California, United States of America
The following excerpt is from Guo v. Moorpark Recovery Serv., LLC, 275 Cal.Rptr.3d 94, 60 Cal.App.5th 745 (Cal. App. 2021):
Section 685.040 provides, "The judgment creditor is entitled to the reasonable and necessary costs of enforcing a judgment. Attorney's fees incurred in enforcing a judgment are not included in costs collectible under this title unless otherwise provided by law. Attorney's fees incurred in enforcing a judgment are included as costs collectible under this title if the underlying judgment includes an award of attorney's fees to the judgment creditor pursuant to subparagraph (A) of paragraph (10) of subdivision (a) of Section 1033.5 ." (Italics added.) "Review of section 1033.5, subdivision (a)(10)(A), shows that attorneys fees may be recovered as costs when authorized by contract." ( Cardinale v. Miller (2014) 222 Cal.App.4th 1020, 1025, 166 Cal.Rptr.3d 546.)
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