California, United States of America
The following excerpt is from Camelot Pictures, LLC v. Lakeshore Entm't Grp., LLC, B269430 (Cal. App. 2017):
"18. In ordinary contract claims, the statute of limitations begins to run upon the occurrence of the last element essential to the cause of action and a plaintiff's ignorance of the cause of action does not toll the statute. Citing from the case of April Enterprises v. KTTV (1983) 147 Cal.App.3d 805, the court held that 'the discovery rule, under which a cause of action accrues when the plaintiff discovers or should have discovered all of the facts essential to his cause of action, is applicable to causes of action involving the breach of a fiduciary relationship. The discovery rule is applied to a fiduciary relationship when strict adherence to the otherwise applicable date-of-injury rule would result in unfairness to the plaintiff and would encourage wrongdoers to mislead their fiduciary to delay bringing suit. It is particularly appropriate when the defendant maintains custody and control of a plaintiff's property or interests.'
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