.

Need maybe mention "Judgment entered May 1, 2026. The oral ruling on prejudgment interest omitted from judgment; to correct on direct appeal, may need motion to alter/amend. If not timely, appeal from original judgment; but interest omission may be plain error? Not under assumed rules. We stick to rules.

Need maybe include "No extension for rule1 deadline." So if May29 missed, no later motion can toll. The court may not extend. This is critical.

Need maybe include "The fee deadline may be subject to statute providing otherwise; facts say no special fee deadline ordered, so 14-day rule applies. If the fee-shifting statute itself imposes a longer or different deadline, follow it; under given facts, assume 14 days." The prompt: "The fee-shifting statute applies, and no special fee deadline was ordered." The rule says unless statute or order provides otherwise. If the fee-shifting statute applies but no special deadline ordered, does the statute provide otherwise? It could be that the fee-shifting statute has its own deadline (e.g., 30 days under §1988? Actually under 42 USC 1988 no specific deadline, court discretion). But prompt likely expects 14 days because no special deadline. Need maybe note assumption: Because no statute or order is specified to extend the fee deadline, use the 14-day rule. If the fee statute itself supplies a different deadline, that would control. But facts say fee-shifting statute applies and no special fee deadline ordered, so 14 days.

Need maybe check if attorney fees motion "must be filed no later than 14 calendar days after entry of judgment unless a statute or order provides otherwise." If the fee-shifting statute applies, could that itself "provide otherwise"? It doesn't specify. The facts: "The fee-shifting statute applies, and no special fee deadline was ordered." So no. Good.

Need maybe include "May 8 motion filed by former counsel." If client has current counsel, need maybe file fee motion and rule1 motion by current counsel. Need maybe if former counsel filed May8 without authority? Not relevant. But maybe if current counsel not of record? Not given. We can ignore.

Need maybe include "The witness exclusion: To seek new trial based on it, the rule1 motion must request a new trial (or rehearing/retrial) and state grounds. The May8 motion only asks reconsideration; not enough. The planned motion should expressly ask for a new trial or, in the alternative, amendment; if it only asks the court to reconsider the evidentiary ruling, it may again fail to toll." Good.

Need maybe include "If the planned motion is filed timely but the court denies it on July10, the denial order is the trigger. If the court grants it and enters amended judgment, that order also triggers 30 days. If the court issues an order that does not finally dispose (e.g., takes under advisement? no, expected decision), appeal period not start. If it issues interlocutory order? Not specified. We can say recalc from actual entry of order disposing last timely rule1 motion."

Need maybe include "If the court's July10 order is not the last timely rule1 motion because another timely rule1 motion remains, the 30 days starts after that later motion's disposition." Good for completeness.

Need maybe include "If the motion is filed on May29 and the court rules before July10, use actual disposition date." Good.

Need maybe include "Original notice deadline if no tolling motion is filed: if no timely rule1 motion, 30 days from judgment, May31 -> June1. If a timely rule1 motion is filed, original deadline is tolled; no NOA due by June1. If a premature NOA filed before disposition, it becomes effective upon disposition." Need maybe if fee motion filed does not toll, so original deadline still June1 if no rule1. Good.

Need maybe consider "notice of appeal must be filed within 30 days after entry of judgment unless rule2 tolls the period." If rule1 motion timely filed, the 30-day period is tolled from when filed until disposition? The rule says "A timely motion under rule 1 tolls the time to appeal. A new 30-day appeal period begins when the court enters the order disposing of the last timely rule-1 motion." This means the original 30-day period is tolled; new period begins after disposition. It does not say the original period expires if motion pending. So no NOA due June1 if timely motion filed. Good.

Potential nuance: The May 8 motion is a "local motion for reconsideration of an interlocutory evidentiary ruling" filed within 10 days. Does it toll the time to appeal? Rule4 says does not alter judgment and does not toll appeal period. It might toll the 30-day period under some rules? No. So no.

Potential nuance: A motion to alter/amend judgment to add prejudgment interest: Is that a "motion for a new trial or to alter or amend the judgment"? Yes. Does the 28-day deadline run from entry of judgment even if interest was orally ruled? Yes. Need file by May29. If the court orally ruled interest recoverable but judgment omitted, a motion to alter/amend is proper. If not filed, maybe appeal can raise omission? But no toll.

Potential nuance: "Judgment was entered on May 1, 2026. Marisol wants prejudgment interest corrected, attorney fees sought, and an adverse evidentiary ruling appealed." If she wants appeal evidentiary ruling, she needs to file NOA from final judgment. If she files a rule1 motion for new trial based on witness exclusion, and it is denied, she can appeal both. If she only wants to appeal evidentiary ruling, maybe a motion to reconsider interlocutory ruling not enough; need final judgment. Good.

Need maybe produce final in legal memo style. Use headings: Short answers, calculations, preservation plan, consequences. The user asks "Provide an ordered preservation plan that: ..." We can answer with bullet list/table. Need be precise.

Let's draft final. Need maybe include date calculations. Let's think of exact phrasing for consequences:

- Missing fee motion deadline: "The fee claim is untimely; absent an applicable statutory deadline or court order extending it, the client cannot recover the $185,000 in fees (or any fees) on that claim, and a late fee motion will be denied or treated as waived. This does not stop an appeal of the merits, but it leaves the fee claim unpreserved/lost." Could "exact consequence" maybe "loss of the fee award". Good.

- Missing rule1 motion deadline: "No tolling occurs; the 30-day appeal clock remains running from judgment. The client loses the opportunity to seek a new trial or alteration/amendment by post-trial motion (court may not extend), and any post-June 1 appeal from the merits is lost if no NOA filed. If the court later decides a late motion on July 10, that decision does not start a new appeal period because the motion was not timely." Good.

- Missing original NOA deadline: "Loss of right to appeal the May 1 judgment; the judgment becomes final and unreviewable on ordinary direct appeal. The May 8 motion and any late rule1 motion do not save the appeal." Good.

- Missing new NOA deadline: "Loss of right to appeal the final judgment/order disposing the timely rule1 motion; no appellate review of the interest correction, new trial, or evidentiary exclusion on that appeal." Good.

- Maybe missing local reconsideration deadline (May11): "Loss of local reconsideration of witness exclusion, but no tolling; appeal from final judgment may still be possible if preserved and NOA filed." But May8 already filed. Could include in table.

Need maybe include "If the planned rule-1 motion is timely filed and denied July 10, the notice of appeal is due August 10, 2026." The client asks when. Need highlight.

Need maybe include "Do not wait until July 10 to file fee motion." Good.

Let's ensure date calculations with excluded day:

Fee: 14 days after May1: Day 0 May1 excluded. Days:
1 May2 Sat
2 May3 Sun
3 May4 Mon
4 May5 Tue
5 May6 Wed
6 May7 Thu
7 May8 Fri
8 May9 Sat
9 May10 Sun
10 May11 Mon
11 May12 Tue
12 May13 Wed
13 May14 Thu
14 May15 Fri. Yes.

Rule1: 28 days:
1 May2
...
14 May15
15 May16 Sat
16 May17 Sun
17 May18 Mon
18 May19 Tue
19 May20 Wed
20 May21 Thu
21 May22 Fri
22 May23 Sat
23 May24 Sun
24 May25 Mon
25 May26 Tue
26 May27 Wed
27 May28 Thu
28 May29 Fri. Good.

Original NOA: 30 days:
1 May2
...
14 May15
15 May16
16 May17
17 May18
18 May19
19 May20
20 May21
21 May22
22 May23
23 May24
24 May25
25 May26
26 May27
27 May28
28 May29
29 May30 Sat
30 May31 Sun -> June1 Mon.

New NOA after July10:
1 Jul11 Sat
2 Jul12 Sun
3 Jul13 Mon
4 Jul14 Tue
5 Jul15 Wed
6 Jul16 Thu
7 Jul17 Fri
8 Jul18 Sat
9 Jul19 Sun
10 Jul20 Mon
11 Jul21 Tue
12 Jul22 Wed
13 Jul23 Thu
14 Jul24 Fri
15 Jul25 Sat
16 Jul26 Sun
17 Jul27 Mon
18 Jul28 Tue
19 Jul29 Wed
20 Jul30 Thu
21 Jul31 Fri
22 Aug1 Sat
23 Aug2 Sun
24 Aug3 Mon
25 Aug4 Tue
26 Aug5 Wed
27 Aug6 Thu
28 Aug7 Fri
29 Aug8 Sat
30 Aug9 Sun -> Aug10 Mon.

Need maybe note if August 10 is a court holiday? Not specified. If holiday, next open. But likely open.

Potential issue: Rule 6 says if last day falls Saturday/Sunday/court holiday, deadline moves to next day clerk's office is open. For fee deadline May15 Friday, no shift. Rule1 May29 Friday, no shift. Original NOA May31 Sunday -> June1. New NOA Aug9 Sunday -> Aug10.

Need maybe include "Electronic filing by 11:59 p.m. local court time". For all deadlines.

Need maybe include "Day counting: the day judgment was entered is not counted." Good.

Potential nuance: If the rule1 motion is filed on May29, does it toll from May29 until disposition? Yes. But what if the court's order disposing is July10, and the motion was filed May29. The original 30 days would have expired June1, but tolling saves it. Good.

Potential nuance: If the planned rule1 motion is filed on May29 but the court decides July10, and the fee motion was filed May15 but not decided until after Aug10? Does fee motion toll appeal from merits? No. If fees are awarded later as a separate judgment, maybe separate appeal? But not needed.

Potential nuance: If the planned rule1 motion is filed by May29 and is "in the alternative" new trial, does the motion toll even if it also requests interest? Yes, if timely and seeks rule1 relief. If it is a single motion with multiple rule1 requests, it is a timely rule1 motion. The last timely rule1 motion is that one.

Potential nuance: If the May8 motion is within 28 days and asks reconsideration of evidentiary ruling, could its substance request "new trial" implicitly? It asks only trial judge reconsider witness exclusion. Does that inherently request new trial? Not if it does not request alteration/new trial. Rule8 says substance requests relief available under rule1. Reconsideration of evidentiary ruling is not available under rule1? It is local. So no. Good.

Potential nuance: "A local motion for reconsideration of an interlocutory evidentiary ruling may be filed within 10 days, but it does not alter the judgment and does not toll the appeal period." It might still be a post-trial motion? No.

Potential nuance: "A notice of appeal must be filed within 30 calendar days after entry of judgment unless rule 2 tolls the period. A premature notice filed after judgment but before disposition of a timely rule-1 motion becomes effective upon disposition, but filing a proper later notice is safer." If a timely rule1 motion is filed, the original NOA deadline is tolled, so no need to file before disposition. If you file a premature notice, it becomes effective upon disposition. But if it becomes effective upon disposition, does it need to be within 30 days of disposition? It likely is, because it was filed after judgment and before disposition, and becomes effective on disposition. But "proper later notice is safer". We can say: "If you file before disposition, it is treated as effective on July10, but the safest course is to wait and file a proper notice after disposition, by Aug10." That answers.

Need maybe mention "If the rule1 motion is timely filed but not yet decided, the original deadline is tolled; a notice filed before disposition is not necessary to preserve appeal, but can be protective." Good.

Need maybe include "If the rule1 motion is not filed, the May8 motion does not toll, so NOA by June1. If you miss June1, no appeal." Good.

Need maybe include "If fee motion is missed, can you appeal fee denial?" If not filed, no fee claim. If filed untimely and denied, could maybe appeal? But rule says must file; likely no. We can say "The exact consequence under the given rules is that the fee claim is not timely and is lost; it does not create a tolling event."

Need maybe include "The fee motion does not toll the appeal; therefore, even if a timely fee motion is filed May15 and remains pending, the NOA deadline is governed by judgment and any timely rule1 motion, not the fee motion." Good.

Need maybe include "The planned rule1 motion should be filed before the fee motion?" No, fee earlier. But if time urgent, file fee first. The ordered plan:
1. Immediately file attorney-fee motion (by May15) to preserve fees.
2. By May29, file a timely rule1 motion with explicit requests: alter/amend to add $42k interest; alternatively new trial on witness exclusion; state grounds. This is necessary to toll.
3. Do not rely on May8 motion. It is a local reconsideration only; no toll.
4. If no timely rule1 motion, file NOA by June1.
5. If timely rule1 motion filed and denied July10, file NOA by Aug10. Best to file after disposition; premature before disposition optional but less safe.

Need maybe include "If the court's decision is not July10, recalc: 30 days after actual entry, excluding decision date, with weekend/holiday shift." Good.

Need maybe include "If there is a later timely rule1 motion, the last one controls." Good.

Need maybe include "If the planned motion is filed on May29 and the court issues a final order denying it on July10, the notice of appeal should be filed after July10, by Aug10. If you filed a notice before July10, it becomes effective July10; but a later notice is safer." Good.

Potential issue: The rule1 motion deadline is 28 days after entry of judgment, but "The court may not extend that deadline." If the last day is Friday, no shift. If it were weekend, move. Good.

Potential issue: The fee motion deadline: "unless a statute or order provides otherwise". The fee-shifting statute applies. Could there be a statute that says fee motions must be filed within 30 days? The facts say no special fee deadline ordered. But "fee-shifting statute applies" might itself provide otherwise? We need maybe state: "Under the stated facts, no special statutory or court deadline is specified, so the 14-day rule controls." Good.

Need maybe include "Marisol is plaintiff; judgment in her favor. She wants prejudgment interest corrected. If she appeals, she may be appealing to add interest? Usually winner appeals to get interest? Could be cross-appeal? Not relevant. She filed rule1 to alter. If denied, appeal from denial. Good.

Need maybe include "The adverse evidentiary ruling: To appeal it, it must be included in the notice of appeal from the final judgment. The NOA should expressly include the May1 judgment and the July10 order, and the issues: omission of prejudgment interest, exclusion of witness, attorney fees if denied?" Maybe good. The plan: file NOA after disposition that includes all orders: judgment, rule1 order, fee order if final? Need maybe if fee motion decided before NOA, include fee order. If fee motion pending, cannot appeal until final? The prompt only asks merits judgment and adverse evidentiary ruling. But we can recommend NOA include the judgment and the order denying the rule1 motion (and any fee order if final) to preserve. But under rule, notice of appeal from final judgment; if fee motion pending, not final. Not necessary. But ordered preservation plan could include content: NOA should identify all orders and issues. Good.

Need maybe include "The May8 motion does not need to be included in NOA? It may be part of record. But the appeal should be from final judgment and post-trial order." Good.

Need maybe think about whether a motion for attorney fees that is timely filed can be a "timely rule-1 motion" if it requests altering judgment to add fees? The rule3 says fee motion does not toll appeal from merits judgment. But if it is also a motion to alter/amend? The rule1 says motion for new trial or alter/amend judgment. If a motion for attorney fees is a motion to alter/amend? It might be. But rule3 specifically says an attorney-fee motion does not toll time to appeal from the merits judgment. So even if it's a motion to alter, it doesn't toll? The rule says "A motion for attorney fees must be filed no later than 14 days... An attorney-fee motion does not toll the time to appeal from the merits judgment." So no. Good.

Need maybe consider if the May8 motion, filed 7 days after judgment, could be a "motion to alter or amend" by substance because it asks judge reconsider exclusion that led to judgment? It asks only reconsider evidentiary ruling. Does that inherently seek alteration of judgment? Not necessarily; it could ask for new hearing? But facts explicitly: It does not request alteration of the judgment, a new trial, or any other rule-1 relief. So no.

Need maybe mention "The May8 motion is timely under the 10-day local rule (May 11 deadline), but timeliness of that local motion does not convert it into a rule-1 motion." Good.

Need maybe include "If the current counsel files the planned motion on or before May29, the May8 motion's lack of tolling is cured by the new timely rule1 motion." Good.

Need maybe include "If the planned motion is not filed by May29, do not file a late rule1 motion and wait for July10; file NOA by June1. A late motion cannot toll." Good.

Need maybe include "If the planned motion is filed on May29 and the court decides on July10, the appeal deadline is Aug10, not June1. If you also filed a premature notice before July10, it becomes effective July10, but still file proper later notice by Aug10 to be safe." Good.

Need maybe include "All e-filings by 11:59 p.m. local court time." Good.

Let's think of possible hidden traps: The date of judgment Friday May 1, 2026. Day excluded. If the 28-day deadline falls on Saturday? No, May29 Friday. 30-day original falls May31 Sunday, moves to Monday June1. 30-day after July10 falls Aug9 Sunday, moves Aug10. Good.

Could there be a federal holiday on Monday June1? Not generally. Monday Aug10 no. Could local court holiday? Not specified. We can say "assuming no court holiday; if one occurs, shift to next open day." Good.

Could there be a "long weekend" where May31 Sunday -> June1 Monday, but if June1 is a court holiday (e.g., local holiday), shift to Tuesday. Not specified. We'll note.

Could there be a nuance about "calendar days" vs "days" and "last day falls on Saturday, Sunday, or court holiday" for the 28-day motion: If deadline May29 Friday, fine. If electronic filing by 11:59. Good.

Could there be a nuance about "triggering event" for rule1 motion tolling: The motion must be filed; the new 30-day period begins when order disposing last timely rule1 motion entered. It doesn't say the filing date of motion matters for appeal deadline except timeliness. So if motion filed May29 and denied July10, new period 30 days after July10. Good.

Could there be a nuance about "original notice-of-appeal deadline if no tolling motion is filed" if the May8 motion is filed but does not toll? If no tolling motion under rule1, the original 30-day deadline is June1. The May8 local motion does not toll. Good.

Could there be a nuance about "fee motion can wait until merits motion is decided" if fee motion does not toll appeal and has 14-day deadline. No. It cannot wait. It must be filed by May15. If filed after May15 but before July10, it is untimely. If the fee-shifting statute provides otherwise? Not in facts. Good.

Could there be a nuance about "motion for a new trial or to alter or amend the judgment must be filed no later than 28 days after entry of judgment. The court may not extend that deadline." If the planned motion is filed after May29, even if court expected July10, no toll. The consequence: lose post-trial relief and tolling. Good.

Could there be a nuance about "A post-trial motion must identify requested relief and grounds. Filing a document under the wrong label does not toll unless its substance requests relief available under rule 1 and it is timely." The planned motion must not merely say "reconsider" or "motion for reconsideration"; it must request "alter or amend judgment" and "new trial". It must state grounds: oral ruling on prejudgment interest omitted; erroneous witness exclusion. Good.

Could there be a nuance about "The May 8 motion asks only that trial judge reconsider the witness exclusion. It does not request alteration of judgment, new trial, or any other rule-1 relief." It is a local motion for reconsideration of interlocutory evidentiary ruling within 10 days. It doesn't alter judgment and doesn't toll. But does it preserve the evidentiary issue for appeal? Maybe if filed timely local, yes? But not toll. The question only asks tolling. We can say "It may preserve the local issue or be part of the record, but it does not start/toll the appeal clock." Need not assert preservation if not given. Better: "It does not toll; its only effect is the local reconsideration request." Good.

Could there be a nuance about "The client asks whether the May 8 motion already tolled the appeal clock" Answer: No. But if it was filed within 28 days and substance? It doesn't request rule1 relief, so no. Good.

Could there be a nuance about "whether the fee motion can wait until the merits motion is decided" Answer: No; deadline May15; it does not toll appeal; waiting until July10 would be late. Good.

Could there be a nuance about "when the notice of appeal will be due if the planned post-trial motion is timely filed and denied on July 10" Answer: Aug10, 2026. Good.

Need maybe include "If the planned motion is timely filed but granted on July10, new judgment/order, the NOA due Aug10 as well (if appeal from that order). If the client no longer needs appeal because interest corrected? But maybe still wants fees/evidentiary? The plan can note if judgment is corrected, may not need appeal, but if any issue remains, deadline still Aug10. The question assumes denied. But we can mention "if denied or otherwise disposed of." Good.

Need maybe include "If the fee motion is decided separately after Aug10, an appeal of fee denial may have its own deadline; not part of given rules." Not necessary but could be useful. But don't introduce uncertainty. Maybe state "The fee motion does not toll the merits appeal; any fee appeal would be a separate matter not governed by the stated tolling rules." But the prompt doesn't ask. Could omit.

Need maybe include "The exact consequence of missing the May8 local reconsideration deadline" It was filed, but maybe include for completeness: local motion deadline May11; missing = lose local reconsideration; no toll. But the assignment asks "Identifies the exact consequence of missing each separate deadline." The separate deadlines include maybe May8? It was already filed; but to be safe, include a row: Local reconsideration (May 11 deadline; filed May 8): consequence of missing would be loss of local reconsideration, but no tolling in any event. Since it's already filed, not actionable. Good.

Need maybe format as:

**Assumptions**: No court holidays on indicated days; e-filing; judgment May 1; no special fee deadline.

**Direct answers**:
- May8 motion: no toll.
- Fee motion can't wait: due May15.
- If timely rule1 motion decided July10: NOA due Aug10.

**Deadline sequence**:
1. May 1, 2026: judgment entered (day 0 excluded).
2. By May 11, 2026: local reconsideration deadline; May8 timely but no toll.
3. By May 15, 2026: attorney-fee motion. Content. Consequence.
4. By May 29, 2026: rule1 motion. Content. Consequence.
5. If no timely rule1 motion: NOA by June 1, 2026. Consequence.
6. If timely rule1 motion decided July10: NOA by Aug10, 2026. Consequence.
7. Before/after disposition: after (safest), premature optional.

Maybe include a table:

Deadline | What to file | Calculation | Consequence if missed

Need ensure "ordered preservation plan" means order of actions. We can present in chronological order and action items.

Need maybe include "If the planned rule1 motion is not filed by May29, do not wait for July10; file NOA by June1 to preserve appeal. The July10 order will not create a new appeal period because the motion was not timely." Good.

Need maybe include "If the planned rule1 motion is filed by May29, the original June1 deadline is tolled. You do not need to file NOA by June1. But if you want a protective notice, you may file one after judgment and before July10; it becomes effective July10. However, safest is to file after July10 by Aug10." Good.

Need maybe include "The NOA should be filed electronically by 11:59 p.m. on Aug10 (or next open day if holiday)." Good.

Need maybe include "The notice of appeal should include the final judgment and the order denying the rule1 motion; if a fee order is final, include it if appealing fees." Good.

Potential issue: The rule says "A notice of appeal must be filed within 30 calendar days after entry of judgment unless rule 2 tolls the period." If a timely rule1 motion is filed, the appeal period is tolled, and a new 30-day period begins when the court disposes of last timely rule1 motion. So if the motion is timely filed but not yet disposed, is the notice deadline "suspended" or "tolled"? Yes. So no NOA due June1. Good.

Potential issue: "A premature notice filed after judgment but before disposition of a timely rule-1 motion becomes effective upon disposition, but filing a proper later notice is safer." If a timely rule1 motion is filed, and you file a notice before disposition, does it become effective upon disposition and therefore the 30-day period starts from that effective date? It says new 30-day period begins when court enters order disposing. So yes. The premature notice is effective then, so it is timely? It becomes effective at the beginning of the period? That seems odd, but the rule says so. We can just state as given.

Need maybe include "If the planned rule1 motion is filed timely but the court's disposition is later than July10, recalculate 30 days from actual disposition; do not use July10 if not actual." Good.

Need maybe include "If there is a cross-appeal or notice from other parties, not relevant." No.

Need maybe include "The motion to alter or amend to add interest is separate from attorney fee motion. Do not combine in a way that makes fee request after May15. If the rule1 motion is filed before May15 and includes a fee request, it might satisfy fee deadline? But planned motion likely by May29. To avoid risk, file fee motion separately by May15." Good.

Need maybe include "If the court has ordered otherwise? No." Good.

Let's consider if there is any need to mention Rule 54, 59, 50 etc? No, assumed rules.

Need maybe produce final answer in a way that is clear and authoritative. We can start with "Bottom line". Then calculations. Then plan. Then consequences. The desired oververbosity 9, so detailed. But not too long? User asks a complex legal calculation; thorough is good. We can include all. Need avoid unnecessary speculation. But can include caveats.

Let's draft final in sections:

1. Bottom line / answers to client's questions.
2. Date mechanics.
3. Ordered preservation plan with table.
4. Consequences of missing each deadline.
5. Recommended filings/notice strategy.

Let's formulate:

**Bottom line**:
- May 8 motion: no tolling. It is a local 10-day reconsideration only; no rule1 relief.
- Fee motion: cannot wait; due May 15, 2026.
- Rule1 motion: must be filed by May 29, 2026, expressly requesting alter/amend judgment to add $42,000 prejudgment interest and, in alternative, new trial based on witness exclusion.
- If no timely rule1 motion: NOA due June 1, 2026 (May31 Sunday shifts to Monday).
- If timely rule1 motion filed and denied July10: NOA due August 10, 2026 (Aug9 Sunday shifts to Monday).
- Safest: file NOA after disposition, by Aug10. A premature notice before disposition is permitted and becomes effective upon disposition, but a proper later notice is safer.

**Calculations**:
Use table:
- Fee: May1 excluded; 14th day May15 Friday.
- Rule1: 28th day May29 Friday.
- Original NOA: 30th day May31 Sunday -> June1 Monday.
- New NOA: July10 excluded; 30th day Aug9 Sunday -> Aug10 Monday.

**May8 motion**:
- Local motion deadline was 10 days after judgment: May11 (Monday). Filed May8, timely. But rule4: does not toll. Rule8: substance must request rule1 relief; it does not. Therefore no tolling. It does not alter judgment. It may be relevant to preservation of issue but does not start appeal clock.

**Planned rule1 motion**:
- Must be filed by May29. Must identify relief: (1) alter/amend to add $42k interest; (2) alternatively grant new trial/retrial due to erroneous exclusion; state grounds. If it only says "reconsider evidentiary ruling" or does not request judgment alteration/new trial, it won't toll. A timely motion under this rule tolls even if alternative. If filed after May29, court may not extend; no toll.

**Fee motion**:
- Must be filed by May15. It can be separate. It does not toll appeal. Waiting until July10 = late; fee claim lost. It may be pending while rule1 motion decided.

**Notice strategy**:
- If no timely rule1 motion: file NOA by June1.
- If timely rule1 motion filed: original period tolled. Do not file NOA by June1 unless as protective. After July10 order, file by Aug10. Premature notice filed before disposition becomes effective upon disposition; but safer to wait. If you file premature, still ensure a proper later notice? The rule says later safer. We can say "If you file a premature notice, do not rely on it if there is any doubt; file a proper notice after disposition." Good.

**Consequences table**:
- Miss fee May15: fee claim untimely; no award; cannot recover fees; no tolling.
- Miss rule1 May29: no post-trial relief; no tolling; if no NOA by June1, lose appeal. Late July10 decision does not extend.
- Miss original NOA June1 (if no tolling): lose appeal from May1 judgment; final.
- Miss new NOA Aug10: lose appeal from final disposition; final.
- Miss local May11 (not at issue): lose local reconsideration; no toll anyway.

Need maybe include "If the court's July10 order is the last timely rule1 motion". If another timely rule1 motion is filed, the last disposition controls. The fee motion not. The May8 not. Good.

Need maybe include "If the planned motion is timely filed and the court decides on July10, the deadline is Aug10. If the court decides earlier, recalc; if later, recalc." Good.

Let's consider if there is any possibility that the 28-day deadline for rule1 motion is from "entry of judgment" and if the judgment was orally pronounced earlier? Facts: clerk entered judgment May1. Use entry. Good.

Need maybe include "All deadlines are calendar days, not business days." Good.

Need maybe include "The day of entry (May1) is excluded." Good.

Potential issue: If the fee motion deadline is May15, and the rule1 motion deadline is May29, could filing the rule1 motion by May29 also serve as a motion to alter judgment to add attorney fees, thereby preserving fees? Rule3 says attorney-fee motion must be filed by 14 days. If the rule1 motion requests attorney fees and is filed May29, that's 28 days, likely late under rule3. So separate fee motion by May15. Good.

Potential issue: If the fee-shifting statute applies, maybe the fee motion deadline is not 14 days if statute provides otherwise. But facts: no special fee deadline ordered. We can phrase: "Under the stated assumption that no statute or order changes the deadline, the 14-day rule controls. If the applicable fee statute itself imposes a different deadline, that statute would control; none is specified." Good.

Potential issue: The prompt says "A motion for attorney fees must be filed no later than 14 calendar days after entry of judgment unless a statute or order provides otherwise." It also says "The fee-shifting statute applies, and no special fee deadline was ordered." Could one argue the statute itself "provides otherwise" just by applying? No, unless it contains deadline. We can assume not.

Need maybe include "Counsel estimates recoverable fees of $185,000" not needed for deadline, but can mention in fee motion request. Good.

Potential issue: "Marisol wants prejudgment interest corrected, attorney fees sought, and an adverse evidentiary ruling appealed." The planned rule1 motion includes interest and new trial. But if she only wants to appeal evidentiary ruling, not necessarily seek new trial? The rule1 motion to new trial based on witness exclusion is necessary to preserve and toll. If she files only appeal? You can't appeal before final? The evidentiary ruling is interlocutory, but part of final judgment. To get new 30-day period, need rule1 motion. If she doesn't file rule1, original NOA due June1. If she files rule1 including new trial, tolls. Good.

Potential issue: If the planned rule1 motion is timely filed but the court denies it on July10, does the denial order "dispose of the last timely rule-1 motion"? Yes. If the motion is denied without prejudice to refile? Maybe not final? The rule says order disposing. If denied, final. Good.

Potential issue: If the court grants the motion and amends judgment, the new judgment might be appealable. The 30-day period starts from order. Good.

Potential issue: "A premature notice filed after judgment but before disposition of a timely rule-1 motion becomes effective upon disposition" Could mean if you file NOA before July10, it becomes effective July10, so the 30-day period runs from July10 and you have until Aug10? But if it becomes effective July10, is it filed within 30 days of July10? It is effective on day 0? Maybe the rule treats it as timely if filed before disposition. But we can say "It is a protective option; the cleanest is to file after." Good.

Need maybe include "Do not file a notice of appeal before judgment? It's premature; but here after judgment. The prompt says after judgment but before disposition." Good.

Let's think if there is any issue with "original notice-of-appeal deadline if no tolling motion is filed" when a fee motion is filed. Since fee motion does not toll, original deadline still June1. Good.

Need maybe include "If a timely rule1 motion is filed, the original 30-day period is tolled from the filing of the motion until disposition? The rule says tolls time to appeal; new period begins at disposition. It does not require adding the time before motion. So no need to count any remaining days before filing. If motion filed May29, original period would have been tolled before expiration. Good.

Need maybe include "If the motion is filed on May29, the tolling is effective from May29; the original period is suspended. If the court does not dispose until July10, the new period is 30 days from July10." Good.

Need maybe include "If the planned motion is filed on May29 but the court rules on July10, and you file a notice on June1, is that allowed? It would be premature; it becomes effective July10. But later safer. You could file a protective notice June1, but not necessary." Good.

Need maybe include "If the planned motion is filed timely and the court's order is entered July10, but the clerk's office is closed July10? It says court expected to decide on Friday July10. If order entered but clerk closed? The triggering event is entry of order; if entered after office closed? Not relevant. E-filing deadlines. Good.

Potential hidden trap: The local motion for reconsideration of interlocutory evidentiary ruling may be filed within 10 days. It was filed May8. Does it toll the time to appeal? Rule4 says no. But could it be a "motion for a new trial" because reconsideration of witness exclusion could require new trial? The facts say it does not request new trial. So no.

Potential hidden trap: "Filing a document under the wrong label does not toll unless its substance requests relief available under rule 1 and it is timely." The May8 document is titled "Motion to Reconsider Evidentiary Ruling" but asks only reconsideration. Wrong label? It is correctly local. Not toll.

Potential hidden trap: "A motion for a new trial or to alter or amend the judgment must be filed no later than 28 calendar days after entry of judgment. The court may not extend that deadline." If the planned motion is filed by May29, but it includes a request for attorney fees (which is not rule1? maybe relief not available under rule1? It's not a new trial/alter amend? Attorney fees could be part of judgment? But not necessary. It also includes interest and new trial. The presence of an improper fee request after May15 doesn't necessarily defeat the valid rule1 relief. But to be safe, file fee separately. If the rule1 motion includes a late fee request, that part is untimely, but the rule1 relief still tolls if timely and requests new trial/alter amend. Good. We can mention: "Do not rely on the rule-1 motion to preserve fees if it is filed after May15." Good.

Potential hidden trap: If the rule1 motion is filed timely and requests new trial, but the court decides on July10, and the fee motion was filed timely May15 but not decided until after Aug10. Does the fee motion being pending mean the "last timely rule1 motion" is not disposed? No, fee motion is not rule1. The appeal period for merits starts after rule1 disposition. If fees are not final, can't appeal fees yet, but merits appeal can proceed. The prompt doesn't ask. We can say "The fee motion does not toll the merits appeal; it is not a rule-1 motion for this purpose." Good.

Potential hidden trap: If the May8 motion is a local motion within 10 days, and the planned rule1 motion is filed by May29, but the May8 motion is still pending and the court disposes of it after July10? Does it matter? It is not rule1, so no. The appeal period for merits is controlled by last timely rule1 motion. The local motion may be interlocutory and not final. Not relevant.

Potential hidden trap: "A new 30-day appeal period begins when the court enters the order disposing of the last timely rule-1 motion." If the planned motion is the only timely rule1, and it is denied July10, new period begins July10. If the court also disposes of the May8 motion on, say, June15, not rule1, doesn't matter. If the fee motion is disposed on Aug1, not rule1, doesn't matter. Good.

Potential hidden trap: "The day of the triggering event is excluded. Every later calendar day is counted." For original NOA, triggering event is entry of judgment May1. We did. For new NOA, triggering event is order disposing July10. We did. For fee/rule1, triggering event is entry judgment. We did. For local, entry judgment. Good.

Potential hidden trap: If deadline moves due to weekend, do we count the moved day as the last day? Yes. We did. If May31 Sunday, deadline June1. If Aug9 Sunday, Aug10. Good.

Potential hidden trap: If a deadline falls on a Saturday, count next business day. For fee May15 Friday, no. For rule1 May29 Friday, no. For original NOA May31 Sunday, June1. For new NOA Aug9 Sunday, Aug10. Good.

Potential hidden trap: Electronic filing by 11:59 p.m. local court time. We can state for each.

Need maybe include "If the clerk's office is closed on the moved day due to holiday, move further." Good.

Let's think about how to phrase "exact consequence" without overclaiming jurisdiction. The rules are assumed; we can state "Under the assumed rules, the exact consequence is..." Good.

Need maybe include "If the fee motion is not filed by May15, the client cannot later seek fees by amending the rule1 motion on May29." Good.

Need maybe include "If the rule1 motion is not filed by May29, the client cannot later file a motion to alter/amend or new trial to toll, and the court cannot extend." Good.

Need maybe include "If the NOA is not filed by the applicable deadline, the appeal is not perfected; the judgment becomes final." Good.

Potential nuance: "A motion for a new trial or to alter or amend the judgment must be filed no later than 28 calendar days after entry of judgment." If the planned motion is filed on May29, and the court denies it July10, the notice of appeal deadline is August10. But what about the 30-day period from the original judgment if the motion was filed after the 30-day period? It was filed before (May29 before June1), so tolling. If it had been filed after June1, no toll. Good.

Potential nuance: If the planned motion is filed on May29, but the court's order disposing is July10, and the client files a notice of appeal on July11 (after disposition but before Aug10), it is timely. Good.

Potential nuance: If the client files a notice of appeal on June1 (after judgment, before disposition), it becomes effective July10. Is that "proper later notice"? It is before disposition, so not later. It may be safe if the rule says it becomes effective upon disposition. But the prompt says later safer. We can say "Do not rely on it as the only step if you can wait; file a proper notice after disposition." Good.

Need maybe include "The notice of appeal should be filed after the order disposing the rule1 motion is entered, not before, to avoid questions about prematurity. If you want a protective filing, file a notice that expressly invokes the tolling rule and becomes effective on disposition, but the recommended plan is after." Good.

Let's consider if we need to cite any real rules? The prompt says assume following rules; no citations needed. We can refer to "Rule 1", "Rule 2", etc. Good.

Potential nuance: "The court may not extend that deadline" for rule1. Does that mean if the last day is a weekend and moved to next open day, that's not an extension but a rule. Yes. We use.

Potential nuance: "A motion for attorney fees must be filed no later than 14 calendar days after entry of judgment unless a statute or order provides otherwise." It doesn't say court may not extend. But if missed, maybe court could extend? The assignment wants exact consequence. Under a mandatory deadline, missing = untimely. We can state "unless a court later has independent discretion under another doctrine, but under the stated rule the motion is untimely." But maybe too hedged. We can say "It is untimely; the fee claim is lost/waived." Good.

Potential nuance: If the fee motion is not filed, can the court award fees sua sponte? Not under rules. Not relevant.

Potential nuance: If the fee motion is filed by May15, does it need to be served? Not specified. We can assume.

Potential nuance: If the planned rule1 motion is filed by May29, does it need to be served? Not specified.

Potential nuance: If the May8 motion was filed by former counsel, current counsel should ensure authority. Not relevant.

Need maybe include "The plan should be executed in this order: fee first, rule1 second, NOA last." Good.

Let's draft final.

Possible final structure:

```
Assumptions: ...

I. Direct answers
- May 8 motion: no.
- Fee motion: no, due May 15.
- NOA if timely rule-1 motion denied July 10: Aug 10, 2026.

II. Date calculations
Table...

III. Ordered preservation plan
1. May 15 fee motion...
2. May 29 rule-1 motion...
3. No-tolling fallback NOA June 1...
4. Post-disposition NOA Aug 10...
5. Notice timing: after disposition...

IV. Consequences of missing each deadline
Table...

V. Checklist / recommended content
```

Need ensure not too repetitive but thorough. The user asked "Provide an ordered preservation plan that: ..." We can make the plan the main answer. Include all bullets.

Let's write in a clear, professional tone. Use bold for dates.

Need maybe include "May 11 local reconsideration deadline" in plan. It was already filed, but include for completeness.

Let's formulate exact calculations:

- "May 1 excluded. Day 1 = May 2."
- "14 days: May 15 (Friday)."
- "28 days: May 29 (Friday)."
- "30 days: May 31 (Sunday) -> June 1 (Monday)."
- "July 10 excluded. Day 1 = July 11. Day 30 = August 9 (Sunday) -> August 10 (Monday)."

Need maybe include "If any of these dates is a court holiday, shift to next open clerk day." Good.

Potential issue: If May 15 is a federal holiday? No. May 25 Memorial Day. Not.

Need maybe include "Electronic filing: 11:59 p.m. local court time on the final day (or next open day if shifted)." Good.

Let's think about "exact consequence of missing each separate deadline" in table:

| Deadline | What is lost |
| May 15 | attorney fee claim; no $185,000 fees; cannot wait until July10. |
| May 29 | right to seek post-trial alteration/new trial; no tolling; if no NOA by June1, lose appeal. |
| June 1 | appeal from May1 judgment; final. |
| Aug 10 | appeal from final order/judgment after rule1 motion; final. |
| May 11 (local, already met) | local reconsideration only; no toll. |

Need maybe specify "If the May 29 deadline is missed, the planned motion filed later cannot be a 'timely rule-1 motion' even if the court decides it on July 10; the July 10 order will not start a new appeal period." Good.

Need maybe specify "If the fee deadline is missed, it does not affect the appeal of the merits, but it means fees are not preserved." Good.

Need maybe specify "If the NOA deadline is missed, the court loses appellate jurisdiction?" Under notice of appeal, failure to file timely generally deprives appellate court of jurisdiction. We can say "ordinary appellate jurisdiction/right to appeal is lost; judgment final." Good.

Potential nuance: If a notice of appeal is filed after the deadline but before the appeal becomes final? No, not timely. Good.

Need maybe mention "A cross-notice or notice by another party may affect? Not given." No.

Let's consider if the answer should mention "The May 8 motion was filed within 10 days (deadline May 11) but does not toll. It may be a 'motion for reconsideration of an interlocutory evidentiary ruling' and does not alter the judgment. It is not a rule-1 motion because it does not request new trial or alteration/amendment. Therefore, the appeal clock was not tolled on May 8." Good.

Need maybe mention "The planned motion must request relief available under rule 1: 'alter or amend the judgment to add $42,000 prejudgment interest' and 'grant a new trial (or, in the alternative, order a retrial on the excluded witness issue)'. It should state grounds: the court's oral ruling on interest and the erroneous exclusion. It should not be styled merely as a motion to reconsider an evidentiary ruling if it does not include those requests." Good.

Need maybe mention "If the motion is filed on May 29, it is timely even though the original appeal deadline would otherwise be June 1. It tolls from filing until disposition." Good.

Need maybe mention "If the planned motion is filed before May 15, it could be before fee deadline, but fee still separate. If filed after May15, fee motion still needed by May15." Good.

Need maybe mention "The fee motion should be filed no later than May15 even if the rule1 motion is expected to be decided July10. It does not toll the merits appeal." Good.

Need maybe mention "The notice of appeal should be filed after the July10 order and before Aug10. If you file a premature notice before July10, it becomes effective July10, but the safer course is to wait. If you do file prematurely, still consider a proper post-disposition notice to eliminate doubt." Good.

Potential nuance: "A premature notice filed after judgment but before disposition of a timely rule-1 motion becomes effective upon disposition" Could mean if you file a notice before disposition, you don't need to file another later; it becomes effective on disposition. But the prompt says later safer. We can say "Either may preserve, but the plan should use the safer later notice." The question asks "States whether a notice should be filed before or after disposition." We can say "After disposition is the recommended plan; before disposition is only a protective option." Good.

Need maybe mention "If the planned rule1 motion is timely filed but the court grants it and fully resolves the case in Marisol's favor, she may not need to appeal. But if any issue remains (fees, exclusion), the same Aug10 deadline applies to appeal the final order." Good but not necessary. Could include as caveat.

Let's think if there is any need to calculate "10 days after judgment" for May8 local motion. The prompt doesn't ask, but it might be useful. We can include: local deadline May11 (Monday). May8 is timely. It doesn't toll. If missing, local reconsideration lost. Good.

Need maybe include "The fee motion deadline is not affected by the May8 motion or the planned rule1 motion." Good.

Need maybe include "The rule1 motion deadline is not affected by the fee motion." Good.

Potential nuance: "The day of the triggering event is excluded" For a motion to be "filed no later than 28 days after entry", does the day of entry excluded? Rule6 says generally. Yes.

Potential nuance: If the judgment was entered by clerk May1, but the oral ruling at trial before judgment? The triggering event is entry. Good.

Potential nuance: If the court expected to decide motion July10, but the motion must be filed by May29. If current date is after May29, the plan fails. But the question likely hypothetical. We can say "Assuming the motion has not yet been filed and there is still time, file by May29. If it has already been filed late, the fallback is NOA by June1." Good.

Need maybe include "If the planned motion has already been filed timely, do nothing more until fee motion? But if after May15, fee late. Hmm. The facts: On May8 former counsel filed local. Current counsel plans to file. It doesn't say current date. We can present plan as of after May1? The assignment likely expects calculations regardless. We can say "If not already filed, the fee motion is urgent; if May15 has passed, fees likely lost unless some extension. The rule1 motion must still be filed by May29 to toll." But since it's a deadline sequence, we can state deadlines.

Need maybe not say "immediately" if dates future. But can say "By ...".

Let's consider if there is any possible alternative interpretation of "unless a statute or order provides otherwise" for fee motion. The fee-shifting statute applies. If the statute is e.g., 42 U.S.C. § 1988, it does not set deadline. So 14 days. Good.

Potential nuance: If the fee motion is filed within 14 days, and the court's order on rule1 motion is July10, could the fee motion be considered part of the "last timely rule1 motion" if it requests alteration of judgment to add fees? Rule3 says no toll. But the new 30-day period begins when court disposes of last timely rule1 motion. If the fee motion is a motion to alter judgment, maybe it is a rule1 motion? But rule3 explicitly says attorney-fee motion does not toll time to appeal from merits judgment. So no. We can state "Even if the fee request is cast as altering the judgment, rule 3 provides that it does not toll the merits appeal." Good.

Potential nuance: If the planned rule1 motion requests a new trial, and the fee motion is filed separately, the fee motion may be decided after the NOA. If the fee motion is granted, the judgment may be amended, which could affect appeal? Not given. We can ignore.

Need maybe include "The notice of appeal should be filed from the 'judgment' and the 'order denying the rule-1 motion' (and any other final order) to preserve all issues." Good.

Potential nuance: If the adverse evidentiary ruling is not part of the judgment, can it be appealed? It is an interlocutory ruling, but if it is part of the record and affected the judgment, it can be raised on appeal from final judgment. The rule1 motion for new trial preserves. The NOA should include it. Good.

Potential nuance: If the May8 motion only asks reconsideration and is denied, can that denial be appealed separately? Not under rules; local interlocutory motion not final. Need final judgment. Not relevant.

Need maybe include "No appeal of the evidentiary ruling alone is available until final judgment/order; the notice of appeal must be from the final judgment/order." Good.

Let's now think about final answer wording. Need be precise. Maybe:

```
Assumptions: The May 1 judgment is the triggering event; no court holidays; e-filing; no fee statute deadline other than the assumed 14-day rule.

Date count: May 1 excluded.

1. Attorney-fee motion: 14 days -> May 15, 2026 (Friday). File by 11:59 p.m. Cannot wait until July 10. Consequence: fee claim lost.

2. Rule-1 motion: 28 days -> May 29, 2026 (Friday). Must request alteration/amendment to add $42,000 prejudgment interest and, in alternative, new trial on witness exclusion. A mere reconsideration of evidentiary ruling is insufficient. Consequence if missed: no post-trial relief, no tolling; NOA by June1.

3. May 8 motion: filed within 10-day local deadline (May11), but no rule1 relief; does not toll. It does not alter judgment.

4. Original NOA if no tolling: 30 days -> May31 Sunday -> June1 Monday. Consequence: lose appeal.

5. If planned rule1 motion timely filed and denied July10: 30 days after July10 -> Aug9 Sunday -> Aug10 Monday. File NOA after disposition, by Aug10. Premature before disposition becomes effective upon disposition, but later is safer.

6. Consequences table...
```

Need maybe include "If the planned motion is timely filed, the original June1 deadline is tolled; no notice is due by June1. But if you want to be protective, you may file a premature notice; however, the safest is to wait." Good.

Need maybe include "If the planned motion is not timely filed, the July10 decision does not create a new 30-day period; the only timely appeal deadline is June1." Good.

Need maybe include "If the court disposes of a different last timely rule1 motion after July10, recalc from that date." Good.

Let's consider if there is any issue with "the court is expected to decide that motion on Friday, July 10, 2026." If the motion is filed by May29 and decided July10, the new appeal deadline is Aug10. But if the motion is filed on May29 and the court decides on July10, and the fee motion was filed May15 but not decided, does the fee motion being pending mean the "last timely rule-1 motion" is not disposed? No. Good.

Need maybe include "The fee motion does not toll the appeal from the merits judgment, so its pendency does not affect the Aug10 deadline." Good.

Potential nuance: If the planned rule1 motion includes a request for prejudgment interest and new trial, and the court denies it, the notice of appeal should include both the original judgment and the denial order. If the interest omission was not raised in a timely rule1 motion, can it be raised on appeal? Maybe plain error, but under assumed rules, to get tolling and post-trial relief, need motion. The consequence of missing rule1 deadline includes loss of post-trial correction. We can say "The appeal may still be filed by June1, but the post-trial motion cannot be used to correct the judgment or extend the appeal." Good.

Need maybe include "If the client only wants to appeal the evidentiary ruling, she can file NOA by June1 if no rule1 motion; if she wants the new deadline, file rule1 by May29." Good.

Let's think about possible exact wording for "the exact consequence of missing each separate deadline". We can be firm:

- Fee: "The fee motion is untimely and the fee claim is waived; the client cannot recover the $185,000 in attorney fees on that claim."
- Rule1: "The client loses the right to seek a new trial or alteration/amendment by post-trial motion, and the appeal clock is not tolled. If the client does not file a timely notice by June1, the client loses the right to appeal the judgment."
- Original NOA: "The appeal is not perfected; the May 1 judgment becomes final and unreviewable on ordinary direct appeal."
- New NOA: "The appeal from the final disposition of the timely rule-1 motion is not perfected; the judgment/order becomes final and unreviewable on ordinary direct appeal."
- Local: "Loss of the local reconsideration opportunity; no tolling in any event." Good.

Need maybe include "If the fee motion is filed late, the court may have no discretion to award fees because the deadline is mandatory." Good.

Potential nuance: The fee motion deadline might be subject to "unless a statute or order provides otherwise". If the fee-shifting statute provides a different deadline, we should say "assuming none." Good.

Potential nuance: If the rule1 motion is filed on May29, and the court's order is entered on July10, but the clerk's office is closed on July10? The order entry date is July10; the deadline counting starts July11. Good.

Potential nuance: If the notice of appeal is filed electronically by 11:59 p.m. on August10. Good.

Need maybe include "All deadlines are local court time." Good.

Let's now consider if the final answer should include a "checklist" with exact filings:

1. Fee motion: "Motion for Attorney Fees" or "Motion for Award of Attorney Fees and Costs" by May15. Request $185,000, cite fee-shifting statute, attach fee statement maybe.
2. Rule1 motion: "Motion to Alter or Amend Judgment, and in the Alternative for a New Trial" by May29. Grounds: (a) judgment omitted $42,000 prejudgment interest the court ruled recoverable; (b) erroneous exclusion of witness prejudiced outcome, warranting new trial. Relief: add interest; alternatively, vacate judgment and order new trial.
3. NOA: If no timely rule1: "Notice of Appeal" by June1. If timely rule1 denied July10: "Notice of Appeal" by Aug10, from judgment and order. Include issues: interest, evidentiary exclusion, fees if denied? Maybe if fee order final. Good.

Need maybe mention "Do not title the rule1 motion 'Motion to Reconsider Evidentiary Ruling' if it is meant to toll; include explicit rule1 requests." Good.

Potential nuance: If the planned motion is filed after May15 and before May29, it could be titled "Motion to Alter or Amend Judgment for Prejudgment Interest and for New Trial". Good.

Need maybe include "If the May8 motion is already on the docket, current counsel can file a separate timely rule1 motion; the May8 motion does not need to be amended to toll, but the new motion must be timely and properly scoped." Good.

Potential nuance: If the May8 motion is still pending, and the new rule1 motion includes the same witness exclusion, is there a duplication? Not issue.

Potential nuance: If the court's order disposing the rule1 motion is July10, and the fee motion is also pending, the NOA from merits can be filed; fee issues may need separate appeal after fee decision. Not necessary.

Let's think about whether to include "the May 8 motion was filed within 10 days: deadline May 11 (Monday)". It might be useful but not asked. We can include in May8 section.

Need maybe include "The local motion deadline: 10 calendar days after May1 -> May11 (Monday), because May11 is not weekend. It was filed May8, so timely." Good.

Potential nuance: If the local motion deadline May11 is a court holiday? Not specified. Not relevant.

Let's consider if there is any issue with "Saturday, Sunday, or court holiday" for May11? May11 Monday, no.

Need maybe include "If a deadline falls on a Saturday or Sunday, count the next open day. For the original and new NOA, the last day is Sunday, so move to Monday." Good.

Potential nuance: The rule says "If the last day falls on a Saturday, Sunday, or court holiday, the deadline moves to the next day the clerk's office is open." For the 30-day original, the last day is May31 Sunday. Move to June1. For new, Aug9 Sunday -> Aug10. Good.

Need maybe include "No holidays are specified; if a holiday occurs, adjust." Good.

Potential nuance: If the clerk's office is open on Saturday? It says next day the clerk's office is open. We assume Monday. Good.

Potential nuance: If electronic filing is timely by 11:59 p.m. local court time on deadline. If deadline moves to next open day, 11:59 that day. Good.

Now, let's think if any of the dates could be off by one due to "no later than 28 calendar days after entry" and "day of triggering event excluded". For "after entry" sometimes means the day after entry is day 1. We did. If 28 days after May1 is May29? Let's double-check with date difference: May1 + 28 days = May29? In calendar date arithmetic, May1 + 28 days = May29 (since May1 to May2 is 1 day). Yes. 14 days after May1 = May15. 30 days after May1 = May31. 30 days after July10 = Aug9. Good.

Need maybe include "May 31 is Sunday; June 1 Monday." Good.

Potential nuance: If the 30-day period begins when order disposing last timely rule1 motion is entered, and the order is entered on July10, is the 30th day Aug9? Yes. If the order is entered after 11:59? Not relevant.

Potential nuance: If the order disposing is entered on July10 but not effective until later? Not specified. Use entry.

Need maybe include "If the court issues a final order on July10 but a party files a later timely rule1 motion? The last timely rule1 motion controls. But the May29 deadline has passed, so no later rule1 motion can be timely. Unless the court allowed? It may not extend. So no." Good.

Potential nuance: If the planned motion is filed on May29, and the court grants it on July10, but the client does not appeal because judgment now favorable. The fee motion might be pending. Not relevant.

Need maybe include "The adverse evidentiary ruling: The planned rule1 motion should request a new trial, not just reconsideration, to toll and to preserve the issue. The NOA should include the issue." Good.

Let's think about possible answer expectations from a law exam: They may want to test: (1) fee motion 14 days = May15; (2) Rule 59 motion 28 days = May29; (3) appeal 30 days = June1 due weekend; (4) May8 motion not tolling because not Rule 59; (5) Rule 59 motion must request new trial/alter amend and filed by May29; (6) if denied July10, appeal 30 days = Aug10; (7) notice can be filed prematurely but better after; (8) consequences. Our answer aligns.

Need maybe maybe mention "Rule 1 motion is the only motion that tolls; fee motion and local reconsideration do not." Good.

Need maybe include "If the planned motion is filed timely, the appeal clock is tolled from the filing of the motion until disposition; the original 30-day deadline is suspended. The new 30-day period does not begin until the order disposing the motion is entered." Good.

Potential nuance: If the motion is filed on May29, does tolling begin on May29 or on judgment? A timely motion tolls the time to appeal; likely from filing. But the new period begins at disposition. We don't need to calculate interim. Good.

Potential nuance: If the motion is filed after the 30-day appeal period would have expired, would it still toll if within 28? Here 28<30, so no conflict. If 28 deadline after 30? not. Good.

Potential nuance: If the fee motion is filed by May15, does it have to be served? Not specified.

Potential nuance: If the May8 motion is filed by former counsel and not authorized, could it be void? Not given. Ignore.

Potential nuance: If current counsel is not of record, filings? Not given.

Need maybe include "This plan assumes the planned rule-1 motion is not already filed late. If it has not been filed by May 29, the July 10 decision cannot be used to extend the appeal." Good.

Let's now draft final answer. It should be self-contained. Use headings. Include table. Ensure all assignment bullets are addressed. Let's write in final. Need be careful with language "exact consequence". Use "under the assumed rules".

Potential final:

```
Assumptions: No court holidays; e-filing; no fee statute deadline; May 1 excluded.

Bottom line:
- May 8 motion does not toll.
- Fee motion due May 15.
- Rule-1 motion due May 29 and must request alter/amend interest and new trial.
- Original NOA due June 1 if no tolling.
- If timely rule-1 motion denied July 10, NOA due Aug 10.
- Safest: NOA after disposition; premature optional.
```

Then detailed.

Need maybe include "May 11 local deadline" in table:

| Event | Deadline | Status/consequence |
| Local reconsideration | May 11 | Filed May8; no toll |

But the May8 motion was filed before deadline. The consequence of missing it: no local reconsideration. Good.

Let's ensure the final doesn't say "Rule 59" unless mapping; but can use "Rule 1". Good.

Need maybe include "The planned motion must be filed no later than May 29, 2026, not 'by the time the court decides'". Good.

Potential nuance: "The court may not extend that deadline" for rule1. We can state "No later date can be used; a motion filed May30 is untimely even if the court would have extended." Good.

Potential nuance: "The fee motion deadline is May15; if the fee-shifting statute provides a different deadline, that controls, but facts say no special deadline." Good.

Need maybe include "If the fee motion is filed on May15 by 11:59 p.m., it is timely." Good.

Potential nuance: "If the planned rule1 motion is filed on May29 and the court denies on July10, the notice of appeal due Aug10. If the client files a notice on June1, it is premature but becomes effective July10; however, a proper later notice is safer." Good.

Let's think if there is any need to mention "the notice of appeal should be filed after the order is entered, not before, because the appeal period hasn't started." But rule says premature becomes effective upon disposition. We can say "It can be filed before as protective, but the cleanest is after." Good.

Potential nuance: If a premature notice is filed before disposition, and then a later proper notice is filed after disposition, which controls? The later is safer. We can say "If you file a premature notice, do not treat it as the end of the plan; file a proper notice after disposition to avoid doubt." Good.

Need maybe include "If the planned motion is timely filed, there is no need to file a NOA by June1. But if you miss the May29 motion deadline, you must file by June1." Good.

Potential nuance: If the planned motion is filed timely but the court's decision is not July10, the NOA deadline changes. We can include "Use the actual disposition date; July10 is the estimate." Good.

Potential nuance: If the court's order is entered on July10 but the clerk's office is closed that day? The order date is July10; deadline counting starts July11. Not needed.

Let's now produce final. Ensure no analysis. Use clear bullets. Need be thorough. Final oververbosity 9. We'll include all details.

Double-check final dates one more time:
- May 15 Friday? May 1 Friday, +14 = May15 Friday. Yes.
- May 29 Friday. Yes.
- June 1 Monday. Yes.
- Aug 10 Monday. Yes.

Need maybe mention "May 31 Sunday" and "Aug 9 Sunday". Good.

Let's consider if there is any issue with "court holiday" on June 1? In some jurisdictions, June 1 may be a holiday? Not generally. We can say "assuming no holiday". Good.

Potential issue: If the last day falls on a court holiday, move to next open day. For original NOA, if June1 is a holiday, deadline June2. We can state. For new, if Aug10 holiday, next open. Good.

Potential issue: If the fee motion deadline May15 is a court holiday, shift to May18? Not specified. We can state generally. But our table can say "May 15, unless a holiday, in which case next open day." Good.

Need maybe include "All deadlines are calendar days, not court days." Good.

Let's write final now.
