California, United States of America
The following excerpt is from Ireland v. Schneider, H038334 (Cal. App. 2014):
Ireland reiterates his contention below that he did not sustain actual injury that triggered the one-year statute of limitations provided by section 340.6 when he incurred attorney's fees in defending and prosecuting the litigation in the underlying action, Jones v. Ireland, supra, No. 94818. He maintains that actual injury within the meaning of
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section 340.6 could not occur while the litigation in Jones v. Ireland, supra, No. 94818 was pending and had the potential to be resolved in his favor. Additionally, Ireland argues that the date of actual injury is a question of fact that cannot be resolved on summary judgment.
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