Attorneys are taught to be zealous advocates for their clients. With rare exception, an attorney's zealous advocacy should not lead to liability to third parties. Two recent state Court of Appeal decisions demonstrate that the line between zealous advocacy and actionable attorney conduct is blurring.
In Rickley v. Goodfriend, 212 Cal. App. 4th 1136 (2013) (rev. denied April 10, 2013), the 2nd District Court of Ap...
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