Dr. Leevil, LLC v. Westlake Health Care Center

A purchaser at a foreclosure sale need not perfect its title in the property by recording a trustee’s deed upon sale before serving the occupant(s) with a notice to quit, so long as title is perfected before the ensuing unlawful detainer action is filed and served.  Disagreeing with U.S. Financial, L.P. v. McLitus (2016) 6…