Code of Civil Procedure Section 918.5, subdivision (a) states: "(a) The trial court may, in its discretion, stay the enforcement of a judgment or order if the judgment debtor has another action pending on a disputed claim against the judgment creditor. (b) In exercising its discretion under this section, the court shall consider all of the following: (1) The likelihood of the judgment debtor prevailing in the other action. (2) The amount of the judgment of the judgment creditor as compared to the amount of the probable recovery of the judgment debtor in the action on the disputed claim. (3) The financial ability of the judgment creditor to satisfy the judgment if a judgment is rendered against the judgment creditor in the action on the disputed claim." In Erlich v. Superior Court (1965) 63 Cal.2d 551, the California Supreme Court said: "A judgment debtor who by assignment or otherwise becomes the owner of a claim against his judgment creditor in equity may have his claim set off against the judgment, and the fact that the claim has not itself been reduced to judgment is not an obstacle. Nor must the claim of the judgment debtor be liquidated ; it being sufficient that the claim though unliquidated has matured. . . . Finally, the insolvency of the party against whom the relief is sought affords sufficient ground for invoking this equitable principle. " (Erlich, at p. 555.) In Airfloor Co. of California, Inc. v. Regents of University of California (1979) 97 Cal. App. 3d 739, the court followed Erlich and said: "The rationale for this rule is based on equitable principles for to hold otherwise unfairly deprives the judgment debtor of not only his right of set-off, but with an impecunious creditor, the right to receive any recovery whatsoever. In exercising its discretion, the court must consider the likelihood of the judgment debtor prevailing in the other action and the financial ability of the judgment creditor to satisfy a judgment on the disputed claim if such should be rendered." (Airfloor Co. of California, Inc. v. Regents of University of California, supra, 97 Cal. App. 3d 739, 741.) The Law Revision Commission followed the principles expressed in these cases in recommending enactment of section 918.5. It said: "The rationale for the rule is based on equitable principles that not to stay enforcement of the judgment unfairly deprives the judgment debtor not only of the right to offset but also--with an impecunious creditor--of any right to recover at all." (Conformity Revisions, 15 Cal. Law Revision Com. Rep. (1980) pp. 2648-2649.) In order to prevail under this section, the judgment debtor must convince the trial court to exercise its equitable discretion to protect the judgment debtor's right of set-off, particularly when the judgment creditor is insolvent. Respondent cites the appropriate rule: "Since the trial court's decision was one subject to an exercise of its equitable powers, . . . the only issue before us on this appeal is whether that discretion was so abused that it resulted in a manifest miscarriage of justice. " (Wm. R. Clarke Corp. v. Safeco Ins. Co. of America (2000) 78 Cal.App.4th 355, 359.) In Dolan v. Buena Engineers, Inc. (1994) 24 Cal.App.4th 1500: "'Where the issue on appeal is whether the trial court has abused its discretion, the showing necessary to reverse the trial court is insufficient if it presents facts which merely afford an opportunity for a different opinion: "An appellate tribunal is neither authorized nor warranted in substituting its judgment for the judgment of the trial judge. To be entitled to relief on appeal from the result of an alleged abuse of discretion it must clearly appear that the injury resulting from such a wrong is sufficiently grave to amount to a manifest miscarriage of justice; . . ." ' " (Id. at p. 1504.)