The following excerpt is from Allen v. Kramer, CASE No. 1:15-cv-01609-DAD-MJS (PC) (E.D. Cal. 2016):
1, 2016). In Gregge v. Kate, 2015 WL 2448679, at *10 (E.D. Cal. May 20, 2015), the court collected multiple cases demonstrating just how unsettled the law was:
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