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3324 REVIEW DENIED Negligence by an accountant in auditing a charter school resulted in actual damage to the school district that relied on the audit and triggered the statute of limitations on an action against the accountant when the school district detrimentally relied on the audit by certifying the charter school or when it suspected the error and suffered out-of-pocket losses by paying investigation fees in an effort to limit its exposure. CitationAPPLE VALLEY USD v VAVRINEK (Charter School) 98 CA4 934 [See: EdC 47600 etseq; CCP 339; Seheult v Jeffer, Mangels... 97 CA4 1411, T/AT 6/02; International Engine v Feddersen 64 CA4 345, T/AT 7/98; Van Dyke v Dunker 46 CA4 446, T/AT 7/96]
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