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News & Press: Court Cases

Foreclosure/Unlawful Detainer

Tuesday, January 15, 2019  
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Dr. Leevil, LLC v. Westlake Health Care Center
Cal. Supreme Court (S241324) 12/17/18

Under C.C.P. Section 1161a(b), after a trustee's sale, perfection of title, which includes recording the trustee's deed, is necessary before the new owner serves a three-day written notice to quit on the possessor of the property. Accordingly, an unlawful detainer action cannot proceed where the three-day notice is served before recordation of the trustee's deed, even where the trustee's deed is recorded prior to filing the action.


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