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For all the complexities inherent in appellate work, the start of an appeal is a deceptively simply matter. A notice of appeal to the California Court of Appeal must satisfy only three formal requirements. The first requirement is obvious to anyone who recognizes the jurisdictional nature of the filing: It must be timely filed. California Rule of Court 8.104(b) ("If a notice of appeal is filed late, the reviewing court must dismiss the appeal."). Moreover, a notice may be validly filed even without a proof of service. Cal. R. Ct. 8.100(a)(3) ("Failure to serve the notice of appeal neither prevents its filing nor affects its validity").

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