California, United States of America
The following excerpt is from Harb v. Sene, A142044 (Cal. App. 2016):
1. "A cause of action for professional negligence is generally governed by the two-year statute of limitations under Code of Civil Procedure section 339, subdivision 1 for an 'action upon a contract, obligation or liability not founded upon an instrument of writing.' " (Thomson v. Canyon (2011) 198 Cal.App.4th 594, 606.)
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