California, United States of America
The following excerpt is from People v. Martinez, 205 Cal.Rptr. 852, 36 Cal.3d 816, 685 P.2d 1203 (Cal. 1984):
6 This court has declined to establish a test to measure reasonable diligence. Instead, in People v. Williams, supra, 57 Cal.2d 263, 273, 18 Cal.Rptr. 729, 368 P.2d 353, we said that "The term 'diligence' is 'incapable of exact definition because it is a relative term' [citation] and the 'diligence' of defendant in marshaling his evidence for the trial must be determined in the light of the 'peculiar circumstances' involved."
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