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Memorandum of Costs After Judgment


Adding Costs and Interest to a Judgment

The amount recoverable by a judgment creditor includes the total amount of the judgment entered by the court, plus any costs incurred after judgment and accrued interest on the total amount. 

Under California Code of Civil Procedure (CCP) § 685.040, a judgment creditor is entitled to reimbursement for the "reasonable and necessary" costs of enforcing a judgment. The law provides a detailed list of the types of costs that can be recovered, including the costs of issuing the writ of execution; levying officers' fees for processing writs or levies; debtor's examination fees; and fees for preparing, issuing and recording an abstract of judgment or notice of lien (CCP § 685.050 et seq). Attorneys' fees related to the enforcement of judgment are generally not reimbursable, unless specifically allowed by law, or the underlying judgment includes an award of attorney's fees CCP § 685.040. The law does not provide for reimbursement of costs such as postage, photocopying, or long-distance telephone charges, nor can the judgment creditor be compensated for his or her time or mileage related to enforcement efforts. Once approved by the court, costs become part of the judgment (CCP § 685.090). To be reimbursable, costs must be reported to the court within two years of being incurred (CCP § 685.070(b)). For this reason, many judgment creditors regularly file a Memorandum of Costs after Judgment (MC-012) with the court.

Unpaid judgment amounts accrue interest at the legal rate of 10% per year (CCP § 685.010; 7% if the judgment debtor is a state or local government entity, California Constitution, Article XV, §1). Costs approved by the court are included as part of the judgment amount, and thus accrue interest. Additionally, upon renewal of a judgment, the unpaid judgment amount and accrued interest are calculated to determine the renewed judgment amount.

To have costs and interest added to the enforceable amount owed, the judgment creditor must file and serve a Memorandum of Costs after Judgment (MC-012). On this form, the judgment creditor must include the exact amount of all costs and accrued interest.

FORMS
The Judicial Council form commonly used in this procedure is:

Click here to download this Guide, with step-by-step instructions, including sample forms.

created 2/13 mpj
reviewed en 11/13
updated 1/14 mpj