California, United States of America
The following excerpt is from Wal-Noon Corp. v. Hill, 119 Cal.Rptr. 646, 45 Cal.App.3d 605 (Cal. App. 1975):
'4. Inasmuch as this action was not predicated on the lease, and plaintiffs, in any event had breached the lease, attorney's fees will not be allowed (See as to requirements of notice Sieber v. Blanc (1888) 76 Cal. 173, 174 (18 P. 260); McNally v. Ward (1961) 192 Cal.App.2d 871, 884 (14 Cal.Rptr. 260)).'
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