Memorandum of Decision
ALAN JAROSLOVSKY, Bankruptcy Judge.
California Code of Civil Procedure section 704.070 permits a debtor to exempt seventy-five percent of paid earnings that were paid to an employee within 30 days of levy. Section 706.011(a) defines such earnings as "compensation payable by an employer to an employee for personal services performed by such employee, whether denominated as wages, salary, commission, bonus, or otherwise."
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