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Batra v. Hart CA4/1
Dr. Munish K. Batra appeals from a judgment in favor of Hoyt Hart on Batra's complaint for breach of three 2014 promissory notes and Hart's affirmative defense of setoff for usurious interest Hart paid on a 2010 promissory note. Batra contends we must reverse the judgment because the court failed to determine the amount due under the 2014 promissory notes and the determination was a necessary predicate to determining whether the interest Hart paid on the 2010 promissory note was usurious. Batra also contends we must reverse the judgment because the court's statement of decision was legally deficient in multiple respects.
We conclude the issue of Batra's damages for Hart's breach of the 2014 promissory notes was not before the court at trial because the parties stipulated the trial would proceed only as to equitable issues. We further conclude there were no deficiencies in the court's statement of decision requiring reversal of the judgment.

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