California, United States of America
The following excerpt is from De Haas v. Shahinian, B234726 (Cal. App. 2013):
6. At oral argument, for the first time, Shahinian cited authority supporting his claim that an attorney's breach of fiduciary duty may give rise to recovery of emotional distress damages. (Stanley v. Richmond (1995) 35 Cal.App.4th 1070.) Although this may be true in theory, damages must be identified and quantified, and Shahinian has never done so.
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