Illinois Appellate Court
Civil Court
Liens
Collections
No claim can achieve lien status by service of citation to discover assets until claim has first been reduced to enforceable judgment. Claim for post-judgment attorney fees incurred in collection of underlying judgment can only become a lien on judgment debtors' property in possession of third party after claim has been reduced to enforceable judgment and citation to discover assets has been served per Section 2-1402 of Code of Civil Procedure.