California, United States of America
The following excerpt is from Gulf Insurance v. Berger, Kahn, 79 Cal.App.4th 114, 93 Cal.Rptr.2d 534 (Cal. App. 2000):
Where attorneys have failed to diligently represent their clients, thereby placing them in the position that an unfavorable settlement is necessary, the proof of damages is always a difficult one. But that alone should not prevent a party injured by an attorney's malpractice from having his day in court. (See, Benard v. Walkup (1969) 272 Cal.App.2d 595, 606 ["[T]he applicable rule is that which states that one whose wrongful conduct has rendered difficult the ascertainment of damages cannot complain because the court must make an estimate of damages rather than an actual computation."].)
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