Curtis Eng'g Corp. v. Superior Court of San Diego Cnty.

*545Code of Civil Procedure 1 section 411.35 requires the attorney for plaintiffs or cross-complainants in certain professional negligence cases to serve and file a certificate on the defendant or cross-defendant on or before the date of service of the complaint or cross-complaint declaring that he or she has consulted with and received an opinion from an expert in the field, or an adequate excuse for not doing so. ( §§ 411.35, subd. (a), (b).) In this case, we conclude that a certificate filed after expiration of the statute of limitations and more than 60 days after filing the original pleading…