Bienert, Miller & Katzman v. Patwardhan CA4/3, G052667

Law Firm (Bienert, Miller & Katzman) represented Jessica Young beginning September 11, 2008; Vinod Patwardhan agreed (by separate September 15, 2008 writing) to act as third‑party payor and unconditionally guarantee payment.
Retainer required bills to be paid on receipt and imposed late charges; Young also agreed to be responsible if Patwardhan failed to pay.
Patwardhan defaulted almost immediately; by August 2014 his unpaid balance was $42,588.
Law Firm sued Patwardhan for breach of contract and common counts on September 10, 2013.
Parties stipulated that Law Firm’s representation of Young concluded on February 3, 2010; trial court held the limitations period began to run only when representation ended and awarded Law Firm $42,588.
Court of Appeal affirmed, rejecting Patwardhan’s contention that each monthly bill started a separate four‑year limitations period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the statute of limitations for nonpayment of attorney fees accrue where a third‑party payor guaranteed payment?	Law Firm: limitations accrues when representation ends (so suit timely).	Patwardhan: each monthly bill accrues its own four‑year limitations period (most bills time‑barred).	Court: accrual occurs when representation concludes (Feb 3, 2010); judgment for Law Firm affirmed.

Hancock v. Pico, 47 Cal. 161 (1873) (early holding that fee claims accrue at end of representation)
Cullinan v. McColgan, 87 Cal.App. 684 (1927) (applied same limitations rule to third parties who benefit from services)
Atchison v. Hulse, 107 Cal.App. 640 (1930) (limitations for attorney fee collection accrues at end of representation)
E.O.C. Ord, Inc. v. Kovakovich, 200 Cal.App.3d 1194 (1988) (reaffirming accrual upon completion of services)
Beal Bank, SSB v. Arter & Hadden, LLP, 42 Cal.4th 503 (2007) (discussing tolling while attorney continues representation and policy avoiding disruption of attorney‑client relationship)