California, United States of America
The following excerpt is from Tesoro Coast, LLC v. United Escrow Co., B228202, Los Angeles County Super. Ct. No. BC409236 (Cal. App. 2011):
exercise; (2) a breach of that duty; (3) a proximate causal connection between the negligent conduct and the resulting injury; and (4) actual loss or damage resulting from the professional's negligence." (Budd v. Nixen (1971) 6 Cal.3d 195, 200.)
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