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FDI-22-796258·sf·FamilyLaw·Post-Judgment Financial Issues
Hearing in about 3 hoursMixed

ERICA PLAM v. ERIC HUDSON PLAM

Request for Order: Child Support; Reserved Financial Issues; Attorney Fees; Sanctions

Hearing date
Aug 20, 2026
Department
403
Prevailing
Mixed

Motion type

Browse all Motion for Attorney Fees rulings statewide →

Causes of action

Monetary amounts referenced

$18,784.79$5,000$25,000$7,500

Parties

PetitionerERICA PLAM
RespondentERIC HUDSON PLAM

Ruling

1 SUPERIOR COURT OF CALIFORNIA 2 COUNTY OF SAN FRANCISCO 3 UNIFIED FAMILY COURT 4

5) 6 ERICA PLAM,) Case Number: FDI-22-796258) 7 Petitioner) Hearing Date: August 20, 2026) 8 VS.) Hearing Time: 9:00 AM) 9 ERIC HUDSON PLAM,) Department: 403) 10 Respondent) Presiding: BOBBY P. LUNA) 11) 12 REQUEST FOR ORDER RE: CHILD SUPPORT, RESERVED FINANCIAL ISSUES; REQUEST FOR 13 ORDER: TEMPORARY EMERGENCY ORDER, ORDER SHORTENING TIME; SEE #7 OTHER 14 ORDERS REQUESTED 15 TENTATIVE RULING 16 Having read and considered the pleadings, declarations, and other evidence submitted in this matter, the 17 Court makes the following findings and orders: 18 I.

Request for Order filed 1/7/26: 19 A. Procedural History 20 1) The parties are Petitioner Erica Plam (Mother) and Respondent Eric Hudson Plam (Father). 21 2) On 9/5/25, the Court ordered the immediate reappraisal and sale of the San Francisco property 22 located at 1850 10th Avenue in San Francisco, California (against Mother’s request to delay the 23 sale of the home for 10 months), with additional orders regarding the sale process, expenses 24 incurred to effectuate the sale, carrying costs, and sale proceeds.

The Court reserved jurisdiction 25 over the sale of the home. See Findings and Order After Hearing (FOAH) filed 9/5/25. 26 3) On 10/7/25, the Court issued a Final Statement of Decision, which includes disposition of the San 27 Francisco property and the Reno property (located at 712 S. Arlington Avenue Reno, Nevada) 28 and other orders related to property division. The Court ordered, in pertinent part: 29

1 a. Regarding the San Francisco property, the Court ordered that the net sale proceeds of the 2 home be divided equally between the parties minus Family Code section 2640 3 reimbursements. The Court also stated that expenses related to the sale of the home will 4 be divided equally between the parties. See page 6-7. 5 b. “Epstein credits” are to be paid from the community. (In re Marriage of Jefferies (1991) 6 228Cal.App.3d 548.) See page 8. 7 c. The Court exercised its discretionary authority and awarded $25,000 of Epstein credits to 8 Father for “reimbursement of separate property mortgage payments, property tax 9 payments, and home insurance for the San Francisco home post separation during the 10 time that [Mother] had exclusive use of the residence.”

The Court declined to award 11 Watts charges to either party. See page 9. 12 d. Regarding the Jeep vehicle purchased in 2019, the Court declined to issue Epstein credits 13 or Watts charges. The Court awarded proceeds of a lemon law settlement to Father and 14 ordered Mother to repay Father $25,201, which she received from the lemon law 15 settlement. See page 10. 16 e. Regarding business taxes, the Court ordered Mother to pay Father $6,000 for payment of 17 business taxes. See page 10. 18 4) At the prior 2/17/26 hearing on Father’s 1/7/26 Ex Parte Request for Order, the Court set a review 19 hearing on 5/19/26 stating, “The Court reserves jurisdiction over the sale of the home including 20 division of the sale proceeds consistent with the Court’s 9/5/25 order and further order of the 21 Court.”

See FOAH filed 3/3/26. 22 5) At the prior 3/10/26 hearing, the Court disbursed a portion of the net sale proceeds of the San 23 Francisco property to the parties as follows: (a) $44,230.48 to Father off the top at closing and (b) 24 $50,000 to each party. See FOAH filed 4/2/26. 25 6) On 4/7/26, Judgment was entered incorporating the 10/7/25 Final Statement of Decision. 26 7) On 4/14/26, Father filed a Request for Order seeking disbursement of funds from the net sale 27 proceeds of the San Francisco property. 28 8) At the prior 4/23/26 hearing, the Court ordered: (a) Father agreed to buy out Mother’s interest in 29 the Reno property for $170,000; (b) each party shall receive $150,000 of the net sale proceeds of

1 the San Francisco property; (c) Father’s $150,000 distribution shall be held until Mother receives 2 the buyout payment for the Reno property; and (d) the remaining approximately $106,632 in 3 funds from the net sale proceeds of the San Francisco property shall remain in counsel for 4 Mother’s client trust account not be distributed without written agreement or further court order. 5 See 4/23/26 Minute Order. 6 9) On 5/6/26, Mother filed a Responsive Declaration in opposition to Father’s 4/14/26 Request for 7 Order. 8 10) On 5/12/26, Father filed a Reply Declaration reiterating his requests related to disbursement of 9 funds from the net sale proceeds of the San Francisco property. 10 11) At the prior 5/19/26 hearing, the Court ordered: 11 a.

It is undisputed that approximately $106,632.64 of the net sale proceeds of the San 12 Francisco property remains in counsel for Mother’s client trust account (i.e., Mother 13 acknowledges this amount in her 5/6/26 Responsive Declaration and Father 14 acknowledges this amount in his 5/12/26 Reply Declaration), which the Court 15 acknowledged and ordered not be distributed without written agreement or further court 16 order. See 4/23/26 Minute Order. 17 b. Based on the pleadings, the Court finds the parties do not agree on how the remaining 18 funds should be distributed; therefore, the Court finds good cause to rule of Father’s 19 requests (set forth in his 4/14/26 Request for Order) and distribute the remaining net sale 20 proceeds of the San Francisco property in accordance with the Final Statement of 21 Decision issued 10/7/25 as follows: 22 c.

Father’s request for $25,000 in Epstein credits is GRANTED, the full balance of which 23 shall be paid from the undivided funds. This leaves $81,632.64 for equal distribution 24 between the parties ($106,632.64 - $25,000 = $81,632.64) or approximately $40,816.32 25 awarded to each party, subject to the orders below. 26 d. Father’s request for $25,201 in Jeep settlement refund is GRANTED, the full balance of 27 which shall be paid from Mother’s share of the funds. 28 e. Father’s request for $6,000 in business taxes is GRANTED, the full balance of which 29 shall be paid from Mother’s share of the funds.

1 f. Father’s request for $22,115.24 for foreclosure cure reallocation is DENIED as Father 2 was previously reimbursed $44,230.48 from the San Francisco home sale proceeds for 3 curing the mortgage default and preventing foreclosure. See FOAH filed 4/2/26. 4 g. Father’s request for $2,785.04 in reimbursement for unauthorized home repairs is 5 DENIED as the Court ordered the cost of home repairs divided equally. 6 h. Father’s request for $440.40 in mortgage late fee charges and $3,843.36 in mortgage 7 delay damages is DENIED. 8 i.

Father’s request for reimbursement of $1,663.10 for a Bank of America Cashier Check 9 issued in his name only is GRANTED, the full balance of which shall be paid from 10 Mother’s share of the funds. 11 j. Counsel for Mother shall distribute the funds in accordance with the orders made herein 12 within 60 days of this hearing. 13 k. In so far as there remain issues related to the exchange of personal property; the parties 14 shall follow the process ordered at the prior 4/23/26 hearing. See 4/23/26 Minute Order. 15 l.

The Court reserves jurisdiction over Father’s request for $18,784.79 in attorney’s fees 16 sanctions and additional request for $5,000 in fiduciary-duty sanctions and sets the issue 17 for hearing on 7/23/26. The parties shall submit updated Income and Expense Declaration 18 10 days prior to hearing and any supplemental declaration by 6/23/26 and reply by 19 7/10/26. 20 12) Thereafter, the 7/23/26 hearing was continued to 8/20/26. 21 13) On 7/10/26, Father filed a supplemental declaration regarding his request for $18,784.79 in 22 attorney’s fees sanctions and additional request for $5,000 in fiduciary-duty sanctions.

Father 23 states he has won all five ex parte applications brought in the matter (two by Father and three by 24 Mother). 25 14) On 7/10/26, Father filed an updated Income and Expense Declaration. 26 15) On 7/17/26, Mother filed a Reply Declaration in opposition to Father’s request and in dispute of 27 Father’s position. Mother asserts she does not have the ability to pay sanctions. 28 16) On 7/28/28, Mother filed an updated Income and Expense Declaration. 29

1 17) On 8/11/26, the Court denied Mother’s Motion for Reconsideration of the Court’s 5/19/26 order 2 (filed 6/17/26). 3 B. Findings and Order 4 1) Father’s request for $18,784.79 in attorney’s fees sanctions under Family Code section 271 is 5 GRANTED. The Court finds Mother’s conduct throughout this litigation frustrated the policy of 6 the law to promote settlement of litigation and, where possible, to reduce the cost of litigation by 7 encouraging cooperation between the parties and attorneys.

The Court finds this award will not 8 impose an unreasonable financial burden on Mother. Mother shall pay Father this balance in full 9 by 9/20/26. 10 2) Father’s request for $5,000 in fiduciary-duty sanctions under Family Code section 1101 is 11 DENIED as Father did not provide sufficient evidence to prove his claim of breach of fiduciary 12 duty. 13 II. Request for Order filed 7/1/26: 14 A. Procedural History 15 1) On 7/1/26, Mother filed a Request for Order seeking: (a) a review hearing in 60 days to permit 16 completion of post-judgment financial discovery and review of unresolved financial issues; (b) an 17 order requiring the parties to continue complying with all prior orders regarding identification and 18 exchange of personal property located in the Reno and San Francisco properties; (c) $25,000 in 19 Family Code section 2030 attorney’s fees; and (d) reservation of jurisdiction over Jeep-related 20 issues. 21 2) On 8/7/26, Father filed a Notice of Limited Scope Representation indicating he has legal 22 representation for the 8/20/26 hearing. 23 3) On 8/7/26, Father filed a Responsive Declaration in opposition to Mother’s Request for Order. 24 Father requests the Court deny Mother’s request or, in the alternative, issue a protective order 25 limiting post-judgment discovery.

Father seeks $7,500 in sanctions pursuant to Family Code 26 section 271 and Code of Civil Procedure section 2023.030. 27 4) On 8/7/26, Father filed a Memorandum of Points and Authorities. 28 5) On 8/7/26, counsel for Father filed a declaration regarding meet and confer efforts. 29 B. Findings and Order

1 1) Mother’s request for a review hearing in 60 days to permit completion of post-judgment financial 2 discovery and review of unresolved financial issues is DENIED as there is no statutory basis for 3 the Court to grant such relief; the discovery deadline and time to appeal entry of Judgment 4 passed. 5 2) Furthermore, Family Code section 218 only permits post-judgment discovery on specific issues 6 currently pending before the Court. There are no other motions currently pending before the 7 Court. 8 3) Mother’s request for $25,000 in Family Code section 2030 attorney’s fees is DENIED.

The Court 9 does not find that an award of $25,000 in attorney’s fees is reasonable or necessary here. 10 4) Father’s request for 7,500 in sanctions pursuant to Family Code section 271 and Code of Civil 11 Procedure section 2030 is GRANTED. The Court finds the filing of the instant Request for Order 12 unnecessarily increased legal fees and constitutes misuse of the discovery process. The Court 13 further finds this award will not impose an unreasonable financial burden on Mother. Mother 14 shall pay this balance in full by 9/20/26. 15 5) All prior orders not in conflict with the orders made herein remain in full force and effect. 16 6) Counsel for Father shall prepare the Findings and Order After Hearing. 17 7) Preparation of Order: If you are directed by the court to prepare the order after hearing – within 18 10 calendar days of the hearing you must either: (a) Serve the proposed order to the other 19 party/counsel for approval, and follow the procedures set forth in CA Rules of Court, Rule 20 5.125(c), or (b) If the other party did not appear or the matter was uncontested, submit the 21 proposed order after hearing directly to the court.

Failure to submit the order after hearing within 22 10 days may allow the other party to prepare a proposed order and submit it to the court in 23 accordance with CA Rules of Court, Rule 5.125(d). 24

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