Although Remanded, Facts Suggested A Possible Delay Because Of A Calamity Evacuation By Defense Counsel. As we have said before, the CCP § 1281.98 defense missed payment deadline for employer/employee cases have resulted in many reversals and remands. That also occurred in Colon-Perez v. Security Industry Specialists, Case No. A168297 (1st Dist., Div. 1 Feb. 11, 2026) (unpublished). This one, too, was reversed and remanded. The appellate court did note that most invoices were paid, except one—with defense counsel saying there was a delay due to a natural calamity requiring her to vacate her home and with the payment still getting there (or close, as we read the facts). All these remands are going to be factual in nature.