California, United States of America
The following excerpt is from Elworthy v. Spiva, H037747 (Cal. App. 2013):
the buyer must restore possession to the seller. [Citation.] Such recovery of the consideration exchanged is part of restitution. [Citations.] As consequential damages, rescinding buyers or sellers may recover such items as real estate commissions paid in connection with the sale [citation], escrow expenses [citation], interest on specific sums of money paid to the other party [citation], and attorney fees in appropriate cases [citation]." (Sharabianlou, supra, 181 Cal.App.4th at pp. 1145-1146, citing Kent v. Clark (1942) 20 Cal.2d 779, 784, italics added.)
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