The following excerpt is from Hagendorf v. Brown, 699 F.2d 478 (9th Cir. 1983):
The California courts apply a liberal standard for establishing the required relationship. See Izzi v. Rellas, 104 Cal.App.3d 254, 262, 163 Cal.Rptr. 689 (1980). Doubts are resolved in favor of relevancy and pertinency. Id. at 263, 163 Cal.Rptr. 689.
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