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IN RE EFRON

No. 13-1765.

746 F.3d 30 (2014)

In re David EFRON, Movant, Appellant. Madeleine Candelario-Del-Moral, Plaintiff, Appellee, v. UBS Financial Services Incorporated of Puerto Rico, Defendant, Appellee.

United States Court of Appeals, First Circuit.

March 21, 2014.

Attorney(s) appearing for the Case

David Efron, pro se.

Judith Berkan , with whom Mary Jo Méndez and Berkan/Méndez were on brief, for plaintiff-appellee.

Enrique G. Figueroa-Llinás , with whom Christopher N. Manning , Ashley W. Hardin , and Williams and Connolly LLP were on brief, for defendant-appellee.

Before HOWARD, SELYA and LIPEZ, Circuit Judges.

SELYA, Circuit Judge.

For over four centuries, persons learned in the law have known that, when litigation is in prospect, vigilance is good and somnolence is bad. Commentators and courts have phrased this sentiment in different ways. See, e.g., In re Wood, [1883] 23 Ch.D. 644 at 653 (Eng.) ("It is a reasonable presumption that a man who sleeps upon his rights has not got much right."); Edmund Wingate, Maxims of Reason (1658) ("Laws come to the assistance...

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