Does a discharged attorney have to bring a separate action to enforce a lien?

California, United States of America


The following excerpt is from Dougherty v. Balles, A140722 (Cal. App. 2015):

After the client obtains a judgment or settlement in the underlying action, a discharged attorney must bring a separate, independent action to establish the existence of the lien, to determine its amount, and to enforce it. (Mojtahedi v. Vargas (2014) 228

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