California, United States of America
The following excerpt is from Stella v. Asset Mgmt. Consultants, Inc., B269207 (Cal. App. 2017):
Section 638, subdivision (a), provides that a referee may be appointed by agreement of the parties to "hear and determine any or all of the issues in an action or proceeding, whether of fact or of law, and to report a statement of decision." The judgment based on a statement of decision following a consensual general reference is treated as if the action had been heard by the court (Code Civ. Proc., 644, subd. (a)) and is reviewed on appeal using the same rules that apply to a decision by the trial court. (See Central Valley General Hospital v. Smith (2008) 162 Cal.App.4th 501, 513.)
2. All of Stella's Causes of Action Are Time-barred
Traditionally, a claim accrues "'"when [it] is complete with all of its elements"those elements being wrongdoing [or
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