California, United States of America
The following excerpt is from Law Offices of Gary Kurtz v. Markowitz, B291880 (Cal. App. 2020):
20. Legal malpractice may serve as an offset against an attorney's claim to recover fees pursuant to section 431.70 even after the expiration of the statute of limitations for bringing a legal malpractice claim. (Safine v. Sinnott (1993) 15 Cal.App.4th 614, 618-619.)
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