In Robert T. Miner, M.D., Inc. v. Tustin Ave. Investors, LLC (2004) 116 Cal.App.4th 264, the estoppel certificate was ambiguous because it confirmed in one paragraph that the lease, which included express option-to-renew provisions, was in full force and effect, yet stated in another paragraph that there were no options. (Id. at pp. 270-271.) The Court of Appeal therefore reversed a summary judgment in favor of the landlord on the ground the landlord had not carried its burden of showing there was no triable issue of material fact as to the meaning of the representations in the estoppel certificate. (Id. at p. 273.) The reversal left "all issues open for trial, including the meaning of the Estoppel Certificate (should there be any competent extrinsic evidence on the subject)." (Ibid.)