What is the test for relief from the statute of limitations under section 945.4 of the Government Claims Act?

In referencing "mistake, inadvertence, surprise or excusable neglect[,]" Oliver appears to be referring to section 946.6, subdivision (c), which allows the trial court to relieve a petitioner from the claims presentation requirements of section 945.4 in certain circumstances, one of which is "[t]he failure to present the claim was through mistake, inadvertence, surprise, or excusable neglect unless the public entity establishes that it would be prejudiced in the defense of the claim if the court relieves the petitioner from the requirements of Section 945.4." ( 946.6, subd. (c)(1), italics added.) This provision, however, does not apply to the six-month limitations period of section 945.6. "The law is established that although the procedure for granting relief from the claim statutes is remedial in nature and must be liberally construed in favor of the claimant [citation], such liberality does not extend to the ... statute of limitations. [Citations.] The [Government] Claims Act indulges late claimants; not late suitors. 'A late claim suggests late discovery of the proper means of seeking redress. But once a claimant has filed his [or her] claim, he [or she] demonstrates familiarity with the statutory procedures governing his [or her] grievance, and can reasonably be charged with knowledge of the time limitations that are part of that procedure.'" (Fritts v. County of Kern (1982) 135 Cal.App.3d 303, 305-306;

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