Post-Judgment Costs of Collection and Bankruptcy

I find this decision interesting, given the current economic climate and the number of employers who threaten to file bankruptcy when their employees ask to be paid lawful wages. On December 30, 2008, the California Court of Appeal held that Code of Civil Procedure Section 685.040, which allows a judgment creditor to recover reasonable and necessary attorney fees incurred in "enforcing" a judgment, applies to those attorney fees that creditor incurrs in a debtor’s post-judgment bankruptcy proceeding. Chinese Yellow Pages Company v. Chinese Overseas Marketing Service Corporation (December 30, 2008, Second District, Division Five).