Farley

BACKGROUND

I. Operative Complaint, Default Judgment, and Attempts to Enforce the Judgment

According to the first amended complaint (FAC), Rivera owned and operated

Crown City, a forklift service and repair business. Farley was employed by Crown City

and Rivera from August 2016 to May 2017. The FAC alleged causes of action for

assault; hostile work environment (sexual harassment); failure to prevent discrimination,

harassment, and retaliation; negligence; wrongful constructive termination in violation of

public policy; failure to provide accurate itemized wage statements; intentional infliction

of emotional distress; and negligent infliction of emotional distress.

The superior court clerk entered the default of Rivera and Crown City in August

2018. In March 2019, the trial court entered a default judgment against Crown City and

Rivera in the amount of $990,052.89. The court issued a writ of execution in July 2019.

Farley was unable to collect on the default judgment through the writ of execution, and

2 the court ordered Rivera to appear for a judgment debtor’s examination. He failed to

appear for the examination. In December 2020, the court ordered that a civil…