The following excerpt is from Garcia v. Grounds, No. CIV S-12-1060 KJM GGH P (E.D. Cal. 2013):
Due diligence in attorney misconduct cases require consideration of "inter alia, whether the petitioner expeditiously secured counsel to file the habeas petition, the frequency and nature of the attorney-client communications, when, in light of the petitioner's education and background, he reasonably should have sought new counsel, and whether the petitioner had the means to consult alternate counsel." Doe v. Busby, 661 F.3d 1001, 1013 (9th Cir. 2011) (internal citations omitted).
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