In Arc Investment Co. v. Tiffith (1958) 164 Cal. App. 2d Supp. 853, the plaintiff in an underlying action obtained a default judgment against the defendant on a promissory note. The plaintiff then garnished the defendant's wages three times, despite the defendant's claim of full exemption. Recognizing an action for abuse of process against the plaintiff, the appellate court stated that the issuance of further writs would prejudice the defendant's employment and result in the expense of reasserting his claim of exemption each time. Tiffith, supra, 164 Cal. App. 2d at page Supp. 855. The successive seizures of the defendant's exempt property gave rise to a claim of abuse of process. Tiffith, supra, 164 Cal. App. 2d at page Supp. 856.