4502 REVIEW DENIED The rule articulated in Coscia v McKenna requires a former criminal defendant who has been convicted and who seeks to bring a malpractice action against the attorney who defended the criminal charge to obtain post-conviction exoneration from the criminal court; it also requires the former client to bring the malpractice action within the applicable period of limitations and obtain a stay of the action in the trial court while diligently pursuing the post conviction remedy in the criminal court; the rule applies to actions that accrued before the decision was published.CitationROSE v HUDSON (Exonerated Plaintiff) 153 CA4 641 [See: Wiley v County of SD 19 C4 532, T/AT 1/99; Coscia v McKenna 25 C4 1194 T/AT 6/00; Brennan v Tremco 25 C4 310, T/AT 5/01]
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