Court Ruling Requires Immediate Compliance: Revised 3-Day & 30-Day Forms Now Available

Court of Appeals ruling necessitates immediate change in noticing.

The Apartment Association of Orange County (AAOC) has revised its "3-Day" and "30-Day" Notice forms to comply with a recent decision by the California Court of Appeals (Second District) in the case of Eshagian v. Cepeda (2025). These revised forms are to be used immediately to ensure legal compliance.

How the court ruling affects 3-Day & 30-Day notices:

• Reaffirms that notices must clearly state that Saturdays, Sundays, and judicial (court) holidays are excluded from the 3-Day and 30-Day noticing and compliance period.
• The date of notice must match the date of service (i.e. the notice is to be signed and served on the same day).
• Notices must include a specific expiration date, calculated by excluding weekends and court holidays. 

AAOC has revised the following forms to ensure compliance:

• 1460: 3-Day Notice to Pay Rent or Quit
• 1461: 3-Day Notice to Pay or 30-Day Notice to Quit (CARES Act)
• 1470: 3-Day Notice to Perform Covenants or Quit (Non-Monetary)
• 1471: 3-Day Notice to Perform Covenants or 30-Day Notice to Quit (CARES Act)
• 1480: 3-Day Notice to Surrender Possession

These revised forms are available for download and immediate use by clicking the links above.

Additional Administrative Guidance:

Members should also complete Form 1170: Proof of Service to internally document the service of notices. This form should not be served to the resident.

If you have questions, contact AAOC at (714) 245-9500 or contact@aaoc.com.