California, United States of America
The following excerpt is from Emma Court LP v. United Am. Bank, A144462 (Cal. App. 2017):
11. In light of this conclusion, we will not address defendants' argument that the award of attorney fees to Lighthouse was appropriate pursuant to the collateral source rule. (See Mize-Kurzman v. Marin Community College District (2012) 202 Cal.App.4th 832, 872 [" 'Simply stated, the collateral source rule provides that "if an injured party receives some compensation for his [or her] injuries from a source wholly independent of the tortfeasor, such payment should not be deducted from the damages which the plaintiff would otherwise collect from the tortfeasor' "].)
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