Martin Potts & Associates, Inc. v. Corsair, LLC

Opinion

HOFFSTADT, J.

-A trial court is required by statute to vacate a default, default judgment, or dismissal that is “in fact” caused by an attorney’s *436“mistake, inadvertence, surprise, or neglect” if the attorney files a sworn affidavit “attesting” to such. (Code Civ. Proc., § 473, subd. (b).)1 Must the attorney’s affidavit also disclose the reasons for his mistake, inadvertence, surprise, or neglect? We conclude the answer is “no.” Although such a statement of reasons will be helpful, and may sometimes be relevant to prove the causal link between the attorney’s conduct and the default,…