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p0449 Civil Code section 1354, which requires service of a demand for alternate dispute resolution before an action can be brought to enforce the CC&Rs of a common interest development, is satisfied if the attorney for the party seeking enforcement effects service by mail; an objection based on the failure of the recipient of the mailed demand to sign a return receipt is waived if not raised in the trial court.CitationCABRINI VILLAS HOA v HAGHVERDIAN (ADR Notice) 111 Cal.app.4th 683 [See: CivC 1354; Children's Hosp v Bonta 97 Cal.app.4th 740]
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