Figuring out the quickest and least costly avenue for appellate relief after an adverse pretrial ruling can be challenging, especially where the ruling disposes of a core issue, but leaves peripheral causes of action pending. An immediate appeal generally is not an option because a judgment must finally dispose of all causes of action between two parties to be appealable. And while the court of appeal can exercise its discretion to review the interlocutory ruling through a writ petition, such petitions are rarely granted.

Some litigants have experimented with another option: After a ruling disposes of their central cause of action, they stipulate to dismiss the remaining causes of action without prejudice and waive the applicable statute of limitations in order to clear the way for entry of judgment.