Cota v. Excellence RE Real Estate CA2/7
INTRODUCTION Excellence RE Real Estate, Inc. (Excellence) appeals the entry of default and default judgment against it after it was sued by Lorraine Cota. Excellence argues the trial court erred by awarding punitive damages because Cota failed to provide the requisite notice she was seeking punitive damages under Code of Civil Procedure section 425.115.1 We agree and reverse.

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