Greenberg, Glusker, Fields, et al. v. Sierra Madre Investors
This is an appeal from the trial court's order determining that the cross-complainant's claims against the cross-defendant law firm fell outside the ambit of Civil Code section 1714.10, subdivision (a), which imposes a prefiling requirement for claims against an attorney based on a civil conspiracy with the client, and instead fell within the subdivision (c) exceptions specifying that no prior court order is required where (1) the attorney has an independent legal duty to the plaintiff (or cross-complainant) or (2) the attorney's acts go beyond the performance of a professional duty to serve the client and involve a conspiracy to violate a legal duty in furtherance of the attorney's financial gain. Because the statute does not apply to the claims alleged, we affirm.



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