Does a promissory note constitute an enforceable contractual obligation to reimburse the County for its defense costs?

While the Attorney General may be correct that the promissory note constituted an enforceable contractual obligation to reimburse the County's defense costs, this would not provide a basis for affirming the trial court's order. Contracts are enforced through civil proceedings, following the filing of a complaint and service of process. Neither the Penal Code nor the promissory note contains a provision waiving or abbreviating normal civil process for the enforcement of this type of contractual obligation. (See Bradley v. Superior Court (1957) 48 Cal.2d 509, 519-520, 310 P.2d 634 [spousal support obligation in property settlement could not be enforced through criminal contempt proceedings].)