In Kiernan v. Union Bank (1976) 55 Cal. App. 3d 111, partial summary judgment was affirmed excluding recovery on all forged checks which had been paid more than a year before the filing of the complaint as required by section 4406. ( Id. at p. 114.) The plaintiff claimed that the bank was estopped to assert the bar of section 4406 where the bank's false representations prevented the plaintiffs from learning of their cause of action for payment of the forged checks. ( Id. at p. 116.) The argument was rejected because plaintiffs could not prove justifiable reliance. While the bookkeeper had concealed the account statements from the plaintiffs, the court held that the plaintiffs had imputed notice of the bookkeeper's activities by reason of their employment relationship with her, and so they could not shift their inquiry obligation from themselves to the Bank in order to invoke estoppel. ( Id. at p. 117.)