Ramirez v. Moran

In Ramirez v. Moran (1988) 201 Cal. App. 3d 431, the Court held that a party's undisputed mailing of a conformed copy of a judgment to another party without a proof of service constituted notice of entry of judgment under Code of Civil Procedure section 659, which requires that a notice of intention to move for a new trial be filed within 15 days of service of notice of entry of judgment. Ramirez stated: "The fact that the record does not include a customary proof of service is not material here. We are concerned with whether there was sufficient notice of entry of judgment rather than proof of service." ( Id. at p. 436.) Ramirez concluded: "'Notice of entry of judgment must be in writing. However, no particular form is required; any notice in writing which will convey to a losing party that a judgment has been entered is sufficient.'" ( Id. at p. 437.)