Does the continuing representation tolling provision apply to a client's cause of action against her former attorney's former law firm?

California, United States of America


The following excerpt is from Rallis v. Cassady, 100 Cal.Rptr.2d 763 (Cal. App. 2000):

The court in Crouse v. Brobeck, Phleger & Harrison, supra, 67 Cal.App.4th at pages 1535-1540, held that the continuing representation tolling provision did not apply to a client's cause of action against her current attorney's former law firm, and declined to follow Beane v. Paulsen, supra. The primary grounds for the court's holding were that a defendant cannot waive the statute of limitations defense on behalf of another co-obligor and that a former partner has no authority to bind other former partners after the partnership is dissolved. (Crouse, at pp. 1538-1539.) We find those legal principles to be inapposite.

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