California, United States of America
The following excerpt is from Nielsen v. Reed, H039647 (Cal. App. 2016):
Scamman v. Bonslett (1897) 118 Cal. 93 (Scamman) illustrates the application of these principles to a judicial foreclosure action. The plaintiff creditor's action did not request a deficiency judgment against the mortgagor. (Id. at p. 95.) After the mortgagor
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