Certificate of Compliance

* **Certificate of Compliance**
* Counsel of Record hereby certifies that the enclosed brief is produced using 13-point Roman type including footnotes and contains approximately XXX words, which is less than the total words permitted by the rules of court.
* Counsel relies on the word count of the computer program used to prepare this brief.

The form is a certification that the enclosed brief complies with the word count requirements of the California Rules of Court. The brief must be produced using 13-point Roman type and must contain no more than XXX words. Counsel must rely on the word count of the computer program used to prepare the brief.

The form must be signed and dated by the attorney of record for the party filing the brief.