California, United States of America
The following excerpt is from Transamerica Ins. Co. v. Superior Court, 29 Cal.App.4th 1705, 35 Cal.Rptr.2d 259 (Cal. App. 1994):
4 The defense of unclean hands is based upon the same factual foundation as the claims of estoppel and waiver. Without passing on the merits of either estoppel or waiver, we find that the defense of unclean hands to this writ proceeding does not prevent our review of the issues hereafter discussed. (Dierssen v. Civil Service Commission (1941) 43 Cal.App.2d 53, 57-58, 110 P.2d 513.)
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