California, United States of America
The following excerpt is from Austin v. Peter Carl Swarth & Law Offices of Peter Carl Swarth, B270071 (Cal. App. 2017):
"The applicable statute of limitations does not begin to run until the cause of action accrues, that is, ' "until the party owning it is entitled to begin and prosecute an action thereon." ' [Citation.]" (Romano v. Rockwell Internat., Inc. (1996) 14 Cal.4th 479, 487.) Thus, to determine when the statutes of limitation ended, we must first address when they began. We conclude the cause of action for intentional infliction of emotional distress accrued on July 7, 2011, and the other causes of action accrued no later than July 20, 2010.
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