California, United States of America
The following excerpt is from Smith v. Hill, 237 Cal.App.2d 374, 47 Cal.Rptr. 49 (Cal. App. 1965):
The right of action against a party wrongfully procuring the appointment of a receiver accrues on the adjudication that the appointment was improper. (Warren v. De Long, 59 Nev. 481, 97 P.2d 792; 45 Am.Jur. 123, p. 104.)
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