Gray1 CPB, LLC v. SCC Acquisitions, Inc.
California Court of Appeal
169 Cal. Rptr. 3d 906 (2014)
Gray1 (plaintiff) held a roughly $9,000,000 judgment against Elieff (defendant), incurring over $3,000,000 in post-judgment enforcement fees over two years; when Elieff finally presented a cashier's check for the full judgment amount with a letter declaring the judgment satisfied, Gray1 accepted the check but did not immediately deposit it, instead filing a motion for post-judgment costs and fees 12 days later, only depositing the check the day after filing that motion. The trial court denied Gray1's motion as untimely, finding the judgment had already been satisfied when Gray1 accepted the check.
Whether a motion for post-judgment costs, including attorneys' fees, must be made before the underlying judgment is satisfied in full.