California, United States of America
The following excerpt is from Lewis v. O'Brien, 248 Cal.App.2d 628, 56 Cal.Rptr. 749 (Cal. App. 1967):
If the personal representative is substituted as a party to the action, as was done in the instant case, the requirements of section 709 concerning presentation of claims is satisfied. (Pelser v. Pelser (1960) 177 Cal.App.2d 228, 231, 2 Cal.Rptr. 259.)
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