1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) NOTICE OF MOTION AND MOTION FOR
) AWARD OF POSTJUDGMENT COSTS;
13 vs. ) MEMORANDUM OF POINTS AND
) AUTHORITIES; DECLARATION OF
14 Any Defendant, and DOES 1-5 ) _________________________, EXHIBITS
)
15 Defendants. ) DATE:
) TIME:
16 ) DEPT:
)
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19 TO DEFENDANT ______________________, AND THEIR ATTORNEYS OF RECORD:

20 PLEASE TAKE NOTICE that on __________________, at __.M., or as soon after that as the
21 matter can be heard, in Department, ___ of the above-entitled court located at
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_____________________________________________, plaintiff and Judgment Creditor will and
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does move the Court for an order pursuant to Code of Civil Procedure 685.040, 685.080 awarding
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the sum of $________ in postjudgment costs including attorneys fees on the grounds that said

26 postjudgment costs were reasonable and necessary costs of enforcing the judgment.
27 The motion shall be based upon this notice of motion and motion, the attached memorandum
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of points and authorities in support thereof, the files and records of this case, the declarations of

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 1 ___________________________and exhibits attached thereto, filed and served herewith, and on any
2 other documentary evidence and oral argument that may be presented at the hearing of this Motion.
3

4 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
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STATEMENT OF FACTS
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Judgment was entered in favor of __________ and against __________ on _________. The
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total amount of the judgment entered was $________.

7 There is a total of $_______ in principal presently owing on the judgment after deducting any

8 credits, and including all accrued interest and other costs that have already been added to the
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principal amount of the judgment.
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Moving party has incurred the total sum of $________ in postjudgment costs including
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attorneys fees and contends that said costs are reasonable and necessary costs to enforcing the
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13 judgment.

14 As shown by the declaration of _______________ and exhibits attached thereto the requested
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costs include attorneys fees, costs for court reporters, experts, private investigators, printing,
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copying, scanning, postage, phone conferencing services, and legal database access. These costs were
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reasonable and necessary costs of enforcing the judgment in that LIST HERE THE FACTS
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19 SUPPORTING YOUR CONTENTION SUCH AS THE JUDGMENT DEBTOR HAS

20 ATTEMPTED TO HIDE ASSETS, HAS DONE EVERYTHING THAT THEY CAN TO

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HINDER YOUR EFFORTS AT COLLECTION, REFUSED TO APPEAR FOR JUDGMENT
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DEBTOR EXAMINATIONS AND REFUSED TO PRODUCE REQUESTED DOCUMENTS,
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ETC.
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25 The requested costs were incurred commencing on DATE and continuing until DATE which

26 clearly shows that the costs were incurred less than two years ago.
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 1 To purchase the entire 12 page document visit:
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https://legaldocspro.myshopify.com/products/sample-motion-for-
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postjudgment-costs-and-attorneys-fees-in-california
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