In 1972, a Court of Appeal classified indemnity agreements as Types I, II, and II. McDonald & Kruse v. San Jose Steel 29 Cal.App.3d 413, 418-421 (1972). Three years later in Rossmoor Sanitation District v. Pylon 13 Cal.3d 622 (1975) the state Supreme Court dealt with various types of indemnity agreements, but never discussed the MacDonald & Kruse classifications. Three years after that, the 2nd District Court of Appeal...
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