Memorandum of Costs After Judgment California: How to Recover Enforcement Expenses
What Form MC-012 Does
Every time you pay to enforce a California judgment — writ filing fees, sheriff deposits, process server charges, recording fees — those costs are recoverable from the debtor. The vehicle for claiming them is Form MC-012, Memorandum of Costs After Judgment, Acknowledgment of Credit, and Declaration of Accrued Interest.
Most judgment creditors don't know this form exists. They spend hundreds of dollars on levies, examinations, and lien recordings, then never add those costs to the judgment balance. The result: you collect the original judgment amount and absorb the enforcement expenses yourself.
What Costs You Can Claim
Form MC-012 lets you itemize several categories of post-judgment expenses:
- Court filing fees — the $40 writ of execution fee (Form EJ-130), the $40 abstract of judgment fee (Form EJ-001), and the $60 debtor examination filing fee
- Sheriff/levying officer deposits — typically $40–$100 per bank levy or wage garnishment service
- Process server fees — charges for personal service of examination orders, subpoenas, or other post-judgment documents, up to the statutory sheriff fee equivalent
- County recorder fees — costs for recording an abstract of judgment against the debtor's real property
- Secretary of State filing fees — the ~$10–$20 fee for filing a personal property lien (Form JL-1)
- Accrued statutory interest — calculated from the date of judgment entry
How to Calculate Statutory Interest
California's post-judgment interest rate under CCP § 685.010 depends on the type of debt:
| Debt Type | Annual Rate | Applies When |
|---|---|---|
| Standard commercial/tort | 10% | Default rate for most judgments |
| Personal debt with unpaid principal under $50,000 | 5% | Judgments entered or renewed on/after Jan 1, 2023, against a natural person, except judgments based on tort or fraud or for unpaid employee wages |
| Medical debt with unpaid principal under $200,000 | 5% | Same effective date and exclusions |
| Public entity judgments | 7% | Judgments against state or local government bodies |
Most small claims judgments between individuals fall into the 5% category under the 2023 consumer debt framework if they meet the criteria above. Interest accrues from the date of judgment entry — not from the date you start enforcing.
The MC-012 form includes a section for declaring accrued interest. You calculate the daily rate (annual rate ÷ 365), multiply by the number of days since entry, and apply it to unpaid principal. Apply partial payments first to allowed costs, then accrued interest, then principal under CCP § 695.220. When a judgment is renewed, accrued interest is included in the renewed judgment balance, which bears interest going forward.
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Filing Deadline
CCP § 685.070(b) requires enforcement costs to be claimed within two years after they are incurred. If you miss that deadline, you lose the right to add those costs to the judgment. File an MC-012 periodically — after each round of enforcement activity — rather than waiting until the judgment is nearly satisfied.
Service and Opposition
Serve a copy of MC-012 on the debtor by first-class mail or personal delivery. Any person 18 or older who is not a party to the case can serve it. File the form with the court clerk and complete the proof of service on its reverse side. The debtor has 10 calendar days from service to file a motion to tax costs (Form SC-105).
The debtor has the right to file a motion to tax (challenge) the claimed costs. If they do, the court schedules a hearing. Bring receipts: sheriff fee receipts, process server invoices, court filing receipts, and your interest calculation worksheet. Costs that are properly documented and fall within the statutory categories are routinely approved.
Why This Matters for Small Claims Collection
On a $5,000 judgment at 5% annual interest, you accrue $250 in the first year alone. Add $40 for the writ, $60 for a debtor examination, $80 in sheriff deposits for a bank levy and a wage garnishment, and $50 in process server fees — that's $430 in recoverable costs and interest that many creditors leave on the table.
The California Small Claims Judgment Collection Guide includes a judgment balance ledger template that tracks each payment, cost addition, and interest accrual so your MC-012 filing matches exactly what the court expects.
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