$274,495 Request Properly Pared Down to $164,697.
Pacelli v. Jaffe, Case No. B213228 (2d Dist., Div. 3 Jan. 9, 2012) (unpublished) is the culmination of a lot of fights involving post-judgment enforcement proceedings. After the appellate court remanded to allow the judgment creditor to recover for post-judgment enforcement efforts in the bankruptcy court under Code of Civil Procedure section 685.040, the lower court only awarded judgment creditor $164,697 out of a requested $274,495–almost a 40% reduction. The appellate court found no abuse of discretion in the reduction, and also chastised the appellants for making “counterproductive” attacks on the deciding judge’s character.