Because she was not allowed to continue with her enforcement efforts once Swintek filed bankruptcy, Good argued that § 108(c) tolled the one-year enforcement period of her ORAP Lien, citing Miner Corp. v. Hunters Run Ltd. P'ship (In re Hunters Run Ltd. P'ship), 875 F.2d 1425 (9th Cir.1989), In re Burns, 291 B.R. at 849, and S. Cal. Bank v. Zimmerman (In re Hilde), 120 F.3d 950 (9th Cir.1997). Trustee contended that Good's ORAP Lien expired by its own terms on June 30, 2011, before her adversary complaint was filed, and that § 108(c) did not toll the one-year period.

Statutory construction begins with the language of the statute. See S. Cal. Bank v. Zimmerman (In re Hilde), 120 F.3d 950, 953-54 (9th Cir. 1997) (holding that bankruptcy trustee could not avoid an ORAP lien even though the ORAP statute does not require "perfection" of the lien); Delaney v. Superior Court, 50 Cal.3d 785, 798, 268 Cal.Rptr. 753, 759, 789 P.2d 934, 940 (1990). If the language of the statute is clear and unambiguous, it must be followed, and the statutory analysis ends.

Statutory construction begins with the language of the statute. See S. Cal. Bank v. Zimmerman (In re Hilde), 120 F.3d 950, 953-54 (9th Cir. 1997) (holding that bankruptcy trustee could not avoid an ORAP lien even though the ORAP statute does not require "perfection" of the lien); Delaney v. Superior Court, 50 Cal.3d 785, 798, 268 Cal.Rptr. 753, 759, 789 P.2d 934, 940 (1990). If the language of the statute is clear and unambiguous, it must be followed, and the statutory analysis ends. Id.; Rossi v. Brown, 9 Cal.4th 688, 694, 38 Cal.Rptr.2d 363, 366, 889 P.2d 557, 560 (1995). In 1982, California enacted a comprehensive Enforcement of Judgments Law ("EJL") governing the enforcement of all civil judgments in California. Hon. Alan M. Ahart, Cal. Practice Guide: Enforcing Judgments Debts § 6:1-6:2 (The Rutter Group 2002); CCP §§ 680.010 — 709.030.

Good served the debtor with the order the same day and thus created a one-year "ORAP lien" encumbering the debtor's personal property under California Code of Civil Procedure § 708.110(d). SeeS. Cal. Bank v. Zimmerman (In re Hilde ), 120 F.3d 950, 956 (9th Cir. 1997) ("[A]n ORAP lien is created simply by service on the debtor of an order to appear for a debtor's examination ....").In August 2010, the debtor filed a Chapter 7 bankruptcy petition, and Daff became the bankruptcy estate's trustee.

The effect of this status is governed by state law. In re Hilde, 120 F.3d 950, 952 (9th Cir.1997).           I determine that California law governs the rights of the trustee as a judgment lien creditor in the present case.

The effect of this status is governed by state law. In re Hilde, 120 F.3d 950, 952 (9th Cir.1997). I determine that California law governs the rights of the trustee as a judgment lien creditor in the present case.

In re Raiton, 139 B.R. 931, 934 (9th Cir. BAP 1992); see generally Ahart, Enforcing Judgments and Debts, § 6:145 at 6A-44 (enumerating the types of judicial liens available to judgment creditors). Ms. Weinberger could have cited In re Hilde, 120 F.3d 950, 952 (9th Cir. 1997) to argue her lien is enforceable against the Trustee because she has a contractual lien recognized under Civil Code § 2881 with no state law mechanism of perfection. Indeed, Article 9 excludes her lien from its statutory perfection scheme thereby confirming the lien need not be perfected. However, upholding the lien against the Trustee would turn Hilde's rationale on its head.

In re Raiton, 139 B.R. 931, 934 (9th Cir. BAP 1992); see generally Ahart, Enforcing Judgments and Debts, § 6:145 at 6A-44 (enumerating the types of judicial liens available to judgment creditors). Ms. Weinberger could have cited In re Hilde, 120 F.3d 950, 952 (9th Cir. 1997) to argue her lien is enforceable against the Trustee because she has a contractual lien recognized under Civil Code § 2881 with no state law mechanism of perfection. Indeed, Article 9 excludes her lien from its statutory perfection scheme thereby confirming the lien need not be perfected. However, upholding the lien against the Trustee would turn Hilde's rationale on its head.

Ms. Weinberger could have cited In re Hilde, 120 F.3d 950, 952 (9th Cir.1997) to argue her lien is enforceable against the Trustee because she has a contractual lien recognized under Civil Code § 2881 with no state law mechanism of perfection. Indeed, Article 9 excludes her lien from its statutory perfection scheme thereby confirming the lien need not be perfected.

We conclude that the bankruptcy court was correct because, under California state law, a lien is created when it is served on the debtor. Cal. Civ. Proc. Code § 708.110(d); see also S. Cal. Bank v. Zimmerman (In re Hilde), 120 F.3d 950, 953 (9th Cir. 1997) ("A lien is created on all of the debtor's nonexempt personal property when the debtor is served with an order to appear for a debtor's examination."). II. Brewer had the burden of proving when the PCF-CalComm assignment became effective.