California, United States of America
The following excerpt is from Salton Community Services Dist. v. Southard, 256 Cal.App.2d 526, 64 Cal.Rptr. 246 (Cal. App. 1967):
Although the elements essential to the defense of equitable estoppel differ from those essential to the defense of waiver, the circumstances in a given case may support both defenses. (Gen. see Bastanchury v. Times-Mirror Co., 68 Cal.App.2d 217, 240, 156 P.2d 488.)
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