California, United States of America
The following excerpt is from Khodayari v. Ardalan, B239102 (Cal. App. 2013):
The discovery rule of accrual applies to the fraud causes of action as well under section 338, subdivision (d). "'[T]he uniform California rule is that a limitations period dependent on discovery of the cause of action begins to run no later than the time the plaintiff learns, or should have learned, the facts essential to his claim.' [Citation.] Thus, for example, the statute of limitations in a cause of action for fraud 'commences to run after one has knowledge of the facts sufficient to make a reasonably prudent person suspicious of fraud, thus putting him on inquiry . . . .' [Citations.]" (Cleveland v. Internet Specialties West, Inc. (2009) 171 Cal.App.4th 24, 31.) Thus plaintiff had knowledge that defendants did not intend to represent him through trial before March 1, 2007 when they were relieved as counsel.
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