California, United States of America
The following excerpt is from Estate of Shartsis v. Bronken, D069658 (Cal. App. 2016):
"A party may waive his or her right to a written statement of decision. [Code of Civil Procedure s]ection 632 provides that '[t]he statement of decision shall be in writing, unless the parties appearing at trial agree otherwise.' (Italics added.)" (Whittington v. McKinney (1991) 234 Cal.App.3d 123, 129-130.) The parties here waived the right to a statement of decision at the April 23, 2014 hearing by agreeing that the trial court's oral ruling would serve as the statement of decision.
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