What are the elements of an open book account cause of action?

California, United States of America


The following excerpt is from State Comp. Ins. Fund v. Readylink Healthcare, Inc., 264 Cal.Rptr.3d 68, 50 Cal.App.5th 422 (Cal. App. 2020):

reasonable value of those services; (3) the services were rendered at the request of the defendant; and (4) the services were unpaid. ( Haggerty v. Warner (1953) 115 Cal.App.2d 468, 475, 252 P.2d 373.) The elements of an open book account cause of action are: "1. That [plaintiff] and [defendant] had financial transactions ... ; [] 2. That [plaintiff] ... kept [an] account of the debits and credits involved in the transactions; [] 3. That [defendant] owes [plaintiff] money on the account; and [] 4. The amount of money that [defendant] owes [plaintiff]." ( CACI No. 372.) For every cause of action that SCIF has asserted, SCIF must establish the amount of money due (in the form of damages, reasonable value of services, or money due on an open book account).

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