MOTION – OTHER
Defendants’ motion for entry of interlocutory judgments is DENIED.
Procedural Background
On June 27, 2025, the Court entered an Order awarding Defendants $3,115 in discovery sanctions. (Declaration of Patricia Conway (“Conway Decl.”), ¶7 and Exh. D.) On October 14, 2025, the Court entered an Order awarding Defendants $36,560 in attorney’s fees and costs under Code of Civil Procedure Section 405.38. (Conway Decl., ¶3 and Exh. A.) Plaintiff has not made any payment toward the fee award and has paid $1,000 towards the sanctions award. (Conway Decl., ¶7.)
Defendants request that the Court enter an interlocutory judgment as to the unpaid amount for each order, plus interest at 10% per annum from the date of each order.
Defendants’ Objections
The Court does not rule on Defendants’ objections to Plaintiff’s declaration as Plaintiff’s declaration has no impact on the Court’s ruling.
Discussion
Defendants’ motion is denied. The sanction order already has the full force and effect of a money judgment which Defendants can enforce through execution. (See Newland v. Superior
Court (1995) 40 Cal.App.4th 608, 615 [“monetary sanction orders are enforceable through the execution of judgment laws. These orders have the force and effect of a money judgment, and are immediately enforceable through execution . . . .”] [citation omitted]; Constellation-F, LLC v. World Trading 23, Inc. (2020) 45 Cal.App.5th 22, 30 [“Sanctions orders have the full force and effect of a money judgment”]; Jones v. Otero (1984) 156 Cal.App.3d 754, 759 [“An order imposing monetary sanctions may be enforced under the Enforcement of Judgments Law”]; Edmon & Karnow, Cal.
Prac. Guide: Civil Procedure Before Trial, ¶9:1285 (Rutter Group June 2026 Update) [“A sanctions order is enforceable the same way as a ‘money judgment’; i.e., a writ of execution may be issued by the court and levied on the property of the person sanctioned”] [emphasis in original].) The attorney’s fee order may also be enforced through the Enforcement of Judgments Law. (See Alioto Fish Co. v. Alioto (1994) 27 Cal.App.4th 1669, 1686-1687
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