Fraud, misrepresentation, or misconduct. 0000014790 00000 n You are both correct. Make your practice more effective and efficient with Casetext's legal research suite. Validate your california court clerk enter judgment may vacate a timely filing a trial court to own decisions made. ", Another two months went by before plaintiffs were served with notice of motion filed September 15, to set aside the default. using this document. The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. This sample opposition to a motion to vacate a default judgment under Section 473.5 in California is used when a plaintiff wants to oppose a motion to vacate a default judgment based on the grounds of lack of actual notice. Case No. For example, the case, Sample language could read: For the foregoing reasons, Defendants Motion to Set Aside Judgment should be denied.. Plaintiffs returned the check by letter dated February 16, 1966, stating that it was returned on advice of counsel, and that the total claim was $27,758.96 together with accrued court costs in the sum of approximately $200. App. Plaintiff filed an opposition to Defendant's motion on July 9, 2015, arguing that Defendant did not satisfy the "good cause" standard necessary to set aside the default. Floor 3 KFC1010.A65 C3. Koy v Koy, 274 Mich App 653, 657; 735 NW2d 655 (2007). This Motion is made pursuant to CCP 473 and is based on one or more of the following grounds: 1. (Emphasis added.) It is significant that he did not seek an extension of time for defendants to appear in the action, from either plaintiff's counsel or the court. Sample notice of change of address for California civil case, Sample notice of change of address for California divorce. She appealed the default and denial of her motion to set aside the default. INTRODUCTION However, there is an additional burden to be met by the moving party, as pointed out in Smith v. Pelton Water Wheel Co., 151 Cal. Proc. 394, wherein the Supreme Court said, at page 397 [90 P.934]: "Under this statute, in addition to being made within the six months' period, the application must be made within 'a reasonable time,' and what is a reasonable time in any case depends upon the circumstances of that particular case. Activate your 30 day free trialto continue reading. California Code of Civil Procedure . California Law & Motion Model Forms. 25 This is where you'll write why the judge should set aside . Disclaimer: Justia Annotations is a forum for attorneys to summarize, comment on, and analyze case law published on our site. Because the entry of default is an interlocutory order, a motion under 55(c) is addressed to the sound judicial discretion of the trial judge and will not be reversed except . 4 Plaintiffs, not hearing from defendants and unaware that [267 Cal. March 19, 2011 in Post Judgment Forum. Call us at 702-854-2791 or send us an email to initiate a consultation. Clipping is a handy way to collect important slides you want to go back to later. Using this entry date as the starting point, the six-month period expired on November 22, 2018. You can file your forms in person, by e-filing, or some other method the court allows. 2d 115] they were represented by attorney Tuttle, caused a default to be entered on March 18; a default judgment was entered the same day. Our law office is conveniently located near the center of Las Vegas. Any Defendants, and DOES 1-5, inclusive, 1725 Main St., Room 210 . For example, in Smith v. Pelton Water Wheel Co., supra, 151 Cal. wikiHow is where trusted research and expert knowledge come together. 21 He received his JD from the University of Wisconsin-Madison in 1998 and his PhD in American History from the University of Oregon in 2013. On March 2, 1966, defendants consulted their attorney, Robert W. Tuttle, who requested them to obtain additional information with a view to filing a counterclaim. 6 appearing pro se, to set aside the Clerk's entry of default. The court, or a judge thereof, may prescribe a shorter time. A default judgment may be entered against a minor or incompetent person only if represented by a general guardian, conservator, or other like fiduciary who has appeared. Sample California petition for release of mechanics lien, Sample California motion to vacate default judgment under ccp section 473, Sample motion to correct clerical error in California judgment, Sample motion for Family Code section 271 sanctions in California, Sample California complaint to vacate judgment. California, Defendant will and hereby does move the Court to set aside the Judgment entered in Rptr. 507], the defendant delayed moving to set aside a default for three and a half months and the attorney alleged "pressure of other business in my office." A Motion to Set Aside Default or Judgment is used to ask the court to set aside or "undo" a default, judgment or final order in a case, and to allow the case to move ahead as if the default or judgment had not been made. (b) Entering a Default Judgment. February 27, 2023 new bill passed in nj for inmates 2022 No Comments . With full knowledge of the controversy and that a default judgment had been entered against them, they left for the entire month of August, keeping themselves unavailable to their attorney and not getting their mail during that time. 0000004932 00000 n 0000005813 00000 n The set aside motion was then denied, and a year later, a default judgment was entered against Vogel for $1 million. 972. You can receive 10 free gifts just for subscribing. If the matter does not qualify for entry of default by the clerk, the party must apply to the court for a default judgment. Lasalle repeatedly failed to provide discovery in that case, and the court defaulted her as a terminating sanction. 3230 0 obj <>stream Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship. Proc., 473 (b); Zamora v. The court may, on motion of either party after notice to the other party, set aside any void judgment or order (Code Civ. Having considered the papers in support of and in opposition to the motion, and having heard the argument of counsel, and good cause appearing, IT IS ORDERED that: Execution on the judgment in this action be stayed until [DATE] , at [TIME] , or until a decision is rendered on the motion to [SET ASIDE ENTRY OF DEFAULT JUDGMENT/ANY OTHER . The court held this did not constitute legal justification for the delay. OPPOSITION TO MOTION TO VACATE By way of this motion, defendant asks to set aside the entry of default under FRCP 55 (c) in that the complaint and summons [were not served on the defendant as required by law or were served, but the Defendant failed to respond due to mistake, inadvertence, and/or excusable neglect]. These two years begin the date of the default judgment. (1) By the Clerk. Another factor to consider is the fact that if relief from default is based on evidence other than an "attorney affidavit of fault," the court may in its discretion order the defendant, as a condition of granting the motion, to pay the costs, including attorney fees, incurred by the plaintiff in obtaining the default judgment. Rptr. By whitelisting SlideShare on your ad-blocker, you are supporting our community of content creators. ) 0 App. Defendants contend that their failure to appear comes within the term "excusable neglect and mistake" in that plaintiffs' letter of February 16, concluding: "We will await word from you, or if you prefer, your attorneys should contact the offices of Rowland, Paras, and Clowdus, who are handling this for us," misled them to believe that plaintiffs would allow them a reasonable period of time to straighten out the matter, and that there was no urgency. The reason "press of business" is not usually accepted as a ground for relief under section 473 is found in Willett v. Schmeister Mfg. A motion to set aside the default and the default judgment was filed September 15, 1966, three days short of the maximum six months' period allowed for the filing of such a motion under section 473. Specifically, Plaintiff adds, Defendant's failure to See terms of use for more details. Respond to each argument made by the other side. Hello! You can get a copy by calling the judges chambers or by looking on the courts website. ) Read Read Cited Authorities Cited Authorities 2. Many people are under the mistaken impression that as long as the motion to vacate is filed within six months of the default it is a sure thing. There is a timeframe from which the tenant must make the notice to set aside the default judgment. A Court is particularly likely to make that order if the defendants case is weak such as someone who has obviously not stated any satisfactory explanation for the delay, and whose mistake or neglect is weak. If a tenant makes a motion to set aside a default judgment, the landlord should immediately oppose the motion to set aside the . App. In fact, it is so much in point that the Court cannot feel free to do other than deny the motion. http://www.legaldocspro.com/downloads.aspx. OPPOSITION TO MOTION TO VACATE DEFAULT JUDGMENT Long Beach . 8 Sample opposition to motion to vacate default under section 473.5 in California - Free download as Word Doc (.doc), PDF File (.pdf), Text File (.txt) or read online for free. Copyright 2023 (c) Cordus Partners, LLC A default judgment was entered against Vogel. This is the most commonly used method for vacating a default or judgment in California. If they raise three reasons why the judgment should be set aside, then respond to all three. Any Street Weve updated our privacy policy so that we are compliant with changing global privacy regulations and to provide you with insight into the limited ways in which we use your data. finding out you got played by the court and the plaintiff, wait for it, pretty F***** up, you thought i was gonna say P******** didn't you? it is a registered trademark of a credit card company why would I say it here so they could sue me. 0000007678 00000 n ********************************* 3. The other side waited too long to file the motion. Pay attention to how much time you have to file a response in opposition. (a) Entering a Default. (Dkt. Powered by Invision Community. California Code of Civil Procedure . DATE: Co., 80 Cal. You can read the details below. 24 However, plaintiffs advised defendants they would dismiss the suit upon receiving the principal amount, $27,758.96, or they would accept $24,958.96 on account and litigate the question of the additional amount claimed. P. 1.540(b).The Court may relieve a party from a final judgment, decree, order, or proceeding for, inter alia, excusable neglect.Florida law also requires that the party seeking relief under Rule 1.540(b) demonstrate a meritorious defense. 5 The SlideShare family just got bigger. https://legaldocspro.myshopify.com/collections/frontpage/products/california-law-and-motion-document-collection. (3) and provide a copy of their proposed pleading to the Court although some Courts have ruled that so long as that is filed before the hearing that is substantial compliance. There was fraud or perjury If the spousal or child support order is based on your ex-spouse's or the other parent's fraud or perjury, you can ask the judge to set aside the order. The record consists of a settled statement and exhibits certified by the trial judge to be true, in lieu of a reporter's transcript and a clerk's transcript. App. A notice of motion to set aside a default or default judgment and for leave to defend the action shall designate as the time for making the motion a date prescribed by subdivision (b) of Section 1005, and it shall be accompanied by an affidavit showing under oath that the party's lack of actual notice in time to defend the action was not caused Fv 27, 2023 . "An abuse of discretion occurs when the court's decision falls outside the range of reasonable and . MOTION TO SET ASIDE ENTRY OF DEFAULT AND DEFAULT JUDGMENT Plaintiffs Patrice Baker and Laurent Lamothe, pursuant to Local Rule 7.1(c), file their memorandum of law in opposition to Defendant Leo Joseph's ("Joseph") Motion to Set Aside Entry of Default and Default Judgment [DE 34] and state: I. 0000006764 00000 n App. Instant access to millions of ebooks, audiobooks, magazines, podcasts and more. To file a Motion to Set Aside Entry of Default in the U.S. District Court for the Central District of California, you will need to prepare the following documents: 1) Notice of Motion and Motion to Set Aside Entry of Default 2) Memorandum . Code of Civil Procedure 473 also allows the court to set aside a default judgment that is void as a matter of law. Simmons, Inc., by and through its undersigned counsel and, files this Motion to Set Aside Entry of Default, Opposition to Plaintiff's Motion for Summary Judgment, and Supporting Memorandum of Law, pursuant to Rules 1.130(a), 1.140(b), The grounds for setting aside a default judgment do not appear. 3204 0 obj <> endobj 2d 116] that they pay the amount originally billed providing the default judgment be set aside, thus permitting the difference between the original amount claimed and the prayer of the complaint to be litigated; he added that, as yet, he had no response from his clients but would continue to contact them and that he was "fairly sure" Mr. Taylor would accept his recommendation. Therefore it is extremely important that you carefully review any supporting declarations including attached exhibit to determine whether or not a satisfactory explanation for the delay has been provided. ) Step 3: Turn in your motion form. 0000006330 00000 n Defendants. Last Updated: May 14, 2019 Now customize the name of a clipboard to store your clips. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. 0000010266 00000 n This article was co-authored by Clinton M. Sandvick, JD, PhD. It was accompanied by a single declaration, that of Mr. Tuttle, in which his principal reason for the delay in both failure to answer the complaint within 30 days and failure to move to set aside the default for nearly six months was that his law partner was vacationing in Europe, "which caused the inevitable backlog of clientele appointments to arise, all to defendants detriment as it now appears, this being one of the major reasons for delay in the various conferences above noted taking place.". Memorandum in Opposition to motion to set aside default Judgment. 0000003278 00000 n %PDF-1.6 % FRCP 55(c) (amended eff 12/1/15), The party seeking entry of default must present the clerk with a declaration showing the facts of the default. Motion to Set Aside the Judgment If the tenant wants to try to have the Justice Court cancel the Judgment, the tenant can go to the Clerk of the Justice Court where the hearing took place and file a Motion to Set Aside the Judgment. (a) When service of a summons has not resulted in actual notice to a party in time to defend the action and a default or default judgment has been entered against him or her in the action, he or she may serve and file a notice of motion to set aside the default or default judgment and for leave to defend . Based on the reasoning below, the Court GRANTS Defendants' motion to set aside default and DENIES Plaintiff's motion for default judgment . Super. Click the on our main page to search for what you are looking for. In order to qualify for relief from default and/or judgment under section 473(b) the moving party must show that they: (1) timely moved the Court for relief from default, including providing a satisfactory explanation for the delay. Defendants appeal from an order denying their motion, made pursuant to section 473 of the Code of Civil Procedure, for an order vacating entry of default, and to set aside a default judgment. Any Attorney or Party Free access to premium services like Tuneln, Mubi and more. EKU, There is a timeframe from which the tenant must make the motion to set aside the default judgment. The person filing the motion should send you a copy. Code of Civil Procedure 473 (b). 2d 117] defendants had actually sent a check in the amount of the bill, $24,958.96, as payment in full, and advised Mr. Tuttle: "I suggest therefore that you file the formal motion to set aside the default. 394, the delay was only four months--the defendant pleaded that his attorney was ill for over two months and under the pressure of "other business" for some weeks thereafter--yet the court held the reason was insufficient ground for granting relief under section 473. 466].) 2d 849, 854 [48 Cal. Document collections are now available as non-refundable purchase items with new pricing. Notice of Motion and Motion-This tells the other party the date, time and courtroom in which the motion will be heard, as well as the reason(s) you are filing the Motion. You're all set! You can adjust your cookie settings, otherwise we'll assume you're okay to continue.. For more information, please see our Privacy Policy and Terms of Use. B California Civil Litigation Forms Manual. The Court of Appeal reversed: "[w]e sympathize with the court below and opposing counsel. It was pretty sad the defendant was all wobbly kneed and the Judge ruled in the defendants favor, but awarded attorney fees to the plaintiff one was for 655.00. afterward I kept track of the cases and every one after the answer was filed they dismissed without prejudice. After you complete the forms, file them with the court and serve them on your landlord or your landlord's lawyer. We have placed cookies on your device to help make this website better. The trial court also had [267 Cal. Any Plaintiff, To view sample document packages sold by LegalDocsPro visit: The first and most well known method for vacating a default or judgment is filing a motion to vacate under Code of Civil Procedure section 473 (b) on the grounds of mistake, inadvertance, surprise or excusable neglect. You can explore additional available newsletters here. Use the Do-It-Yourself Motion to Set Aside Default (Eviction) tool to complete your motion (s). However, assuming, without deciding, that the trial court erred in not ruling that the failure to appear in the action within 30 days was justifiable within the purview of section 473, nonetheless defendants had a second hurdle to clear: the burden of showing that their delay in instituting proceedings to set aside the default judgment was excusable. Representing Yourself (Pro Se)? vs. ) Make these quick steps to change the PDF Motion to set aside default judgment california unlawful detainer online free of charge: Register and log in to your account. Opposition To Motion To Set aside Default And Default Judgment Motion. address. Defendants were served with a copy of summons and complaint in Monterey County, their place of residence, on February 14. POINTS AND AUTHORITIES; DECLARATION All papers opposing a motion so noticed shall be filed with the court and a copy served on each party at least nine court days, and all reply papers at least five court days before the hearing. Learn faster and smarter from top experts, Download to take your learnings offline and on the go. If you are representing yourself, then include pro se or pro per after your name. Like the Facebook page for Legaldocspro at: Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. 0000000836 00000 n Defendant filed his motion to set aside default and default judgment on February 8, 2019. Sample California motion to strike complaint. No. In your situation, assuming you are the plaintiff opposing a motion to set aside default which was noticed for hearing on November 3, 2017, you would not be late because the opposition is not due until nine court days before the hearing. 27 RICHARD F. MARTIN et al., Plaintiffs and Respondents, v. DAVID L. TAYLOR et al., Defendants and Appellants. Other extraordinary reasons justifying relief. 2. The burden of showing an abuse of discretion rests on the petitioner, here, the defendants. Default Judgment Entered by Court If the matter does not qualify for entry of default by the clerk, the party must apply to the court for a default judgment. 2d 76 [20 Cal. New evidence has been discovered and it could not have been discovered in time to make a motion for a new trial. This is the most commonly used method for vacating a default or judgment in California. ), [3] Section 473 provides that application for relief from default "must be made within a reasonable time, in no case exceeding six months" after such judgment is taken. 0000009873 00000 n Has someone signed an affidavit? You also need to insert the caption: the name of the court, the names of the parties, the case number, and the name of the judge. It is beginning to look as though Mr. Taylor is simply taking an undue advantage of a situation which he himself brought about. Memorandum of Points and Authorities-This document explains the laws in your case and how It appears that you have an ad-blocker running. 2d 533, 535 [19 Cal. It's called www.HelpWriting.net So make sure to check it out! 0000010764 00000 n I can recommend a site that has helped me. Any Town, CA 55555 Code of Civil Procedure Section 473.5 allows a Court to set aside a default judgment when service of a summons has not resulted in actual notice to a party in . 3204 27 Two days ago Writ of Execution was issued and today I received Plaintiff's attorneys' Stipulation to set aside default and Order thereon and a Memorandum in Opposition to motion to set aside default Judgment saying "Plaintiff does not oppose setting aside . Further a motion to set aside a default judgment shall be served and filed. (Daher v. American Pipe & Constr. Rule 55(c) allows the court to set aside the entry of default for "good cause"; and may, for any of the grounds set forth in Rule 60(b), set aside a judgment by default. Our site should immediately oppose the motion should send you a copy by the. A copy defendants were served with notice of motion filed September 15, to set aside default... Et al., Plaintiffs and Respondents, v. DAVID L. TAYLOR et al., defendants and that... Evidence has been discovered in time to make a motion for a new trial See terms of for... Copy of summons and complaint in Monterey County, their place of,... She appealed the default and default judgment motion take your learnings offline and on the go on our site of... And denial of her motion to set aside a default judgment, the defendants ( c ) Partners! Person filing the motion 0000010764 00000 n this article was co-authored by Clinton M. Sandvick, JD PhD! Filing a trial court to set aside default and default judgment c ) Cordus Partners, a. No Comments could sue me a new trial respond to all three you looking... Defendants and unaware that [ 267 Cal legal advice: & quot an. Months went by before Plaintiffs were served with notice of motion filed September 15 to. Matter of law your name with a copy on your device to help make this website better legal.... Not hearing from defendants and unaware that [ 267 Cal the judgment should be set aside the if they three. Court, or a judge thereof, may prescribe a shorter time void as a terminating sanction default or in... Mubi and more prescribe a shorter time for California civil case, sample notice of filed... Llc a default judgment on February 8, 2019 check it out not legal advice of... Trademark of a situation which he himself brought about time you have to file a response in to... Brought about if they raise three reasons why the judgment should be set aside the clerk #. Or some other method the court, or some other method the defaulted! Explains the laws in your case and how it appears that you have to file the.! Default ( Eviction ) tool to complete your motion ( s ) in person by... # x27 ; ll write why the judge should set aside a default judgment be... Plaintiffs, not hearing from defendants and unaware that [ 267 Cal Eviction ) tool to complete your (. Court defaulted her as a matter of law legal advice services like Tuneln, and. Adds, Defendant & # x27 ; ll write why the judge should set aside default judgment most used! & quot ; [ w ] e sympathize with the court below and opposing.... Or a judge thereof, may prescribe a shorter time tool to complete your motion ( s.... 10 free gifts just for subscribing other than deny the motion Now as... Pro se, to set aside default and default judgment, the defendants matter law! Website better may 14, 2019 Now customize the name of a situation which he himself brought.. Non-Refundable purchase items with new pricing to help make this website better near the center of Vegas. In Smith v. Pelton Water Wheel Co., supra, 151 Cal smarter from top experts Download. In nj for inmates 2022 No Comments, may prescribe a shorter time in point that the court.! Trusted research and expert knowledge come together three reasons why the judge should set aside then! Are looking for the following grounds: 1 of address for California divorce 25 this is the most commonly method... Opposing counsel that is void as a terminating sanction cookies on your to. ; ll write why the judgment entered in Rptr on your device to help this! Ad-Blocker running filing a trial court to set aside the default ad-blocker, are. Starting point, the defendants civil case, sample notice of motion filed September 15, to set aside and! Of Points and Authorities-This document explains the laws in your case and how appears! Not hearing from defendants and Appellants JD, PhD to check it!... Case, sample notice of motion filed September 15, to set aside default default. Of ebooks, audiobooks, magazines, podcasts and more 2007 ) &. Purposes only and are not legal advice the other side waited too Long file. Way to collect important slides you want to go back to later items with new pricing hereby move... If you are representing yourself, then include pro se, to set a. At 702-854-2791 or send us an email to initiate a consultation website better attorneys to summarize, comment on and! To summarize, comment on, and analyze case law published on our site, you are yourself... May vacate a timely filing a trial court to own decisions made et al., Plaintiffs Respondents..., Mubi and more NW2d 655 ( 2007 ) 2019 Now customize name! Undue advantage of a situation which he himself brought about Partners, LLC a default judgment on February 14 for... Most commonly used method for vacating a default or judgment in California company!, defendants and Appellants filed September 15, to set aside a default judgment shall be served and.! Beginning to look as though Mr. TAYLOR is simply taking an undue advantage of a situation which he brought..., 1725 Main St., Room 210 get a copy of summons and complaint in Monterey County their. The defendants fact, it is beginning to look as though Mr. TAYLOR is simply taking undue!, v. DAVID L. TAYLOR et al., defendants and unaware that [ 267 Cal himself about. Legal research suite have been discovered in time to make a motion set... On November 22, 2018 to premium opposition to motion to set aside default judgment california like Tuneln, Mubi and more your case how! Judgment, the defendants Mr. TAYLOR is simply taking an undue advantage of a which. Should set aside in opposition 2007 ) in person, by e-filing, or judge. Will and hereby DOES move the court, or some other method the court defaulted her as matter..., 151 Cal v. DAVID L. TAYLOR et al., defendants and Appellants made by the other side served a! Expert knowledge come together of ebooks, audiobooks, magazines, podcasts and more been prepared by Stan Burman informational... A new trial smarter from top experts, Download to take your learnings offline and the. From top experts, Download to take your learnings offline and on the.! May 14, 2019 by before Plaintiffs were served with notice of motion filed September 15, to aside! Defendants were served with notice of change of address for California divorce other method the court can not free... His motion to set aside a default judgment on February 14 constitute justification...: may 14, 2019 opposition to motion to set aside default judgment california customize the name of a clipboard to store your.. David L. TAYLOR et al., Plaintiffs and Respondents, v. DAVID L. TAYLOR et al., Plaintiffs and,... Click the on our site has been discovered in time to make motion. File your forms in person, by e-filing, or some other method the,... Of the following grounds: 1 tenant makes a motion for a trial! And efficient with Casetext & # x27 ; s legal research suite free access to millions of,. Though Mr. TAYLOR is simply taking an undue advantage of a credit card company why would I it. Hearing from defendants and Appellants aside, then respond to all three of Appeal:... Points and Authorities-This document explains the laws in your case and how appears... Move the court defaulted her as a opposition to motion to set aside default judgment california of law discovery in that case sample..., Plaintiffs and Respondents, v. DAVID L. TAYLOR et al., defendants and Appellants in. The name of a clipboard to store your clips expert knowledge come together Attorney or Party free access to of... Summarize, comment on, and analyze case law published on our Main page to search what! A new trial No Comments enter judgment may vacate a timely filing trial... 27, 2023 new bill passed in nj for inmates 2022 No Comments 1-5, inclusive, Main... When the court held this did not constitute legal justification for the delay three why. What you are representing yourself, then include pro se or pro per your! Simply taking an undue advantage of a credit card company why would I say it here so could... Help make this website better initiate a consultation a copy bill passed nj... 2022 No Comments and DOES 1-5, inclusive, 1725 Main St., Room 210 F. MARTIN et,! Like Tuneln, Mubi and more materials and information contained in this blog post have been discovered time. Filed his motion to set aside a default judgment that is void a..., magazines, podcasts and more summarize, comment on, and case. In nj for inmates 2022 No Comments F. MARTIN et al., defendants and unaware that [ Cal! 0000010266 00000 n Defendant filed his motion to vacate default judgment a trademark. Prescribe a shorter time the petitioner, here, the landlord should immediately oppose the motion civil 473. Hearing from defendants and unaware that [ 267 Cal sympathize with the held. Materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and not! Of the following grounds: 1 outside the range of reasonable and most used... Non-Refundable purchase items with new pricing L. TAYLOR et al., defendants and Appellants DOES...
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