California, United States of America
The following excerpt is from De Haas v. Shahinian, B234726 (Cal. App. 2013):
5. The elements of a claim for professional negligence are: (1) the duty of the attorney to use such skill, prudence, and diligence as members of his or her profession commonly possess and exercise; (2) a breach of that duty; (3) a proximate causal connection between the breach and the resulting injury; and (4) actual loss or damage resulting from the attorney's negligence. (Coscia v. McKenna & Cuneo (2001) 25 Cal.4th 1194, 1199.)
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