Memorandum of costs of enforcing judgment: not later than 2 years after costs incurred (and before full satisfaction)

24 months after date the enforcement costs were incurred, under Cal. Code Civ. Proc. 685.070(b).

Rule text

CCP 685.070(b): "Before the judgment is fully satisfied but not later than two years after the costs have been incurred, the judgment creditor claiming costs under this section shall file a memorandum of costs with the court clerk and serve a copy on the judgment debtor. Service shall be made personally or by mail."

Cal. Code Civ. Proc. 685.070(b), official source

Calculate this deadline

Deadline
Monday, November 6, 2028
  1. Trigger (Date the enforcement costs were incurred): Friday, November 6, 2026.
  2. Add 24 months: Monday, November 6, 2028.
Rules applied
Cal. Code Civ. Proc. 685.070(b)
CCP 685.070(b): "Before the judgment is fully satisfied but not later than two years after the costs have been incurred, the judgment creditor claiming costs under this section shall file a memorandum of costs with the court clerk and serve a copy on the judgment debtor. Service shall be made personally or by mail."
Official source
Cal. Code Civ. Proc. 12, 12a, 12b, 10; Cal. Rules of Court, rule 1.10
CCP 12: "The time in which any act provided by law is to be done is computed by excluding the first day, and including the last, unless the last day is a holiday, and then it is also excluded." CCP 12a(a): "If the last day for the performance of any act provided or required by law to be performed within a specified period of time is a holiday, then that period is hereby extended to and including the next day that is not a holiday. For purposes of this section, “holiday” means all day on Saturdays, all holidays specified in Section 135 and, to the extent provided in Section 12b, all days that by terms of Section 12b are required to be considered as holidays." CCP 12b: "If any city, county, state, or public office, other than a branch office, is closed for the whole of any day, insofar as the business of that office is concerned, that day shall be considered as a holiday for the purposes of computing time under Sections 12 and 12a." CCP 10: "Holidays within the meaning of this code are every Sunday and any other days that are specified or provided for as judicial holidays in Section 135."
Official source
  • Two limits: (1) before the judgment is fully satisfied (event-based, not modeled) and (2) 2 years after the costs were incurred. Each cost item has its own 2-year clock. Covers only the listed cost categories (685.070(a)); others require a noticed motion (685.080; see enforcement_costs_motion_2yr). Attorney's fees are recoverable only if the underlying judgment awarded contractual or statutory fees (685.040). Section amended Stats. 2024, ch. 514 (AB 2837), eff. Jan. 1, 2025.
  • If the clerk's office is closed or inaccessible on the last day (weather, emergency or local closure orders), the deadline may be extended. Check local orders.

This calculator applies the cited rules to the dates you enter. It is not legal advice. Court orders, local rules, and case-specific facts can change a deadline; verify before relying on it. Rule set pending attorney review.

Worked example

Date the enforcement costs were incurred on Monday, March 15, 2027, personal service: due Thursday, March 15, 2029.

  1. Trigger (Date the enforcement costs were incurred): Monday, March 15, 2027.
  2. Add 24 months: Thursday, March 15, 2029.

Notes

Two limits: (1) before the judgment is fully satisfied (event-based, not modeled) and (2) 2 years after the costs were incurred. Each cost item has its own 2-year clock. Covers only the listed cost categories (685.070(a)); others require a noticed motion (685.080; see enforcement_costs_motion_2yr). Attorney's fees are recoverable only if the underlying judgment awarded contractual or statutory fees (685.040). Section amended Stats. 2024, ch. 514 (AB 2837), eff. Jan. 1, 2025.

Related deadlines

All California civil deadlines

Local rules by county

County local rules and courtroom procedures can add to or change this deadline. Pick a county to calculate with them applied.

Rules current as of 2026-10-25. Confirm against the official source and any local rule or court order before relying on a date. Rules changelog.