Is a plaintiff required to allege the time and surrounding circumstances of the discovery of the cause of action?

Defendants nonetheless contend plaintiffs did not adequately describe "'(1) the time and manner of discovery and (2) the inability to have made earlier discovery despite reasonable diligence.'" (E-Fab, Inc. v. Accountants, Inc. Servs. (2007) 153 Cal.App.4th 1308, 1319; id. at p. 1324 [plaintiffs required to "allege 'facts showing the time and surrounding circumstances of the discovery of the cause of action upon which they rely'"].) "'The purpose of this requirement is to afford the court a means of determining whether or not the discovery of the asserted invasion was made within the time alleged, that is, whether plaintiffs actually learned something they did not know before.'" (Id. at p. 1324.) "[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. [Citations.] It is irrelevant that the plaintiff is ignorant of his legal remedy or the legal theories underlying his cause of action." (Gutierrez v. Mofid (1985) 39 Cal.3d 892, 897-898.)

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