California, United States of America
The following excerpt is from Goebel v. Lauderdale, 214 Cal.App.3d 1502, 263 Cal.Rptr. 275 (Cal. App. 1989):
This case is similar to In re Easterbrook, supra, 200 Cal.App.3d 1541, 244 Cal.Rptr. 652 where the court concluded that an action for attorney malpractice did not accrue until a verdict had been rendered in the client's criminal case. In that case, the court stressed that "there has been no verdict in the criminal case and [the client] has, at most, suffered only speculative harm which does not suffice to create a cause of action for negligence." (Id. at p. 1544, 244 Cal.Rptr. 652.) Similarly, in Robinson v. McGinn, supra, 195 Cal.App.3d 66, 240 Cal.Rptr. 423, the court held that the [214 Cal.App.3d 1508] statute of limitations for legal malpractice did not began to run until the client had exhausted his administrative remedies.
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