California, United States of America
The following excerpt is from McClain v. Kissler, 251 Cal.Rptr.3d 885, 39 Cal.App.5th 399 (Cal. App. 2019):
The first case cited by the authors, Benedict v. Danner Press , is a decision by this court. There, the default resulted from a combinations of a client's mistake (regarding whether he had been personally served) and counsel's negligence in failing to challenge the process server's declaration of service. We granted relief, explaining our holding in terms of "causation in fact":
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