The following report is based on true facts gathered from the following sources:
Direct experiences in litigation against Jaffe & Clemens
Contact with other litigants who faced Jaffe & Clemens
Discussion with other attorneys who faced Jaffe & Clemens
Review of case files at Los Angeles Superior Court involving Jaffe & Clemens
Review of appellate case files at LASC
Review of appellate case details on the LASC appelate website
Review of online information regarding Jaffe & Clemens (caselaw, appellate decisions, news reports, etc.)
All statements below are opinions based on the above sources. We will be willing to testify in a court of law as to the veracity of this information. Any errors or ommissions are not intentional.
Jaffe & Clemens is a prominent family law firm located in Beverly Hills. They advertise themselves to be "compassionate and trusted." This is far from the truth in our opinion, as you will see by their litigation tactics below. While this report focuses on William Ryden, in our experiences and opinions, the information listed below appears to be company policy and process. It appears the overall strategy of the J&C firm is to litigate as long as hard as possible to maximize fees whenever they have the right circumstances. It seems that their goal is to liquidate the families of all assets. The saddest part of what J&C are doing is the effect it has on the children. Instead of promoting settlement of custody issues, they promulgate a war; instead of helping to resolve financial issues as quickly as possible, they turn their cases into the Nuremberg trials. The poor children who suffer from their actions must be recognized. God will have judgement for these people.
CREATING CONFLICT AND MAKING ENEMIES OF SPOUSES
The first job of J&C is to create a level of animosity between spouses. J&C prefer having the non-earner spouse for many reasons that will be elucidated in this report. Spouses will be referred to as Primary Earner ("E") and Non-earner ("NE"). When J&C have a client who is a NE the case becomes essentially a contingency case. The family law court awards attorneys fees to the NE with impunity. J&C will start to build a wall between spouses by scaring their client into believing the E want's them to be penniless and on the street. In many of these cases, after a few months, spouses that were getting along are completely adverserial. This is necessary so that there cannot be transfer of information from one spouse to the other or any kind of relationship that could promote settlement.
One of J&C techniques is to start a disinformation campaign with letters going to the opposing spouse. These letter will contain derogatory and demeaning statements about the opposing spouse, with accusations of malfeasance. At meetings between parties, J&C attorneys such as William Ryden may be provocative and hostile, which further enhances the growing conflict. J&C will also work with their client's family to alienate the opposing spouse. Their disinformation campaigns involve a lot of gaslighting of the opposing spouse - accusing them of things they never did and making up events that never happened.
PRENUPTIAL AGREEMENTS
J&C capitalize greatly when there is an existing prenuptial agreement. This is an immediate cash-generating entity because all prenuptial agreements can be challenged in court. In the cases we reviewed, J&C appeared to litigate against the validity of the prenup regardless of whether it was legitimate or not. The litigation over this aspect of the case can easily run up hundreds of thousands of dollars.
PSYCHIATRIC PROBLEMS
When couples are going through a divorce, it puts a massive psychiatric strain on all parties. However, Mr. Ryden is known for receiving referrals of spouses who have serious psychiatric issues. Three of his recent clients have had psychiatric hospitalizations. These spouses are particularly vulnerable and susceptible to manipulation by their attorney. which makes this all the more heartwrenching.
CHAOS AROUND TEMPORARY SUPPORT ORDERS
One area of specific expertise for J&C is to create chaos at the onset of the divorce around temporary support orders. Temporary spousal and child support orders are necessary for spouses to separate their finances. Until there are temporary orders it is difficult or impossible to move forward with financial separation. J&C endeavor to avoid temporary support orders altogether, hoping to keep the joint accounts open and shared for as long as possible. What this does, when they are of course representing the NE, is the following:
1. Earner does not get tax credit for deductibility of spousal support
2. Non-earner can withdraw as much money as possible and hide away cash.
3. Non-earner can establish a new marital standard of living by increasing spending; temporary orders are necessary to limit the spending of the NE
4. More conflict is created between two parties who are divorcing who are now sharing a bank account; more letters fly back between parties which equals increased fees.
5. J&C will then come back at trial and using their in-house accountants they will calculate or miscalculate the support that "should have" been payed and demand reimbursement.
6. Beware of retroactivity clauses in any temporary orders by J&C.
If J&C cannot get the parties (ie the opposing spouse) to leave the joint accounts open, they will try for a hybrid approach, that will create further chaos and litigation opportunities down the road. For example, they will get the E spouse to pay a low level of support (below guideline) and get that spouse to sign a stipulation with retroactivity built in. Then they will also have the E spouse pay household expenses (rent, utilities, school, etc). This turns the situation into a dog and pony show. A few years later, when the parties finally get to trial, J&C will have had their in-house accountants rack up tens of thousands of dollars calculating how much should have been paid. This will involve going through literally every receipt and check image from years of marriage. Can you imagine the amount of work this involves?
THE TEMPORARY SUPPORT GAME
When J&C have the non-earner, and the earner makes a lot of money, or has a post-separation increase in cash flow, this is a bonanza!! Temporary support orders in these instances are always high and often outrageous. J&C's goal is to lock in one of these high pendente lite orders and then put the baby to sleep, ie delay, delay, delay. This can become an extremely frustrating situation for the opposing spouse earner. It is an art form for J&C. Once they get this order, they put off all settlement conferences and trial. Possibly, their client can have a medical problem which will drag out the temporary orders for years!
DISCOVERY
God forbid if you are the Earner spouse going up against J&C. They have specific discovery strategies that will cause great pain and cost to the opposing spouse. What happens is J&C will propound extensive, extensive discovery, demanding hundreds of lines of items. The Earner spouse, of course, has much more discovery to produce than a non-earner so this becomes a massive, stressful, costly process. In the meanwhile J&C will delay the prodution of discovery from their own client for as long as possible. Remember, the ultimate goal of J&C in our opinion, is to DELAY DELAY DELAY. Each month their bills are tens of thousands of dollars. Every month of delay is equal to twenty, thirty or forty thousand dollars of income to J&C. The longer the opposing spouse takes to get their discovery the better. Meanwhile, their own client produces little to no discovery to prolong the process. Then the parties get to trial setting conference and J&C pull some minutiae out that is missing and demand the trial be delayed. This may stretch things out for months and months. Then, they make it as difficult as possible to get their own client's discovery to potentiate the delays. DISCOVERY IS A NIGHTMARE with J&C. Beware!
CUSTODY DISPUTES
When there are custody problems, in our opinion, this is not an opportunity for J&C to be "compassionate." It is a money-making opportunity. J&C are willing to file false allegations of domestic violence. They will believe anything their client says and the groupthink is frightening. Of course a custody battle will turn in to a custody evaluation. Instead of mediating or settling they will set up the battle of the century between spouses. J&C are a very well established family law firm, and they have custody experts in their back pocket who will advocate for their position vigorously. In our opinion, just like large corporations that have mediation clauses and mediators that favor the corporation, J&C has assembled experts that will favor their client.
THREATENING BEHAVIORS IN COURT
Here we highlight Mr. William Ryden. In three cases we reviewed Mr. Ryden provoked and physically entered the opposing litigants personal space in a threatening manner. Two of the cases (two different litigants) occured in the hallway of the courtroom. The third happened in the courtroom bathroom and it almost came to fisticuffs by report. Why would J&C allow this? If Mr. Ryden could get one of the opposing litigants to strike him he would immediately have the bailiff arrest that person for assault. It would be a turning point in the case. Of course this type of behavior makes Mr. Ryden appear like a vigorous advocate for his client, but the behavior is actually bullying. In our opinion, J&C have lost all sense of decorum in the past five years or so and have created a culture of legal bullying to maximize profits.
DIVISION OF BUSINESSES
Another huge profit center for J&C. When there is a business that needs to be divided, this is the gray area that J&C profit on. If the business has mixed community and separate property aspects this will be a litigation nightmare beyond belief for the primary earner. J&C will take a hardline stance from the get-go that any business, if it has even an ounce of community property in it, is all community property. They will litigate to trial the asset is 50/50, even in the presence of a prenuptial agreement stating othewise. Of course this process will become a living hell for the Earner/business operator. J&C will deny any existance of post-separation efforts or equitable allocation of the business. They will come up with a preposterous fair compensation. They will manufacture logic that has no basis in reality and ride it all the way through trial until they lose.
J&C SPECIOUS "LOGIC" AND FALSE "ARGUMENTS"
One of the amazing things about J&C is the financial arguements and logic they manufacture. They will come up with motions and replies to the court which when read seem to make sense in a bad way for the opposing client. However, careful examination of these arguments frequently shows severe errors in logic. If the judge is not on his or her toes or doesn't have the time to really look at an issue, it can be a big problem. Some examples of this include:
1. False calculations of expenses
2. Including post-separation monies in division of community assets
3. Grossly overestimating and overcalculating cash flow of the payor
4. Adding in perquisites, retirement funds and other expenses to cash-flow analysis that are not relevant
5. Inflating expenses of the non-earner spouse to increase the marital standard of living (this is a cottage industry for them)
6. Including post-separation expenses in marital standard of living calculations
7. Coming up with false "breach of fiduciary duty" issues.
TACTICS FOR MOTIONS AND HEARINGS
J&C have an aresenal of weapons when they get in the courtroom. First, they will try to disqualify any motion or order by opposing counsel for jurisdictional or procedural reasons. They seem to always do this and try to get it thrown out of court. They also often try to take over the entire hearing. The more they talk the less information the judge can get about the opposing case. If the judge states they are going to lose the issue, they have five alternate scenarios they will request of the judge. For example, in a fees hearing, let's say the judge denies the fees. They will then ask for money to be set aside in an escrow account; or ask for a limit on the opposing spouses spending, etc.
MEDIATION SESSIONS AND PRIVATE JUDGES
In our experience, these sessions are often money-making opportunities. Many of the opposing litigants told us stories where they spent 8-10-12 hours in the conference room trying to hammer out a settlement, only to be thwarted at the last minute. Remember, 10 hours of mediation is about $13,000 for J&C because they are almost always double billing with the primary attorney and assistant. The assistant seems to be there only to carry notebooks and boxes into the courtroom and to find pages in the document binders. A ridiculous waste of money at $4-500 per hour.
J&C have a bevy of private judges who are also aligned with them. Remember, many of these attorneys go way back. Again, a private judge session can be another 10-12 hours of money-earning. One litigant told us a story that a 12 hour mediation session ended with the J&C attorney refusing to show a spousal support offer to his client.
Mr. Ryden is known for packing up his briefcase and walking out of mediation sessions at the slightest perturbation. Of course, when Mr. Ryden walks, there is no recourse to the opposing spouse. They have to pay their share of the aborted session.
DELAY DELAY DELAY
We believe J&C want to delay every case for as long as possible. As mentioned, when they are billing tens of thousands of dollars a month, it makes sense for them. Here are some techniques they use to delay everything:
1. Set up mediation sessions where there is no intention of settling
2. Set up mediation sessions and then they have their client cancel at the last minute
3. Whenever the judge offers a date for a future hearing or process they say "I'm out of town in July." Then they have their client say "I'm taking the kids on vacation in August." Surprisingly, judges don't get this. They almost always agree.
4. Delay all trial-setting conferences for discovery "problems."
5. Delay custody appointments and home-visits as long as possible.
INFLATED ATTORNEY'S FEES
J&C will rack up fees in the millions of dollars. We learned from several litigants that they tell their clients "there are two prices - full price if your spouse has to pay the fees and a big discount if you have to pay." J&C will go into a fees hearing with outrageous costs and then ask for half to look "reasonable." The family law system of course turns a case of the non-earner into a contingency case for J&C. No earner will spend that kind of money when they are working for it. Instead, a disgruntled non-earning spouse will be convinced by J&C to seek revenge by litigating as much as possible. The NE doesn't care; the E will have to pay it so it is meaningless to them other than to hurt their soon to be ex-spouse.
APPPEALS
J&C love to appeal. They usually lose, but it earns them more money. Here is a case where Mr. Ryden tried to take a case involving a federal pension out of the federal court, so he could get attorneys fees. He lost the case after racking up a million dollars in fees that his client was stuck with.
https://www.youtube.com/watch?v=EaCy7g_Q_tg
Imagine the pain it causes a family to have to go through the appeal process and extend the litigation for a year or years. No one can move on from the divorce. The spouses remain enemies fighting in the world of abstract law. How does this help the children??
WHEN DOES IT STOP
In the stories we heard the litigation only stopped when:
1. Their client realized the toxic nature of the J&C process
2. The court punished them for unnecessary and overly aggressive litigation
Jaffe and Clemens Reviews
The following report is based on true facts gathered from the following sources:
Direct experiences in litigation against Jaffe & Clemens
Contact with other litigants who faced Jaffe & Clemens
Discussion with other attorneys who faced Jaffe & Clemens
Review of case files at Los Angeles Superior Court involving Jaffe & Clemens
Review of appellate case files at LASC
Review of appellate case details on the LASC appelate website
Review of online information regarding Jaffe & Clemens (caselaw, appellate decisions, news reports, etc.)
All statements below are opinions based on the above sources. We will be willing to testify in a court of law as to the veracity of this information. Any errors or ommissions are not intentional.
Jaffe & Clemens is a prominent family law firm located in Beverly Hills. They advertise themselves to be "compassionate and trusted." This is far from the truth in our opinion, as you will see by their litigation tactics below. While this report focuses on William Ryden, in our experiences and opinions, the information listed below appears to be company policy and process. It appears the overall strategy of the J&C firm is to litigate as long as hard as possible to maximize fees whenever they have the right circumstances. It seems that their goal is to liquidate the families of all assets. The saddest part of what J&C are doing is the effect it has on the children. Instead of promoting settlement of custody issues, they promulgate a war; instead of helping to resolve financial issues as quickly as possible, they turn their cases into the Nuremberg trials. The poor children who suffer from their actions must be recognized. God will have judgement for these people.
CREATING CONFLICT AND MAKING ENEMIES OF SPOUSES
The first job of J&C is to create a level of animosity between spouses. J&C prefer having the non-earner spouse for many reasons that will be elucidated in this report. Spouses will be referred to as Primary Earner ("E") and Non-earner ("NE"). When J&C have a client who is a NE the case becomes essentially a contingency case. The family law court awards attorneys fees to the NE with impunity. J&C will start to build a wall between spouses by scaring their client into believing the E want's them to be penniless and on the street. In many of these cases, after a few months, spouses that were getting along are completely adverserial. This is necessary so that there cannot be transfer of information from one spouse to the other or any kind of relationship that could promote settlement.
One of J&C techniques is to start a disinformation campaign with letters going to the opposing spouse. These letter will contain derogatory and demeaning statements about the opposing spouse, with accusations of malfeasance. At meetings between parties, J&C attorneys such as William Ryden may be provocative and hostile, which further enhances the growing conflict. J&C will also work with their client's family to alienate the opposing spouse. Their disinformation campaigns involve a lot of gaslighting of the opposing spouse - accusing them of things they never did and making up events that never happened.
PRENUPTIAL AGREEMENTS
J&C capitalize greatly when there is an existing prenuptial agreement. This is an immediate cash-generating entity because all prenuptial agreements can be challenged in court. In the cases we reviewed, J&C appeared to litigate against the validity of the prenup regardless of whether it was legitimate or not. The litigation over this aspect of the case can easily run up hundreds of thousands of dollars.
PSYCHIATRIC PROBLEMS
When couples are going through a divorce, it puts a massive psychiatric strain on all parties. However, Mr. Ryden is known for receiving referrals of spouses who have serious psychiatric issues. Three of his recent clients have had psychiatric hospitalizations. These spouses are particularly vulnerable and susceptible to manipulation by their attorney. which makes this all the more heartwrenching.
CHAOS AROUND TEMPORARY SUPPORT ORDERS
One area of specific expertise for J&C is to create chaos at the onset of the divorce around temporary support orders. Temporary spousal and child support orders are necessary for spouses to separate their finances. Until there are temporary orders it is difficult or impossible to move forward with financial separation. J&C endeavor to avoid temporary support orders altogether, hoping to keep the joint accounts open and shared for as long as possible. What this does, when they are of course representing the NE, is the following:
1. Earner does not get tax credit for deductibility of spousal support
2. Non-earner can withdraw as much money as possible and hide away cash.
3. Non-earner can establish a new marital standard of living by increasing spending; temporary orders are necessary to limit the spending of the NE
4. More conflict is created between two parties who are divorcing who are now sharing a bank account; more letters fly back between parties which equals increased fees.
5. J&C will then come back at trial and using their in-house accountants they will calculate or miscalculate the support that "should have" been payed and demand reimbursement.
6. Beware of retroactivity clauses in any temporary orders by J&C.
If J&C cannot get the parties (ie the opposing spouse) to leave the joint accounts open, they will try for a hybrid approach, that will create further chaos and litigation opportunities down the road. For example, they will get the E spouse to pay a low level of support (below guideline) and get that spouse to sign a stipulation with retroactivity built in. Then they will also have the E spouse pay household expenses (rent, utilities, school, etc). This turns the situation into a dog and pony show. A few years later, when the parties finally get to trial, J&C will have had their in-house accountants rack up tens of thousands of dollars calculating how much should have been paid. This will involve going through literally every receipt and check image from years of marriage. Can you imagine the amount of work this involves?
THE TEMPORARY SUPPORT GAME
When J&C have the non-earner, and the earner makes a lot of money, or has a post-separation increase in cash flow, this is a bonanza!! Temporary support orders in these instances are always high and often outrageous. J&C's goal is to lock in one of these high pendente lite orders and then put the baby to sleep, ie delay, delay, delay. This can become an extremely frustrating situation for the opposing spouse earner. It is an art form for J&C. Once they get this order, they put off all settlement conferences and trial. Possibly, their client can have a medical problem which will drag out the temporary orders for years!
DISCOVERY
God forbid if you are the Earner spouse going up against J&C. They have specific discovery strategies that will cause great pain and cost to the opposing spouse. What happens is J&C will propound extensive, extensive discovery, demanding hundreds of lines of items. The Earner spouse, of course, has much more discovery to produce than a non-earner so this becomes a massive, stressful, costly process. In the meanwhile J&C will delay the prodution of discovery from their own client for as long as possible. Remember, the ultimate goal of J&C in our opinion, is to DELAY DELAY DELAY. Each month their bills are tens of thousands of dollars. Every month of delay is equal to twenty, thirty or forty thousand dollars of income to J&C. The longer the opposing spouse takes to get their discovery the better. Meanwhile, their own client produces little to no discovery to prolong the process. Then the parties get to trial setting conference and J&C pull some minutiae out that is missing and demand the trial be delayed. This may stretch things out for months and months. Then, they make it as difficult as possible to get their own client's discovery to potentiate the delays. DISCOVERY IS A NIGHTMARE with J&C. Beware!
CUSTODY DISPUTES
When there are custody problems, in our opinion, this is not an opportunity for J&C to be "compassionate." It is a money-making opportunity. J&C are willing to file false allegations of domestic violence. They will believe anything their client says and the groupthink is frightening. Of course a custody battle will turn in to a custody evaluation. Instead of mediating or settling they will set up the battle of the century between spouses. J&C are a very well established family law firm, and they have custody experts in their back pocket who will advocate for their position vigorously. In our opinion, just like large corporations that have mediation clauses and mediators that favor the corporation, J&C has assembled experts that will favor their client.
THREATENING BEHAVIORS IN COURT
Here we highlight Mr. William Ryden. In three cases we reviewed Mr. Ryden provoked and physically entered the opposing litigants personal space in a threatening manner. Two of the cases (two different litigants) occured in the hallway of the courtroom. The third happened in the courtroom bathroom and it almost came to fisticuffs by report. Why would J&C allow this? If Mr. Ryden could get one of the opposing litigants to strike him he would immediately have the bailiff arrest that person for assault. It would be a turning point in the case. Of course this type of behavior makes Mr. Ryden appear like a vigorous advocate for his client, but the behavior is actually bullying. In our opinion, J&C have lost all sense of decorum in the past five years or so and have created a culture of legal bullying to maximize profits.
DIVISION OF BUSINESSES
Another huge profit center for J&C. When there is a business that needs to be divided, this is the gray area that J&C profit on. If the business has mixed community and separate property aspects this will be a litigation nightmare beyond belief for the primary earner. J&C will take a hardline stance from the get-go that any business, if it has even an ounce of community property in it, is all community property. They will litigate to trial the asset is 50/50, even in the presence of a prenuptial agreement stating othewise. Of course this process will become a living hell for the Earner/business operator. J&C will deny any existance of post-separation efforts or equitable allocation of the business. They will come up with a preposterous fair compensation. They will manufacture logic that has no basis in reality and ride it all the way through trial until they lose.
J&C SPECIOUS "LOGIC" AND FALSE "ARGUMENTS"
One of the amazing things about J&C is the financial arguements and logic they manufacture. They will come up with motions and replies to the court which when read seem to make sense in a bad way for the opposing client. However, careful examination of these arguments frequently shows severe errors in logic. If the judge is not on his or her toes or doesn't have the time to really look at an issue, it can be a big problem. Some examples of this include:
1. False calculations of expenses
2. Including post-separation monies in division of community assets
3. Grossly overestimating and overcalculating cash flow of the payor
4. Adding in perquisites, retirement funds and other expenses to cash-flow analysis that are not relevant
5. Inflating expenses of the non-earner spouse to increase the marital standard of living (this is a cottage industry for them)
6. Including post-separation expenses in marital standard of living calculations
7. Coming up with false "breach of fiduciary duty" issues.
TACTICS FOR MOTIONS AND HEARINGS
J&C have an aresenal of weapons when they get in the courtroom. First, they will try to disqualify any motion or order by opposing counsel for jurisdictional or procedural reasons. They seem to always do this and try to get it thrown out of court. They also often try to take over the entire hearing. The more they talk the less information the judge can get about the opposing case. If the judge states they are going to lose the issue, they have five alternate scenarios they will request of the judge. For example, in a fees hearing, let's say the judge denies the fees. They will then ask for money to be set aside in an escrow account; or ask for a limit on the opposing spouses spending, etc.
MEDIATION SESSIONS AND PRIVATE JUDGES
In our experience, these sessions are often money-making opportunities. Many of the opposing litigants told us stories where they spent 8-10-12 hours in the conference room trying to hammer out a settlement, only to be thwarted at the last minute. Remember, 10 hours of mediation is about $13,000 for J&C because they are almost always double billing with the primary attorney and assistant. The assistant seems to be there only to carry notebooks and boxes into the courtroom and to find pages in the document binders. A ridiculous waste of money at $4-500 per hour.
J&C have a bevy of private judges who are also aligned with them. Remember, many of these attorneys go way back. Again, a private judge session can be another 10-12 hours of money-earning. One litigant told us a story that a 12 hour mediation session ended with the J&C attorney refusing to show a spousal support offer to his client.
Mr. Ryden is known for packing up his briefcase and walking out of mediation sessions at the slightest perturbation. Of course, when Mr. Ryden walks, there is no recourse to the opposing spouse. They have to pay their share of the aborted session.
DELAY DELAY DELAY
We believe J&C want to delay every case for as long as possible. As mentioned, when they are billing tens of thousands of dollars a month, it makes sense for them. Here are some techniques they use to delay everything:
1. Set up mediation sessions where there is no intention of settling
2. Set up mediation sessions and then they have their client cancel at the last minute
3. Whenever the judge offers a date for a future hearing or process they say "I'm out of town in July." Then they have their client say "I'm taking the kids on vacation in August." Surprisingly, judges don't get this. They almost always agree.
4. Delay all trial-setting conferences for discovery "problems."
5. Delay custody appointments and home-visits as long as possible.
INFLATED ATTORNEY'S FEES
J&C will rack up fees in the millions of dollars. We learned from several litigants that they tell their clients "there are two prices - full price if your spouse has to pay the fees and a big discount if you have to pay." J&C will go into a fees hearing with outrageous costs and then ask for half to look "reasonable." The family law system of course turns a case of the non-earner into a contingency case for J&C. No earner will spend that kind of money when they are working for it. Instead, a disgruntled non-earning spouse will be convinced by J&C to seek revenge by litigating as much as possible. The NE doesn't care; the E will have to pay it so it is meaningless to them other than to hurt their soon to be ex-spouse.
APPPEALS
J&C love to appeal. They usually lose, but it earns them more money. Here is a case where Mr. Ryden tried to take a case involving a federal pension out of the federal court, so he could get attorneys fees. He lost the case after racking up a million dollars in fees that his client was stuck with.
https://www.youtube.com/watch?v=EaCy7g_Q_tg
Imagine the pain it causes a family to have to go through the appeal process and extend the litigation for a year or years. No one can move on from the divorce. The spouses remain enemies fighting in the world of abstract law. How does this help the children??
WHEN DOES IT STOP
In the stories we heard the litigation only stopped when:
1. Their client realized the toxic nature of the J&C process
2. The court punished them for unnecessary and overly aggressive litigation
3. The parties ran out of money
4. Their client ran out of money post-judgement