Meza v. Portfolio Recovery Associates, LLC (Cal.) – When Creditor Uses Declaration in Lieu of Live Testimony in Limited Civil Case, Affiant Must Be Available for Service Within 150 Miles of Trial in Some Circumstances
Summary: The California Supreme Court has held that when a creditor proffers a declaration in lieu of live testimony in a limited civil case, the affiant must be available for service of process within 150 miles of the place of trial, under some circumstances. [Meza v. Portfolio Recovery Associates, LLC, 2019 Westlaw 641517 (Cal.).]