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I guess it would be 2 years - statute of limitations for an oral contract http://cobrands.public.findlaw.com/litigation_appeals/nolo/faq/0566BBF3-858F-4E25-89F7A06B61F9CEF5.html

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2006-04-05 14:18:37
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Q: How long does a doctor have to send somebody a bill in California?
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