Judgment Enforcement, Section 998: Elmi Opinion Now Published

Opinion Held That Postjudgment Enforcement Statute Trumped CCP § 998 With Respect To Fee Entitlement.

               On January 10, 2025, we posted on Elmi v. Related Management Company, L.P., Case No. G062788 (4^th Dist., Div. 3 Jan. 8, 2025), when it was unpublished.  We can now update everyone by indicating that it was certified for publication on February 6, 2025, with the opinion holding that a litigant’s efforts to enforce a SLAPP judgment is governed by the CCP § 685.040 postjudgment enforcement fee statute, not CCP § 998.