California, United States of America
The following excerpt is from Hansen v. Jacobsen, 186 Cal.App.3d 350, 230 Cal.Rptr. 580 (Cal. App. 1986):
We have determined that the lack of clarity in claimants' moving papers and oral argument in failing to distinguish a "notice of lien" from a "lien," [186 Cal.App.3d 355] coupled with respondent's opposition to a "lien," misled the trial court on the nature of the issue before it. We perceive the issue presented below, and to us, as a narrow one: whether a previously discharged attorney who has a contractual lien on a prospective judgment may file a notice of lien in the pending action. We have found no published decision addressing the issue. However, to a great extent the law favoring attorneys' liens is well settled (see Cetenko v. United California Bank (1982) 30 Cal.3d 528, 179 Cal.Rptr. 902, 638 P.2d 1299), and we find that an affirmative answer to our question follows from previous decisions in the area.
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