The following excerpt is from Lyons v. Michael & Assocs., 824 F.3d 1169 (9th Cir. 2016):
We next address Naas v. Stolman, a case relied on by the district court to conclude that the statute of limitations begins to run on the date the underlying debt collection action was filed. 130 F.3d at 893. Naas, however, does not dictate the result here. In that case, the question of whether the discovery rule applies to FDCPA cases was never presented to nor addressed by our court.
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