B. The Trial Court Did Not Err in Allowing Attorneys’ Fees as
Enforcement Costs
The trial court’s award of attorneys’ fees met both
requirements for allowing postjudgment attorneys’ fees under
section 685.040, as set forth Jaffe, supra, 165 Cal.App.4th at
page 935 and its progeny. As to the first requirement, Aprea does
not dispute that the $27,240 in attorneys’ fees awarded by the
trial court—which included only those fees incurred in connection
with litigating the cost motion—were fees “incurred to ‘enforce’ a
judgment.” With respect to the second requirement that “the
underlying judgment had to include an award for attorney fees
pursuant to Code of Civil Procedure section 1033.5,
subdivision (a)(10)(A)” (Jaffe, at p. 935), Aprea argues the
attorneys’ fees included in the judgment were not authorized by
contract because the judgment (on Judicial Council form JUD-
100) did not mention the lease, and the complaint likewise only
sought reasonable attorneys’ fees without mentioning the lease.
However, the lease was attached to the complaint, and Nash and
O’Connor’s motion for entry of default judgment likewise
attached the lease and stated in a supporting declaration that the
requested $1,000 in attorneys’ fees was “as provided for and fixed