California, United States of America
The following excerpt is from People v. Zamora, 134 Cal.Rptr. 784, 18 Cal.3d 538, 557 P.2d 75 (Cal. 1976):
On its face the 1969 amendment appears to set the limitation period running from the actual 'discovery' of a theft. The new provision has nevertheless been interpreted to include the same requirement of 'reasonable diligence' in discovering the facts of a theft that the courts have read into the 'discovery' provision of the statute of limitations for tort actions based on fraud as set forth in Code of Civil Procedure section 338, subdivision 4. (People v. Swinney, supra, 46 Cal.App.3d 332, 340--343, 120 Cal.Rptr.