Overview

Overview

HOLDINGS: [1]-An attorney’s failure to obtain a client’s signature under Bus. & Prof. Code, § 6148, subd. (a), on an engagement letter rendered the alleged attorney fee agreement voidable under § 6148, subd. (c), and an electronic acceptance argument lacked merit; [2]-Repudiating the engagement letter and not paying an invoice effectively voided the alleged agreement; [3]-There was no implied-in-fact agreement under § 6148, subd. (d), because the services materially differed from those previously rendered; [4]-A quantum meruit claim under § 6148, subd. (c), was time-barred under Code Civ. Proc., § 339, subd. 1, because it was filed more than two years after the representation ended; [5]-An account stated claim failed because consent to pay was not shown and because the four-year limitation period in Code Civ. Proc., § 337, subd. 2(2), did not apply absent a written contract.

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Outcome

Judgment affirmed.

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