California, United States of America
The following excerpt is from Whitehill v. Valente, A137613 (Cal. App. 2014):
In her opening brief on appeal, Valente relies solely on Levine v. Diamanthuset, Inc. (N.D.Cal. 1989) 722 F.Supp. 579, 590 (reversed on other grounds in Levine v. Diamanthuset, Inc. (9th Cir. 1991) 950 F.2d 1478) to support her position that her unfair practices claim is governed by the four-year statute of limitations in Business and Professions Code section 17208. That case held that an unfair practices claim against attorneys was not barred by section 340.6. (Levine v. Diamanthuset, Inc., supra, 722 F.Supp. at p. 590.) We note the district court's ruling on this point contains almost no analysis and, of course, does not address subsequent California cases giving section 340.6 a broad interpretation. We decline to follow it.
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