There are numerous a bankruptcy proceeding situations which might be registered that happen to be identified based on the chapters in the individual bankruptcy code. The particular six fundamental forms of cases include Chapters Seven, Nine, 12, 14, 12 as well as 15. The debt case submitted is usually dependent upon the from the credit card debt, whatever assets and valuations, and also the latest wages of the particular debtor. Chapter 7 bankruptcy as well as Thirteen are the most popular cases submitted within the individual bankruptcy courtroom through people. Chapter 7 bankruptcy filings typically include cases when your consumer concurs to turn over his property and also qualities in line with the provisions in the bankruptcy signal. Phase Being unfaithful insures the actual rights associated with economically troubled municipality to extract by way of credit card debt reorganization. The rehab of your company by means of credit card debt reorganization can be found in Part 11 with all the conditions signing up to companies as well as relationships. Section 12 circumstances either can end up being registered with the consumer with a voluntary basis or the credit card companies may well document the request them selves provided that these people fulfill the court requirements.
Source: freefinancearticles.info
Video: Attorney Marc Whitehead Has Solutions for Debt Relief
Don?t Wait to Seek Debt Help
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Source: momsgetreal.com
Debt Relief Makes Financial Woes Manageable
If opening your credit card bills sending you in a state of panic, you should consider applying for debt relief. Debt relief is an option for consumers who have thousands owning in unsecured debt, but don?t want to file for bankruptcy. Bankruptcy is not the only solution to your financial woes Bankruptcy will destroy your credit rating for at least seven years and should really only be entertained when the sum is high and repayment seems unimaginable. This should really be a last resort option to relieve debt. A Consumer Proposal may be right for you A consumer interested in applying for relief meets with a Certified Debt Arbitrator to discuss how much money is owed and to whom. The Arbitrator then puts together a consumer proposal and contacts the creditors to see if they accept the proposal. A consumer proposal is usually based on paying back a percentage of how much you owe. For example, for every dollar you owe the proposal says you will pay back 30 cents. This means you would be paying back 30 per cent of your debt. The creditors may accept or reject the proposal, and if it?s rejected, a counter-proposal may be filed. Please note that only unsecured debts are applicable. If you have a mortgage or a loan tied to your home, car, or a co-signer, that doesn?t qualify because if you were to default on your payments, they get something in exchange. Money owed to a credit card company qualifies and in some cases student loans qualify, but only if a certain numbers of years have passed since you were last registered as a student. Reasons a consumer proposal works If consumers are feeling stressed about owing money, they tend to stay home and not spend money. This is bad for the economy, so a consumer proposal helps to relieve the financial burden and stress, while allowing consumers to still be out supporting the economy. Many companies that assist you in finding relief also provide counseling to get control of your spending and understand how to get your finances work for you. The consumer proposal consolidates all your unsecured debts into one low monthly payment to give you more cash flow. If you file for bankruptcy, your creditors get nothing. A consumer proposal means that they are getting a portion of what is owed to them. It?s better to get something than nothing. If you?re feeling overwhelmed with outstanding bills that seem impossible to pay, find out your options, because bankruptcy is not always the best course of action. A certified arbitrator will be able to help you determine the best way to relieve your financial burden and get back to enjoying your life. There are many companies offering assistance to those with financial troubles. Some charge a fee up to $1,000 for preparing your consumer proposal, while others are non-profit and charge no fee. Doing your research is a good way to find a company that works for you at a price that is within your budget.
Source: abcarticledirectory.com
shut obey: Utilizing Debt Reduction Services ? Debt Relief Mag
We cancelled our TV satellite service about two years ago. We cancelled it because we could no longer afford to pay a monthly TV bill and reduce debt. We?re in a much better financial state than we were two years ago. We can now afford to pay a monthly TV bill, and continue to make substantial steps toward reducing debt. The question is ? should we? We have found life without TV to be not only acceptable, but in many ways preferable. The kids no longer fight about what?s on the TV. The TV is not constantly on, rotting our brains. We have an extra $60 per month to allocate somewhere else. Most of what?s on TV is crap anyway. We are missing the Olympics. And I miss the Big 10 network and NCAA tournament coverage most of all (Go MSU!). And sometimes, if used properly, it can give you a parenting break. (The same old DVDs get tiring after a while). So, we?re considering whether or not we should re-up with our satellite TV service. And, getting the cheapest, most basic service is not appealing to me Like I said, the Big 10 network is part of the deal. What do you all think? Source: savingadvice.com
Source: blogspot.com
Extension of the Mortgage Forgiveness Debt Relief Act.
The Senate was unable to act on the bill before adjourning for its August break and the party conventions. The Senate reconvenes Sept. 10. Chairman Baucus (D-MT) had hoped to finish this package before the election in order to provide certainty about the extension (or not) of more than 50 provisions. Nonetheless, it is not known if the package also would be considered in the House before the election.
Source: posterous.com
andreaguchi: Free Debt Settlement Help ? Debt Relief Mag
If you became aware of this article, you may be one of the many Americans seeking information about credit card debt solutions. One might turn out to be living a limited life, but because regarding incidents beyond our control, one is click here delinquent. It merely convinces shoppers that their debt problems are resolved. A better choice could be to just not take advantage of the cards impulsively; hiding them for emergencies may be a better solution in most cases. This greatly reduces the likelihood of your employer finding out that you will be struggling with debt in the slightest degree. Solutions they present should only definitely not settle with an individual. It can be performed ? plus its done every time of day ? but there will be the process. Whereas, when it goes to government debt assist, which comes by using a grant, the individual doesn?t need to pay these people back. With this the patron can get insurance from all charge card companies. Debt settlement is the place that the debts are negotiated paying back less versus balance owed. Part within the mission of a Christian help with your debt program is for many people to later on resume living the biblical avenue. There is a huge store of expertise available online. These services may perhaps cost several $ 100 or so dollars, however they most likely could save you thousands. Despite the benefits, normally it works better to visit a nearby credit card debt relief office and speak about your financial problems nose to nose. Consumer Credit standing Counseling Services: People who desire to organize their debts and the best solution or option for the kids. Some key issues you have to contemplate are you?re able to send history, its standing, its certification, the assurances it provides, its rates together with any savings you are going to obtain from featuring a services, and the freedom to correct your plan associated with attack. If you?re truthful concerning this, your creditors will perceive that it must be not a concern of you not wishing to pay, it really is as you cannot pay whilst still being maintain adequate foods, shelter, clothing, and transportation. Stimulus money supplied by the government while doing this recession helps that will offset the deficits that companies are generally taking by accepting settlements corresponding to only a fraction of your total debt due. So month to month you make just the main payment to insure all. They draw attention together with the catchy lines enjoy, don?t Let Debt provide down! Yes, there is a government help with your debt help, but is available available as grant programs. However, if you are up against a court case on account of unsatisfied debt, bankruptcy is in all probability your last choice to have onto specific vital assets, for example your stuff, your auto, plus your retirement life accounts. Furthermore, media attention on Idaho and in the course of America have extremely centered upon a growing realization that Credit score Counseling companies, though they can indeed be in no way for profit (some sort of essentially meaningless naming that merely highlights that they pay that much to their employees since they receive in finances), these firms are raking within the dollars by 2 bottle dipping fees through demanding extravagant money from not simply their clients but will also their clients? the creditors. There will be other actions to ensure that you are currently making the ideal decision in selecting a debt relief corporation. By working with credit card debt settlement networks, you are sure to identify a company that exceeded its strict following and regulatory tips. Only select this diet regime if the review is and only it. In reality, back in Sept 2010, the Federal commerce Committee (FTC) created some interesting changes with the law that allows you to counter the abuses which are taken place by just some relief agencies. It is typically the worse case scenario within the Debt relief system. Moreover, you can decide on a relief program which will best meets your preferences by checking through the ratings in addition to customer reviews given by the relief networking sites. Source: typepad.com
Source: blogspot.com
Free Debt Settlement Help
Debt relief companies are as popular not to mention common as agencies that extend funds. Debt settlement can completely obliterate unsecured I got it here debt in in terms of a year. A professional credit card debt settlement company also are a member from the Association of Agreement Companies (TASC). Whenever these issues are been found, you?ll go through imprisonment as well as fine. When trying to find debt relief company do obtain the following: This means that the accounts may sit with hardly any follow up with your accounts might not be settled. If you see that you are desperate to know how to find debt help, you might need to know about the 3 solutions beneath. It is significant that, you?ve discontinued on dozens of needless expenses as well as you?ve commenced allocating a measure each month to relieve on those obligations. You can consolidate your debt under one bureau and plan easy methods to clear it. You do will need to remember though, if you be certain mistakes concerning debt relief you could learn yourself even deeper in financial trouble. It presented twenty-four online supports to the consumers. The debt relief agreement has been online since the start of 90s and is area of the tax code 7122. To evade any difficulties on your quest to repay your debt, you must perform your sufficient research and understand exactly the services you are trying to find. Once you begin using it, the snowball impression will start yet again and you most likely will find yourself during the same situation once again. Consumer Credit history Counseling Services: People who would like to organize their debts and here is the best solution or option for your children. Some key issues you want to contemplate are you can actually history, its standing, its certification, the assurances it gives you, its rates in addition to any savings you can obtain from having its services, and the freedom to correct your plan regarding attack. If you?re truthful concerning this, your creditors will perceive that should be not a subject of you not hoping to pay, it really is imagine you?re cannot pay nonetheless maintain adequate foodstuff, shelter, clothing, and transportation. Stimulus money furnished by the government while doing this recession helps to help offset the deficits that companies will be taking by accepting settlements comparable to only a fraction on the total debt you owe. The results on your credit profile is that your future power to pay goes in place as debt cuts down on as settlements are built. Remember, not all companies that comes with these services can be legitimate. There are a number of programs out there in the marketplace and it may be very difficult to identify the one that is true and what design is not. Financial hardship will be recognized today by the large credit card issuers and almost all of provide some program for credit card debt solutions. In addition, CuraDebt is compensation based, which means it?s in their best interest to acquire you the most effective savings. Unfortunately, there are a lot of credit counseling and debt settlement services out there which might be more concerned by using profiting from consumer debt ridden customers compared to helping them manage your debt they have. This is available tactic of aid of America Inc.. There are budgetary relief directories, some of that may be found on the homepage of your state you are in and these deliver listings of ethical help with your debt companies, and this is definitely a great place to begin your search. As I mentioned previously, debt settlement is made for people with accounts which can be already delinquent or missed. Most debt relief companies sort out placing their customers with a monthly payment method. Debt relief solutions are those who are having difficulty with the ability to make ends connect.
Source: typepad.com
Points to Consider When Choosing a Credit or Debt Counseling Agency
Before contracting with a debt or credit counseling agency, ask if they maintain any professional association memberships. The most popular and reputable organizations include the National Association of Certified Credit Counselors, the National Federation for Credit Counseling, the Association of Credit Counseling Professionals and the Association of Independent Consumer and Credit Counseling Agencies. Also, ask what professional training and association memberships their individual counselors have received and maintain.
Source: budgetclowns.com
wa news today: Utilizing Debt Reduction Services ? Debt Relief Mag
We cancelled our TV satellite service about two years ago. We cancelled it because we could no longer afford to pay a monthly TV bill and reduce debt. We?re in a much better financial state than we were two years ago. We can now afford to pay a monthly TV bill, and continue to make substantial steps toward reducing debt. The question is ? should we? We have found life without TV to be not only acceptable, but in many ways preferable. The kids no longer fight about what?s on the TV. The TV is not constantly on, rotting our brains. We have an extra $60 per month to allocate somewhere else. Most of what?s on TV is crap anyway. We are missing the Olympics. And I miss the Big 10 network and NCAA tournament coverage most of all (Go MSU!). And sometimes, if used properly, it can give you a parenting break. (The same old DVDs get tiring after a while). So, we?re considering whether or not we should re-up with our satellite TV service. And, getting the cheapest, most basic service is not appealing to me Like I said, the Big 10 network is part of the deal. What do you all think? Source: savingadvice.com
Source: blogspot.com
Credit Card Debt Settlement ? Debt Relief Mag
Debt relief companies are as popular not to mention common as agencies that extend funds. Debt settlement can completely obliterate unsecured I got it here debt in in terms of a year. A professional credit card debt settlement company also are a member from the Association of Agreement Companies (TASC). Whenever these issues are been found, you?ll go through imprisonment as well as fine. When trying to find debt relief company do obtain the following: This means that the accounts may sit with hardly any follow up with your accounts might not be settled. If you see that you are desperate to know how to find debt help, you might need to know about the 3 solutions beneath. It is significant that, you?ve discontinued on dozens of needless expenses as well as you?ve commenced allocating a measure each month to relieve on those obligations. You can consolidate your debt under one bureau and plan easy methods to clear it. You do will need to remember though, if you be certain mistakes concerning debt relief you could learn yourself even deeper in financial trouble. It presented twenty-four online supports to the consumers. The debt relief agreement has been online since the start of 90s and is area of the tax code 7122. To evade any difficulties on your quest to repay your debt, you must perform your sufficient research and understand exactly the services you are trying to find. Once you begin using it, the snowball impression will start yet again and you most likely will find yourself during the same situation once again. Consumer Credit history Counseling Services: People who would like to organize their debts and here is the best solution or option for your children. Some key issues you want to contemplate are you can actually history, its standing, its certification, the assurances it gives you, its rates in addition to any savings you can obtain from having its services, and the freedom to correct your plan regarding attack. If you?re truthful concerning this, your creditors will perceive that should be not a subject of you not hoping to pay, it really is imagine you?re cannot pay nonetheless maintain adequate foodstuff, shelter, clothing, and transportation. Stimulus money furnished by the government while doing this recession helps to help offset the deficits that companies will be taking by accepting settlements comparable to only a fraction on the total debt you owe. The results on your credit profile is that your future power to pay goes in place as debt cuts down on as settlements are built. Remember, not all companies that comes with these services can be legitimate. There are a number of programs out there in the marketplace and it may be very difficult to identify the one that is true and what design is not. Financial hardship will be recognized today by the large credit card issuers and almost all of provide some program for credit card debt solutions. In addition, CuraDebt is compensation based, which means it?s in their best interest to acquire you the most effective savings. Unfortunately, there are a lot of credit counseling and debt settlement services out there which might be more concerned by using profiting from consumer debt ridden customers compared to helping them manage your debt they have. This is available tactic of aid of America Inc.. There are budgetary relief directories, some of that may be found on the homepage of your state you are in and these deliver listings of ethical help with your debt companies, and this is definitely a great place to begin your search. As I mentioned previously, debt settlement is made for people with accounts which can be already delinquent or missed. Most debt relief companies sort out placing their customers with a monthly payment method. Debt relief solutions are those who are having difficulty with the ability to make ends connect. Source: typepad.com
Source: typepad.com
What Happens to Income Tax After Short Sale in ?
Filed 10/2/09 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION FOUR ANDREW BUESA et al., Plaintiffs and Appellants, v. CITY OF LOS ANGELES, Defendant and Respondent. B212854 (Los Angeles County Super. Ct. No. BC378215) APPEAL from a judgment of the Superior Court of Los Angeles County, Elihu M. Berle, Judge. Affirmed. Law Office of David W. Allor and David W. Allor for Plaintiffs and Appellants. Rockard J. Delgadillo and Carmen Trutanich, City Attorneys, and Paul L. Winnemore, Deputy City Attorney for Defendant and Respondent. _________________________ 2 This is an appeal from a judgment on the pleadings in an action against the City of Los Angeles (City)1 brought by two former Los Angeles police officers, Andrew Buesa and Michael Cardenas. Plaintiffs seek damages for a violation of their rights under the Public Safety Officers Procedural Bill of Rights Act (Gov. Code, ? 3300 et seq. (POBRA)).2 The gravamen of their complaint is that a perjured declaration submitted by the City deprived them of their statute of limitations defense in an administrative mandamus proceeding over their discharges. The issue is whether they may maintain this as a separate action, or whether under the doctrine of collateral estoppel it is barred by the final judgment denying their petition for administrative mandamus. We conclude that plaintiffs? action under POBRA is barred because it constitutes an impermissible collateral attack on the mandate judgment. FACTUAL AND PROCEDURAL SUMMARY Since this matter is on appeal from a judgment on the pleadings, we take our factual summary from the allegations of the second amended complaint, which is the charging pleading. On February 2, 2002, plaintiffs participated in the arrest of a suspect following a car and foot chase. The same day, the Los Angeles Police Department (LAPD) learned of alleged acts of misconduct by plaintiffs arising from that arrest. The next day, Sergeant Joe Losorelli, of the LAPD Internal Affairs Group, was assigned to investigate the alleged misconduct. On August 15, 2002, Losorelli met with a deputy district attorney in the Los Angeles County District Attorney?s Office for the purpose of seeking a determination whether criminal charges should be filed against plaintiffs based on the February 2002 incident. Losorelli met with the deputy district attorney again on October 2, 2002, at which time he provided a copy of his investigation and witness statements. 1 Police Chief William J. Bratton was a named defendant in the original complaint, but he was deleted in the second amended complaint, the charging pleading. He is not a party to this appeal. 2 Statutory references are to the Government Code unless otherwise indicated. 3 According to plaintiffs, the district attorney?s office opened its criminal investigation against plaintiffs that day. POBRA provides a one-year statute of limitations for bringing of police misconduct charges. The time runs from discovery of the misconduct. (? 3304, subd. (d).) Section 3304, subdivision (d)(1) tolls the limitations period while a criminal investigation or prosecution is pending. On December 2, 2002, Losorelli asked LAPD superiors to toll the statute of limitations against plaintiffs because of the pending criminal investigation. He asked that the period be tolled from his August 15, 2002 meeting with the district attorney?s office until the conclusion of the criminal investigation. The criminal investigation was terminated on February 11, 2003, when the deputy district attorney in charge of the case elected not to seek a grand jury indictment. Personnel complaints against plaintiffs were filed at the Los Angeles Police Commission on August 3, 2003, alleging misconduct arising from the February 2002 arrest. They were served the next day. On August 3, 2004, a board of rights found plaintiffs guilty of misconduct and recommended that they be discharged. On September 29, 2004, the chief of police adopted the recommendation that plaintiffs be terminated for failure to report the use of force against a suspect. The chief signed orders removing them from employment, effective that day. Plaintiffs filed a petition for writ of administrative mandamus (Code Civ. Proc., ? 1094.5) on December 14, 2004 seeking review of their terminations. They alleged that Losorelli furnished a false declaration regarding tolling, which was used by defendant in responding to the petition. Allegedly, Losorelli knew that pursuant to a policy of LAPD and the district attorney?s office, only the latter was authorized to open a criminal investigation against sworn personnel. According to the complaint, the district attorney?s office opened the criminal investigation against plaintiffs on October 2, 2002. Plaintiffs allege: ?Sergeant Losorelli knowingly and intentionally testified falsely that his investigation against plaintiffs was considered a criminal investigation from the beginning (as of February 2, 2002). Sergeant Losorelli knowingly and intentionally testified falsely that he first presented the case against plaintiffs to [the deputy district 4 attorney] for possible criminal filing at a July 31, 2002 meeting, when this meeting actually took place on August 15, 2002.? Allegedly, with knowledge that the August 3, 2003 personnel complaints against plaintiffs were time-barred, Losorelli presented a false declaration in the mandamus action ?with the intent of fraudulently extending the tolling period for criminal investigations? authorized by section 3304, subdivision (d) ?and with the malicious intent to deprive plaintiffs of their rights,? and further employment with the LAPD. According to plaintiffs, they discovered Losorelli?s wrongful conduct on July 25, 2007, after the administrative mandamus proceeding was concluded. They do not explain the circumstances of that discovery. Plaintiffs? petition for writ of administrative mandate was denied by the trial court. The court found the weight of evidence at the administrative hearing supported the decision to terminate plaintiffs. It identified the application of the POBRA statute of limitations as ?the main legal issue in the case.? The court noted that both sides had submitted documentary evidence and declarations on the limitations issue, and that no objection to this evidence was made by either side. The trial court found: ?The disciplinary action against the petitioners is not barred by the limitations provision of the POBR? because of the tolling provision in section 3304, subdivision (d)(1). The court stated that charges were served on plaintiffs 18 months and two days after the alleged misconduct. It found: ?The alleged misconduct was the subject of a criminal investigation that commenced on or before July 31, 2002, when an LAPD investigator met with the District Attorney regarding the matter, and which did not end until February 11, 2003, when the District Attorney decided not to ask the grand jury for an indictment because of the lack of evidence. The one-year limitation period was therefore tolled for six months and eleven days. The investigation was therefore completed and notice of charges were served upon the petitioner[s] within the 5 twelve month period required by section 3304(d).? No appeal was filed from the denial of the petition for administrative mandate and that order is now final.3 Plaintiffs filed their original complaint in this separate action seeking reinstatement on September 27, 2007. They filed a first amended complaint which was the subject of a successful motion for judgment on the pleadings. The motion was granted with leave to amend. Plaintiffs? second amended complaint dropped the claim for reinstatement, and, instead sought damages against the City for violation of POBRA. City responded with a new motion for judgment on the pleadings. At the first hearing on the motion, the trial court requested additional briefing on whether perjury in a prior proceeding may be the basis for a collateral attack on the judgment. After supplemental briefing on that issue, a second hearing was held. The court found: ?The gravamen of this lawsuit is an action under Government Code section 3309.5, but it?s based upon plaintiffs? claim for perjury in the underlying action in the mandamus proceeding.? The court observed that the weight of California authority is that perjury is not a basis for collateral attack on a judgment. It found ?that since the gravamen of the complaint in this case is perjury in a prior proceeding and further based upon the principles of law that perjury in a prior proceeding, which is intrinsic fraud, is not grounds for collateral attack, the court is going to grant the motion for judgment on the pleadings.? Judgment was entered in favor of City. This appeal followed. DISCUSSION ?The standard of review for a motion for judgment on the pleadings is the same as that for a general demurrer: We treat the pleadings as admitting all of the material facts properly pleaded, but not any contentions, deductions or conclusions of fact or law contained therein. We may also consider matters subject to judicial notice. We review the complaint de novo to determine whether it alleges facts sufficient to state a cause of 3 Plaintiffs sued their former attorney for malpractice for promising, but failing, to appeal the denial of the writ petition. We are not informed of the outcome of that action. 6 action under any theory. [Citation.]? (Dunn v. County of Santa Barbara (2006) 135 Cal.App.4th 1281, 1298.) The issue presented is whether the action for damages under POBRA is barred by the final judgment following denial of plaintiffs? petition for writ of administrative mandate pursuant to Code of Civil Procedure section 1094.5. Plaintiffs argue they are not collaterally attacking the mandate judgment, which is final, and therefore the doctrines of finality of judgments and collateral estoppel do not apply. Their theory is that their procedural rights under POBRA were thwarted by the alleged perjury by Sergeant Losorelli. Rather than seeking reinstatement to the LAPD, plaintiffs now seek damages for emotional distress, lost earnings and benefits (including pensions), both past and future. They also seek a civil penalty of $25,000 under section 3309.5, and costs of suit. Finally, plaintiffs seek ?an order of injunctive or extraordinary relief that the court deems necessary and just to prevent such future similar actions on the part of defendants against other employees.? A. POBRA POBRA ?sets forth a list of basic rights and protections which must be afforded all peace officers (see ? 3301) by the public entities which employ them. (?? 3300 et seq.) ?It is a catalogue of the minimum rights (? 3310) the Legislature deems necessary to secure stable employer-employee relations (? 3301).? (Baggett v. Gates (1982) 32 Cal.3d 128, 135.)? (Gales v. Superior Court (1996) 47 Cal.App.4th 1596, 1600, fns. omitted (Gales).) Plaintiffs? second amended complaint alleges an action under section 3309.5, which provides a private right of action for police officers who claim a violation of their rights under POBRA.4 4 In pertinent part, section 3309.5 provides: ?(a) It shall be unlawful for any public safety department to deny or refuse to any public safety officer the rights and protections guaranteed to him or her by this chapter. [?] . . . [?] (c) The superior court shall have initial jurisdiction over any proceeding brought by any public safety officer against any public safety department for alleged violations of this chapter. [?] (d)(1) In any case where the superior court finds that a public safety department has violated any of the provisions of this chapter, the court shall render appropriate injunctive or other 7 B. Availability of POBRA Cause Of Action City argues that plaintiffs have not stated a cause of action under POBRA because the alleged perjury was committed in the administrative mandamus proceedings after plaintiffs had been discharged from the LAPD. At that point, City argues, plaintiffs were no longer peace officers as defined by section 3301. Plaintiffs respond that the purpose of POBRA would be defeated if their rights are guaranteed only up to the point of discharge. We need not resolve whether a cause of action lies under POBRA based on a false declaration filed in an administrative mandamus proceeding because the time to challenge the declaration is in the Code of Civil Procedure section 1094.5 proceeding. A subsequent collateral attack on that basis is not allowed, as we next discuss. C. Finality of Adjudications The California Supreme Court examined the principles underlying the finality of judgments in Cedars-Sinai Medical Center v. Superior Court (1998) 18 Cal.4th 1 (Cedars-Sinai), in which it held that there is no separate tort for intentional spoliation of evidence. The court reviewed several cases that denied a tort remedy for the presentation of false evidence or suppression of evidence and observed these decisions ?rest on a concern for the finality of adjudication.? (Id. at p. 10.) ?This same concern underlies another line of cases that forbid direct or collateral attack on a judgment on the ground extraordinary relief to remedy the violation and to prevent future violations of a like or similar nature, including, but not limited to, the granting of a temporary restraining order, preliminary injunction, or permanent injunction prohibiting the public safety department from taking any punitive action against the public safety officer. [?] . . . [?] (e) In addition to the extraordinary relief afforded by this chapter, upon a finding by the superior court that a public safety department, its employees, agents, or assigns, with respect to acts taken within the scope of employment, maliciously violated any provision of this chapter with the intent to injure the public safety officer, the public safety department shall, for each and every violation, be liable for a civil penalty not to exceed twenty-five thousand dollars ($25,000) to be awarded to the public safety officer whose right or protection was denied . . . . If the court so finds, and there is sufficient evidence to establish actual damages suffered by the officer whose right or protection was denied, the public safety department shall also be liable for the amount of the actual damages.? 8 that evidence was falsified, concealed, or suppressed. After the time for seeking a new trial has expired and any appeals have been exhausted, a final judgment may not be directly attacked and set aside on the ground that evidence has been suppressed, concealed, or falsified; . . . such fraud is ?intrinsic? rather than ?extrinsic.? [Citations.] Similarly, under the doctrines of res judicata and collateral estoppel, a judgment may not be collaterally attacked on the ground that evidence was falsified or destroyed. [Citations.]? (Ibid., italics added.) The claim that the judgment was based on forged documents or perjured testimony does not obviate the force of this policy favoring finality of judgments. As explained in Pico v. Cohn (1891) 91 Cal. 129, upon which the Supreme Court relied, ??[W]e think it is settled beyond controversy that a decree will not be vacated merely because it was obtained by forged documents or perjured testimony. The reason of this rule is, that there must be an end of litigation; and when parties have once submitted a matter . . . for investigation and determination, and when they have exhausted every means for reviewing such determination in the same proceeding, it must be regarded as final and conclusive . . . . [?] . . . [W]hen [the aggrieved party] has a trial, he must be prepared to meet and expose perjury then and there. . . . The trial is his opportunity for making the truth appear. If, unfortunately, he fails, being overborne by perjured testimony, and if he likewise fails to show the injustice that has been done him on motion for a new trial, and the judgment is affirmed on appeal, he is without remedy. The wrong, in such case, is of course a most grievous one, and no doubt the legislature and the courts would be glad to redress it if a rule could be devised that would remedy the evil without producing mischiefs far worse than the evil to be remedied. Endless litigation, in which nothing was ever finally determined, would be worse than occasional miscarriages of justice . . . .?? (Cedars-Sinai, supra, 18 Cal.4th at pp. 10-11, italics added, quoting Pico v. Cohn, supra, 91 Cal. 129, 133-134; accord, United States v. Throckmorton (1878) 98 U.S. 61, 68-69.) 9 D. Intrinsic Fraud Courts traditionally have distinguished between extrinsic and intrinsic fraud, a distinction which ?is of critical importance because intrinsic fraud cannot be used to overthrow a judgment, even where the party was unaware of the fraud at the time and did not have a chance to raise it at trial.? (Pour Le Bebe, Inc. v. Guess? Inc. (2003) 112 Cal.App.4th 810, 828.) As we have discussed, the introduction of perjured testimony is a classic example of intrinsic fraud. (See also Kachig v. Boothe (1971) 22 Cal.App.3d 626, 634, cited with approval in Pour Le Bebe, Inc. v. Guess? Inc., supra, 112 Cal.App.4th at p. 828.) Plaintiffs argue these principles do not apply because their second amended complaint does not seek to invalidate the denial of the mandate petition and does not seek their reinstatement. They characterize the two actions: ?The prior action litigated whether [plaintiffs] were entitled to equitable relief because inter alia the City of Los Angeles brought charges against them beyond the one year statute of limitations. The present action seeks statutory penalties and damages for a different and distinct violation of Government Code ? 3309.5 by an employee of the City of Los Angeles.? They rely on Corral v. State Farm Mutual Auto. Ins. Co. (1979) 92 Cal.App.3d 1004 (Corral). Corral arose out of an uninsured motorist arbitration between an insured and her insurer. The insurer refused to stipulate that the third party involved in the accident with the insured was uninsured. The arbitration was continued to allow the insured to obtain evidence that the third party was uninsured or to obtain a stipulation to that effect. When neither was obtained, counsel for the insured submitted on the evidence produced at the hearing. The arbitrator found for the insurer. Six weeks later the insured sought to reopen the arbitration based on a new declaration from the third party stating that he was uninsured. The request was denied on the ground the arbitrator lacked authority to grant the relief requested. (Corral, supra, 92 Cal.App.3d at pp. 1007-1008.) The insured?s motion in the superior court to vacate the arbitration award was denied as untimely, a ruling that was affirmed by the Court of Appeal. (Id. at p. 1008.) 10 The insured then filed a separate action against the insurer for breach of the duty of good faith and fair dealing. In it, she alleged that at all times the insurer knew that the third party was uninsured, and fraudulently contended at the arbitration hearing that he was insured. In opposition to the defense motion for summary judgment, counsel for the insured submitted his declaration in which he stated that a claims manager for the insured had told him before the arbitration that the insurer would treat the claim as an uninsured motorist case. The attorney declared that, in reliance on these assurances, he made no effort to obtain evidence of the third party?s lack of insurance coverage. (Corral, supra, 92 Cal.App.3d at pp. 1008-1009.) The Corral court rejected the insurer?s argument that the bad faith action was barred by either res judicata or the policies underlying finality of judgments. (Corral, supra, 92 Cal.App.3d at p. 1009.) Instead, it held that each proceeding was based on a different claim of right: the arbitration proceeding was brought to recover benefits under the uninsured motorist provision of the insurance contract; the bad faith cause of action was not based on facts surrounding the automobile collision or the terms of the insurance policy, but on bad faith (refusal to acknowledge that the third party motorist was uninsured) committed after the collision. The court concluded that the bad faith claim constituted a different cause of action, and so was not barred by collateral estoppel. (Id. at pp. 1011-1012.) It held that the bad faith action was ?not a collateral attack upon the arbitrator?s award as it is not directed toward directly preventing the enforcement of that award or defeating rights acquired under it.? (Id. at p. 1013.) The court in Corral acknowledged a then recent case that reached a different result, but disagreed with its holding. The case was Rios v. Allstate Ins. Co. (1977) 68 Cal.App.3d 811, which held that the doctrine of finality of judgments barred a separate action for bad faith alleging that in an arbitration between insurer and insured, the insurer had presented false evidence and testimony. (Corral, supra, 92 Cal.App.3d at pp. 1012-1014.) But Rios (and several other decisions) were cited with approval by our Supreme Court in Cedars-Sinai, supra, 18 Cal.4th at page 10. Of course, the Corral court did not 11 have the benefit of the Supreme Court?s reasoning in Cedars-Sinai, which was decided some 19 years later. Plaintiffs do not cite or discuss Rios, but argue that Corral should apply because in that case, as in this one, the facts giving rise to the second action occurred during the first proceeding. They contend: ?As demonstrated in Corral, it is the extraordinary obligations of the defendant that allows the second action to proceed. In that case, it was the insurance company?s obligation of good faith and fair dealing. . . . Similarly, in the present case the City of Los Angeles cannot get away with its conduct at the hearing on the writ where it presented the perjurous [sic] declaration because it had an independent obligation not to violate [plaintiffs?] rights under Government Code, ? 3309.5.? Here, to prevail in their action for damages, plaintiffs had to prove a violation of POBRA based upon defendant?s reliance on a perjured declaration to show that the tolling of the time to file disciplinary actions lasted long enough to render their discharges timely. This goes to the heart of the trial court?s finding in the mandate proceeding. To the extent that Corral stands for the proposition that the finality of judgments doctrine does not apply to a separate bad faith action arising from the presentation of false or perjured testimony in an earlier proceeding, we disagree, and instead follow Cedars-Sinai, supra, 18 Cal.4th 1 and Rios, supra, 68 Cal.App.3d at pp. 818-819. Plaintiffs also rely on Miller v. Campbell, Warburton, Fitzsimmons, Smith, Mendel & Pastore (2008) 162 Cal.App.4th 1331 (Miller). In that case, the executor of an estate hired a law firm to represent her in connection with her duties. At the conclusion of the probate matter, the firm requested and was awarded its fees except for one category which the probate court found to involve work for the executor in her individual capacity. The firm did not appeal that decision. Instead, it filed a new action seeking quantum meruit recovery of the denied fees directly from the client. The trial court held the action was barred by the final judgment in the probate case. The Court of Appeal reversed. Significantly, it found that the probate court did not decide that the law firm was not entitled to the additional fees, but only that the fees were not payable out of the estate. 12 (Id. at p. 1341.) As the Miller court explained, the probate court never ruled on the firm?s entitlement to fees directly from its client, and therefore there was no basis for collateral estoppel. (Id. at p. 1343.) The case before us is quite different. The court ruled on the tolling issue in the mandate proceeding. Indeed it was the central question in the case. ??Collateral estoppel precludes the relitigation of an issue only if (1) the issue is identical to an issue decided in a prior proceeding; (2) the issue was actually litigated; (3) the issue was necessarily decided; (4) the decision in the prior proceeding is final and on the merits; and (5) the party against whom collateral estoppel is asserted was a party to the prior proceeding or in privity with a party to the prior proceeding. (Lucido v. Superior Court (1990) 51 Cal.3d 335, 341.)? (Zevnik v. Superior Court (2008) 159 Cal.App.4th 76, 82.)? (Plumley v. Mockett (2008) 164 Cal.App.4th 1031, 1048-1049.) That describes the present case. Because the tolling issue was actually litigated in the mandate proceeding, a new claim based on the allegedly perjured declaration is a collateral attack on the mandate decision. Perjured testimony cannot be the basis for a separate proceeding. (Cedars-Sinai, supra, 18 Cal.4th at pp. 10-11.) In light of our conclusion, we need not and do not address City?s other arguments. DISPOSITION The judgment is affirmed. City is to have its costs on appeal. CERTIFIED FOR PUBLICATION. EPSTEIN, P. J. We concur: WILLHITE, J. MANELLA, J. 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