Targonski v. Clebowicz, 142 Conn. App. 97

Plaintiffs hired defendant to represent them in a 2004 real estate purchase of a lot and a right-of-way; the closing occurred June 9, 2004 with the deed omitting the right-of-way.
After closing, defendant assured plaintiffs the right-of-way was included; Cronan notified defendant in 2004 that the deed omitted it and proposed cure options.
Cronan sent multiple letters in 2004 proposing an easement contract/addendum; defendant did not respond or inform plaintiffs of the issues.
Plaintiffs later built a house and incurred zoning-related acquisitions and refinancings in 2005; defendant continued to represent them in those matters.
In 2008–2009, disputes arose over trespass and rights to Delahunty’s property; plaintiffs filed suit March 6, 2009, alleging negligence and negligent misrepresentation against defendant; defendant moved for summary judgment arguing the three-year statute of limitations barred the action.
The trial court granted summary judgment, but this Court reversed, holding that genuine issues of material fact existed as to tolling under the continuing course of conduct doctrine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether continuing course of conduct tolls the statute	Targonskis contend defendant breached a continuing duty by not curing the drafting error after learning of it.	Clebowicz argues the doctrine does not apply to attorney drafting errors and there was no continuing duty.	Yes, tolling questioned; issue for trial.
Whether evidence shows a continuing duty after initial wrong	Evidence (Cronan letters) shows continued duty to correct the deed error.	No continuing duty after the initial drafting at closing.	Evidence raises genuine issue of material fact; not summary judgment.
Whether the continuing representation doctrine applies to toll the limitations	Claim that continued representation beyond 2004 extended the tolling period.	Doctrine limited to ongoing litigation matters; not applicable here.	Court did not need reach if other tolling exists; but affirming tolling under continuing course of conduct.

Sanborn v. Greenwald, 39 Conn. App. 289 (1995) (continuing duty can toll when breach extends after initial wrong)
Watts v. Chittenden, 301 Conn. 575 (2011) (continuing duty and tolling requirements for CPL doctrines)
Vanliner Ins. Co. v. Fay, 98 Conn. App. 125 (2006) (continued duty necessary for tolling in continuing course of conduct)
Piteo v. Gottier, 112 Conn. App. 441 (2009) (occurrence statute; tolling may apply to continuing acts)