The following excerpt is from Ehrenberg v. Roussos (In re Roussos), 541 B.R. 721 (Bankr. C.D. Cal. 2015):
As opposed to the fraud on the court claimas to which there is no statute of limitationsa claim for aiding and abetting breach of fiduciary duty is subject to a statute of limitations of either three or four years, depending on the specific circumstances of the breach. See generallySchneider v. Union Oil Co.,6 Cal.App.3d 987, 993, 86 Cal.Rptr. 315 (Ct.App.1970)(discussing different statutes of limitation that may apply to a claim for breach of fiduciary duty).
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