California, United States of America
The following excerpt is from Rayn v. Besneatte, A145818 (Cal. App. 2017):
212 Cal.App.2d 196, 207-208 [post-stroke mental deterioration].) But to establish excusable neglect on the basis of disability, the moving party must show that the disability, and not something else, was the reason for the neglect. (See Davis v. Thayer (1980) 113 Cal.App.3d 892, 909.)
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