The following excerpt is from Avila v. Willits Envtl. Remediation Trust, 633 F.3d 828 (9th Cir. 2011):
4. In California this type of prima facie order is also known as a Cottle order, after Cottle v. Superior Court, 3 Cal.App.4th 1367, 5 Cal.Rptr.2d 882 (1992).
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