Mikhaylov v. Bilzin Sumberg Baena Price & Axelrod LLP
Investor sued his transactional lawyers for malpractice and breach of fiduciary duty after his partner allegedly used firm-prepared documents to divest him of his interests; the trial court dismissed on the two-year professional malpractice statute of limitations. The Third District affirmed, holding the 'first-injury' rule governed because the pending related bankruptcy proceeding could only reduce or eliminate already-incurred damages, not determine whether actionable malpractice occurred.
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