Association of Unit Owners of Timbercrest Condominiums v. Warren

In this construction defect case, defendant moved for summary judgment, and the trial court granted the motion. Plaintiff then filed a “motion for reconsideration” of the summary judgment ruling. The court meanwhile entered judgment, and plaintiff filed a notice of appeal. When the trial court later denied the motion for reconsideration, plaintiff did not file a new notice of appeal. The question in this case is whether plaintiff needed to do so. Defendant argues that, because a motion for reconsideration constitutes a motion for new trial, its filing rendered plaintiff’s earlier notice of…