Holt Woods Scisciani LLP Blog

General Cases

Boyer v. Morimoto, No. 36166-7-III, 2019 Wash. App. LEXIS 2363 (Ct App Sep. 10, 2019)

Washington Court Upholds Decision Not to Consider Supplemental Declaration Filed After Memorandum Decision on Summary Judgment. Issue: Does Washington procedural law require trial courts to consider supplemental declarations filed after the court issues a memorandum decision granting a party summary judgment, but before the court enters a formal order on summary judgment? NO

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