California, United States of America
The following excerpt is from Alcone v. SLV Assocs., LLC, G051813 (Cal. App. 2016):
But as plaintiff points out, "two years had not passed since the time . . . Bolanos first met the required paralegal qualifications, and [defendants] presented no evidence that it had . . . [or] that the certification required by subdivision (d) was ever triggered." (See Ellis v. Toshiba America Information Systems, Inc. (2013) 218 Cal.App.4th 853, 889 [rejecting argument "that compliance with the educational requirements of Business and Professions Code section 6540 is in every case a
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