California, United States of America
The following excerpt is from Sandoval v. Cnty. of L. A., B262748 (Cal. App. 2016):
The record does not contain a retainer agreement. But, even if Falese was only representing plaintiff in connection with the automobile accident, Falese was not reasonably diligent in obtaining plaintiff's medical records at the outset of his representation to determine, and have a working knowledge of, the nature and extent of plaintiff's damages or the identification of other possible tortfeasors concerning plaintiff's injuries. Once retained, an attorney has a duty to diligently investigate the facts and identifying possible defendants. (Ebersol v. Cowan (1983) 35 Cal.3d 427, 439; Department, supra, 82 Cal.App.4th at p. 1294, fn. 3.)
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