Section 1328. Discharge of attachment

1. A defendant whose property or debt
  has been levied upon may move, upon notice to the claiming authority and
  the  claiming  agent, for any order discharging the attachment as to all
  or part of the property or debt upon payment  of  the  claiming  agent's
  fees and expenses, if any. On such a motion, the defendant shall give an
  undertaking,  in  an  amount  equal to the value of the property or debt
  sought to be discharged, that the defendant will  pay  to  the  claiming
  authority  the  amount  of  any  judgment  which may be recovered in the
  action against him or her, not exceeding the amount of the  undertaking.
  Making a motion or giving an undertaking under this section shall not of
  itself constitute an appearance in the action.
    2.  When  a motion to discharge is made in the case of property levied
  upon pursuant to a claimed violation of the tax law, the amount  of  the
  undertaking required shall be an amount equal to the lesser of:
    (a) The amount specified in subdivision one of this section; or
    (b)  The  aggregate  amount  of all unpaid tax and civil penalties for
  such violation.