The following excerpt is from Profit Sharing Plan v. Kahrilas (In re Kahrilas), Adv No: 1:11-ap-01409-MT, Case No.: 1:11-bk-13182-MT (Bankr. C.D. Cal. 2014):
Plaintiffs correctly point out that, in California, the parol evidence rule provides for certain exceptions, including establishing fraud. Cal. Civ. Proc. Code 1856(g); see also Tenzer v. Superscope, 39 Cal.3d 18 (Cal. 1985). Here, Plaintiffs are not seeking to enforce or void the written agreement; instead, they are seeking a judgment of nondischargeability and damages for fraud in the inducement. Thus, the parol evidence rule does not apply in this case.
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