California, United States of America
The following excerpt is from Chernavsky v. Gurovich & Assocs., B223232 (Cal. App. 2011):
Appellant's retention of an attorney to "mitigate his damages" was a clear indication of the breakdown of the attorney-client relationship. That a formal substitution of attorney was not filed until February 18, 2004, or arguably might not have been filed at all, in itself is not determinative. "[T]he failure to formally withdraw as attorney of record, standing alone, will not toll the statute of limitations under the rubric of continued representation." (Shapero v. Fliegel (1987) 191 Cal.App.3d 842, 846.)
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