The following excerpt is from Ayala v. Cnty. of Imperial, CASE NO. 15cv397-LAB (NLS) (S.D. Cal. 2017):
Plaintiffs cite Parsons v. Tickner, 31 Cal. App. 4th 1513, 1523-24 (Cal. App. 2 Dist., 1995) for the proposition that the affidavit isn't required. But Parsons simply stands for the proposition that it isn't a condition precedent that must be pled. It explains that failure to file the affidavit could subject the action to a "plea in abatement" that is, a plaintiff might be required to withdraw the claim and refile it after complying. Id. at 1524.
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