The following excerpt is from Williams v. Biter, 1:14-cv-02076-DAD-EPG (PC) (E.D. Cal. 2017):
reasonable belief that it was lawful. We see no basis for imposing on the plaintiff an obligation to anticipate such a defense by stating in his complaint that the defendant acted in bad faith." Gomez v. Toledo, 446 U.S. 635, 640 (1980).
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