California, United States of America
The following excerpt is from Estate of Gaspar v. Humboldt Land Title Co., A142068 (Cal. App. 2016):
"The elements of a claim for professional negligence are: ' "(1) the duty of the professional to use such skill, prudence, and diligence as other members of his profession commonly possess and 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." ' " (Paul v. Patton (2015) 235 Cal.App.4th 1088, 1095.)
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