In Remainders, Inc. v. Bartlett (1963) 215 Cal.App.2d 295, the assignee of a law firm sued a defendant to recover attorney fees and costs for legal matters the firm had handled for the defendant.
It sought to foreclose an oral lien on real property allegedly given as security for the payment of fees.
The court refused to enforce the alleged oral lien based on Code of Civil Procedure section 1971. (Id. at p. 299.)