Cal. Ct. App. 1st Dist. · Court of Appeal opinion · January 1, 2021
Related by Seller ProceedsCourt record Court of Appeal opinion
Rooz v. Kimmel — California Court of Appeal
California Court of Appeal, Fourth District, Division Two · 55 Cal.App.4th 573
AmountNot statedAmount not stated in reviewed source.
ResultCourt of Appeal opinionCourt ruling
HingeSeller ProceedsTeaches accommodation recordings and hold-harmless releases when escrow/title staff record documents as a non-insured favor — limits recovery for delayed security perfection.
SourceCourt opinionPublished opinion
File-record question
Teaches accommodation recordings and hold-harmless releases when escrow/title staff record documents as a non-insured favor — limits recovery for delayed security perfection.
Limit before takeaway
Published appellate opinion only. Kirby v. Palos Verdes Escrow (1986) 183 Cal.App.3d 57 (supporting link) on recording-instruction disputes.
- Court / region
- Cal. Ct. App. 4th Dist.
- Case number
- 55 Cal.App.4th 573
- Filed
- January 1, 1997
- Source record
- Court opinion
- Procedural posture
- Court of Appeal opinion
- Money movement stage
- Seller proceeds stage
- Record gap
- Payee gap
- Strongest reviewed source
- Published opinion
- Allegation / finding status
- Court ruling
- Disposition
- Court of Appeal opinion
- Last posture checked
- 2026-05-31
- Reviewed
- 2026-05-31
What happened
Court held a broad accommodation-recording indemnity and hold-harmless agreement released North American Title from liability for its own failure to timely record a replacement deed of trust after escrow closed.
What it hinged on
Seller Proceeds. Teaches accommodation recordings and hold-harmless releases when escrow/title staff record documents as a non-insured favor — limits recovery for delayed security perfection.
Amount involved
Amount not stated in reviewed source.
Result
Court of Appeal opinion
Why this belongs here
Teaches accommodation recordings and hold-harmless releases when escrow/title staff record documents as a non-insured favor — limits recovery for delayed security perfection.
Documents to inspect
- Seller instructions
- Authorization request
- Callback log
- Wire confirmation
- Closing statement
- Escrow instructions
This list is inferred from the topic pattern, not asserted as an extracted document list for this case.
What the file needed to show
Current reviewed metadata frames the file issue this way:
Teaches accommodation recordings and hold-harmless releases when escrow/title staff record documents as a non-insured favor — limits recovery for delayed security perfection.
Timeline
FiledJanuary 1, 1997
Posture checked2026-05-31
Reviewed for Escrow Cases2026-05-31
Topics
Related patterns
Related records are selected from shared topics, hinge category, court type, and posture. They are discovery aids, not claims that the facts or results match.
Continue research
Open a related reviewed-record search or save this trail when the file-record question is worth revisiting.
Source record
What this record does not show
This reviewed record does not show a court finding that any company or person did anything wrong unless the linked source expressly says so. Read the primary source for allegations, posture, and outcome.
Limit: Published appellate opinion only. Kirby v. Palos Verdes Escrow (1986) 183 Cal.App.3d 57 (supporting link) on recording-instruction disputes.
Reviewed California court records with source links. Allegations are not findings.