California, United States of America
The following excerpt is from Bergen v. Wood, 14 Cal.App.4th 854, 18 Cal.Rptr.2d 75 (Cal. App. 1993):
We make the additional observation that if cohabitation were not a prerequisite to recovery, every dating relationship would have the potential for giving rise to such claims, a result no one favors.
Milian v. De Leon (1986) 181 Cal.App.3d 1185, 226 Cal.Rptr. 831, which allowed recovery
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