In Abraugh v. Gillespie (1988) 203 Cal. App. 3d 462, claimant- appellant sought relief from her late filing of a claim against an insolvent insurer undergoing liquidation. (Id. at p. 464.) Due to her attorney's mistake, appellant Abraugh's claim was filed late, and the Insurance Commissioner later rejected it as untimely pursuant to sections 1021 and 1024. (Id. at p. 465.) Abraugh then filed a section 1032 OSC application seeking a review of the claim denial, arguing that the OSC procedure of section 1032 implies a court has jurisdiction to cure her late claim under section 473. (Id. at pp. 465-467.) The appellate court, however, rejected Abraugh's arguments, holding that unless a claimant was induced into missing the claims filing deadline, section 1032 was inoperative in extending the deadline. (Id. at pp. 467-468.) Furthermore, the Abraugh court followed the long-standing principle that the liquidation proceedings of an insurer are special proceedings and therefore found section 473 not applicable to curing Abraugh's late claim. (Id. at p. 468.) It held that " 'excusable neglect' is not a reason for permitting the filing of a late claim pursuant to section 1032 . . . . A claim against the Commissioner . . . is not a civil action but rather a special proceeding governed by the comprehensive statutory scheme set out in the Insurance Code. In the absence of statutory directive to the contrary, the provisions relating to pleadings in civil actions are inapplicable." (Id. at p. 468.)