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[Attorney name]
[Address]
[Telephone number]

Attorney for Plaintiff, [name]

xxx Court, County of xxx
[xxx District]

xxxxxx ) No. xxx
Plaintiff(s) )
vs. ) CERTIFICATE OF RELIANCE ON
) [RES IPSA LOQUITUR] [AND
xxxxxx ) ON] [FAILURE TO INFORM]
Defendant(s) ) (CCP 411.35(d))
__________________________)

[Name] declares:

1. I am the attorney for plaintiff, [name], in this action.

2. This action is one for damages arising out of professional negligence.

3. A certificate of merit is not required because plaintiff intends to rely solely on [the doctrine of res ipsa loquitur] [and on] [defendant [name]'s failure to inform plaintiff of the consequences of a procedure].

I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Date: xxxxxx _______________________
[Typed name]
Attorney for xxxxxx

[This certificate must be filed when the complaint is filed, in contrast to the certificate of merit, which must be filed on or before the service of the complaint.]

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