Does the statute of limitations apply if the estate has not begun a proceeding?

To that end, Code of Civil Procedure section 366.2's one-year statute of limitations will be applied even if the time period lapses before estate administration has even begun. (See Bradley v. Breen (1999) 73 Cal.App.4th 798, 805-806 [ 366.2 applies when "impossible" to assert claims against estate within one-year period]; Levine v. Levine, supra, 102 Cal.App.4th at p. 1265 [ 366.2 applies where no proceeding to administer estate was initiated and there was no notice to creditors].)¹² Thus, although Rafael's failure to

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