California, United States of America
The following excerpt is from Cal. Clean Energy Comm. v. Cnty. of Placer, C072680 (Cal. App. 2015):
We conclude the summons issue is forfeited for failure to raise it in the trial court. In civil cases, the statute of limitations is an affirmative defense that is forfeited if not appropriately invoked in the trial court. (Adams v. Paul (1995) 11 Cal.4th 583, 597.)
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