California, United States of America
The following excerpt is from Wray v. Bank of Am., N.A., A142720 (Cal. App. 2016):
However, the tender rule is subject to exceptions, and other recent foreclosure cases have excused tender in some contexts. (See, e.g., Glaski v. Bank of America (2013) 218 Cal.App.4th 1079, 1100-1101 [holding tender not required in connection with
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