California, United States of America
The following excerpt is from Slavin v. Trout, 18 Cal.App.4th 1536, 23 Cal.Rptr.2d 219 (Cal. App. 1993):
[18 Cal.App.4th 1541] Johnson v. Simonelli, supra, is a substantially similar case. The plaintiff retained defendant attorneys regarding the sale of plaintiff's business. Plaintiff received a promissory note for most of the purchase price, secured by certain property owned by the buyers. The theory of plaintiff's suit against defendant attorneys was that defendants negligently failed to determine that the security afforded by the buyers' property was inadequate. The buyers defaulted in July 1983; plaintiff obtained the property at a public lien sale in June 1984; plaintiff filed his complaint against defendant attorneys in December 1985. The appellate court upheld a summary judgment on statute of limitations grounds, holding that the plaintiff suffered actual and appreciable harm when the buyers defaulted in July 1983. (Johnson v. Simonelli, supra, 231 Cal.App.3d at p. 110, 282 Cal.Rptr. 205.)
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