California, United States of America
The following excerpt is from Grimshaw v. Ford Motor Co., 119 Cal.App.3d 757, 174 Cal.Rptr. 348 (Cal. App. 1981):
25 The rationale for the rule that only the personal representative of the deceased can maintain certain types of actions is explained in Holland v. McCarthy, 177 Cal. 507, 509-510, 171 P. 421:
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