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DiPIRRO v. AMERICAN ISUZU MOTORS, INC.

No. A102961.

14 Cal.Rptr.3d 787 (2004)

119 Cal.App.4th 966

Michael DiPIRRO, Plaintiff and Appellant, v. AMERICAN ISUZU MOTORS INC., et al., Defendants and Respondents.

Court of Appeals of California, First District, Division Five.

June 23, 2004.

Attorney(s) appearing for the Case

Sheffer & Chanler and Clifford A. Chanler, Pleasanton, for Plaintiff and Appellant.

Nossaman, Guthner, Knox & Elliott, Carol René Brophy and Deborah E. Beck, San Francisco, for Defendants and Respondents.

Certified For Partial Publication.*

SIMONS, J.

If a private plaintiff in a Proposition 651 lawsuit fails to provide a required certificate of merit 60 days before filing the complaint, may that failure be cured by providing the certificate after litigation has begun? In the published portion of this opinion, we conclude that providing the certificate postlitigation is not a cure because it impairs one...

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