What is the test for "actual injury" in medical malpractice cases?

Generally, "when malpractice results in the loss of a right, remedy, or interest, or in the imposition of a liability, there has been actual injury regardless of whether future events may affect the permanency of the injury or the amount of monetary damages eventually incurred." (Foxborough v. Van Atta, supra, 26 Cal.App.4th at p. 227.) Under that principle, actual injury may occur no later than when the right or interest has been lost, and the client incurs legal fees in litigation implicating the lost right or interest.