After securing a $600K judgment against Johnson, plaintiff sued him again to set aside a fraudulent transfer by which Johnson attempted to avoid execution of the judgment. After two years of litigation on the fraudulent transfer suit, plaintiff filed a memorandum of post-judgment costs seeking to collect attorney fees and costs it expended in the second suit. To thwart that effort, defendant finally send plaintiff a check for the amount of the original judgment plus interest and demanded entry of a full satisfaction. Plaintiff cashed the check but entered only a partial satisfaction, noting it had already filed a memorandum seeking another $225K in fees and costs. Held, acceptance of the check did not bind plaintiff to enter a full satisfaction. Gray1 CPB, LLC v. SCC Acquisitions, Inc. (2015) 233 Cal.App.4th 882 is distinguishable because there, the judgment debtor paid in full before the judgment creditor had filed a court pleading seeking post-judgment costs; whereas, here, the memo. of post-judgment costs was filed before defendant sent the check. Also, plaintiff was entitled to recover post-judgment fees and costs incurred in the second suit even though it had not yet prevailed in that action. CCP 685.040 does not condition award of post-judgment costs on the judgment creditor being a prevailing party in follow-on litigation. Under CCP 685.070, the judgment creditor must seek the post-judgment costs within 2 years after they are incurred and before satisfaction of judgment, but it also does not require successful conclusion of follow-on litigation.