California, United States of America
The following excerpt is from Shetty v. Bank of N.Y. Mellon, H045717 (Cal. App. 2020):
Defendant contends that plaintiff's cancellation of instruments cause of action was time barred. "Actions for cancellation of an instrument are subject to the four-year limitations period in the catchall provision of [Code of Civil Procedure] section 343." (Salazar v. Thomas (2015) 236 Cal.App.4th 467, 477, fn. 8; accord, Zakaessian v. Zakaessian (1945) 70 Cal.App.2d 721, 725 ["[o]rdinarily a suit to set aside and cancel a void instrument is governed by section 343 of the Code of Civil Procedure"].)4
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