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P1465 REVIEW DENIED The Conditions, Covenants and Restrictions (CC&Rs) of a homeowners association requiring that disputes between the association and the developer be decided by judicial reference does not satisfy Code of Civil Procedure section 638's requirement of a prelitigation agreement and does not require determination by judicial reference.CitationTREO @ KETTNER HOA v SUPERIOR COURT (Judicial Reference) 166 CA4 1055 [See: CCP 638; Trend Homes v Superior Court 131 CA4 950, P/AT 9/05; Grafton Partners v Superior Court 36 C4 944, P/AT 9/05]
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