What is the scope of discovery that a judgment creditor can obtain from a third party in a judgment debtor examination? Extensive, according to the court in Yolanda’s, Inc. v. Kahl & Goveia Commercial Real Estate, 11 Cal. App. 5th 509 (2017), a recent decision by the Second District Court of Appeal concerning post-judgment discovery efforts which reaffirms the State of California’s long-standing public policy to “leave no stone unturned in the search for assets which might be used to satisfy the judgment.”

Background Facts