California Demurrer

Practitioner's guide to CCP § 430.10 — mechanics, strategy, and claim-specific playbooks derived from Orange County and Santa Clara County tentative rulings.

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Load-Bearing Authorities

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Mechanics

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Strategy

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Claim Types

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Tactical Patterns

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After the Ruling

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Playbooks by Claim Type

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Fraud Claims

Specificity, concealment, reliance, SOL, economic loss rule, and Rattagan v. Uber (2024).

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Contract Claims

Breach of contract, implied covenant, quasi-contract, statute of frauds, and specific performance.

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UCL & Consumer Claims

UCL § 17200, CLRA, and FAL — standing, three prongs, remedies, and safe harbors.

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Statute of Limitations

Discovery rule, equitable tolling, continuous accrual, Government Claims Act, and incurability analysis.

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Negligence

Duty, breach, causation, and damages for negligence, premises liability, NIED, and professional negligence.

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Business Torts

IIPEA, intentional interference, conspiracy, aiding and abetting, alter ego, and CUTSA preemption.

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Defamation

Specificity, fact vs. opinion, litigation privilege, common interest privilege, trade libel, actual malice.

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Elder Abuse (W&I § 15600)

Status, neglect, financial abuse, corporate ratification, and enhanced remedies under W&I § 15600.

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PAGA

LWDA notice, standing, Viking River arbitration split, Estrada manageability, and 2024 reform.

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Insurance Bad Faith

Waller coverage threshold, genuine dispute doctrine, Moradi-Shalal, Brandt fees, and Cumis counsel.

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Employment Claims (FEHA)

Prima facie elements, adverse action, CRD exhaustion, Tameny public policy, and § 1102.5 whistleblower.

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Legal Malpractice

But-for causation, case within a case, fiduciary duty overlap, and RPC 1.4.2(b) rescission.

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Privacy & CIPA

Reasonable expectation of privacy, living person requirement, and intersection with other privacy torts.

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Other Claims

IIED, habitability, Knox-Keene preemption, ERISA preemption, and interference with economic relations.

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