In Juknavorian v. Sands & Associates (Super. Ct. L.A. County, 2007, No. SC094392), the Court affirmed the superior court's dismissal of the malpractice action brought by the client, Martin Juknavorian, against the firm, Sands & Associates. The opinion in that case discussed the procedural history pertinent to this appeal: "On June 27, 2007, Juknavorian filed his original complaint for damages for malpractice. In it, he alleged that in May 2002, he retained . . . Sands & Associates . . . to represent him in a marital dispute with his wife . . . . The attorneys 'failed to exercise reasonable care and skill' in their representation, 'in that the firm . . . failed to consolidate 2 actions brought by the wife against Juknavorian, failed to present evidence during numerous motions and trial and underestimated the costs and attorney fees to him.Had the firm exercised proper care and skill in the foregoing matter, Juknavorian would have settled the cases brought by his wife before engaging in protracted litigation.As a proximate result of such negligence he incurred damages in excess of $ 34,000.00 in costs and attorney fees and suffered emotional distress.' "At the same time he filed his complaint, Juknavorian filed a 'Rejection of Award and Request for Trial after Attorney-Client Fee Arbitration' (Rejection of Award). He indicated that the Rejection of Award was being filed with a complaint commencing a new action. The Rejection of Award states that the arbitration was conducted on December 7, 2006 and the arbitration award was dated May 29, 2007. The attached award of the Beverly Hills Bar Association is in favor of the firm for $ 24,250.95 in fees owed. The award states that it is advisory, but it would become binding unless rejected in accordance with the provisions of . . . section 6204. Section 6204 provides: "The parties may agree in writing to be bound by the award of arbitrators . . . at any time after the dispute over fees, costs, or both, has arisen. In the absence of such an agreement, either party shall be entitled to a trial after arbitration if sought within 30 days . . . .. . .. . . If no civil action is pending, the trial after arbitration shall be initiated by the commencement of an action in the court having jurisdiction over the amount of money in controversy within 30 days after service of notice of the award." ( 6204, subds. (a), (c), ) "The firm filed a demurrer to the complaint. Juknavorian did not file opposition. The trial court issued a tentative ruling sustaining the demurrer without leave to amend, stating: 'The legal malpractice is time barred. . . .' "On December 7, 2007, Juknavorian filed a first amended complaint for damages. In it, he added allegations that the firm 'charged him excessive and falsely inflated attorney fees and costs, charging him for work not done. This also resulted from unnecessary and protracted litigation when the firm failed to exercise proper care and skill.' Juknavorian alleged that 'in connection with the attorney fees and costs, he sought arbitration relief from the Beverly Hills Bar Association,' which resulted in an award in favor of the firm in the amount of $ 24,250.95. Juknavorian further alleged that his complaint served to appeal the arbitration award pursuant to . . . section 6204. "On January 4, 2008, the firm filed a demurrer on several grounds, including that the action was time-barred. . . . "Juknavorian opposed this demurrer. The trial court sustained the demurrer without leave to amend and dismissed the case. The court explained that 'Juknavorian failed to timely file a complaint for a request for a trial de novo for excessive legal fees after non-binding arbitration and such time has now passed. Further, the existing first amended complaint for malpractice only was not timely filed and is time barred. The statute of limitations on legal malpractice is one year from the date of discovery of the malpractice.'. . . P "Juknavorian first contends that his complaint was timely as to his cause of action for attorney malpractice. It appears that he is arguing that his cause of action for legal malpractice was tolled while the underlying case against him was on appeal and while his fee dispute was arbitrated. The arbitrator's decision was served by mail on May 27, 2007, and allowing five days for service by mail, Juknavorian claims his complaint for malpractice filed on June 27, 2007 was timely. He cites no authority in support of his claim that the legal malpractice action was tolled during the appeal in the marital dispute case and during the fee arbitration proceedings. "Code of Civil Procedure section 340.6, subdivision (a), provides that 'an action against an attorney for a wrongful act or omission . . . arising in the performance of professional services shall be commenced within one year after the plaintiff discovers, or through the use of reasonable diligence should have discovered, the facts constituting the wrongful act or omission, or four years from the date of the wrongful act or omission, whichever occurs first. In no event shall the time for commencement of legal action exceed four years except that the period shall be tolled during the time that any of the following exist:(1) The plaintiff has not sustained actual injury;(2) The attorney continues to represent the plaintiff regarding the specific subject matter in which the alleged wrongful act or omission occurred . . . .' "In the context of negligently conducted litigation, actual injury occurs no later than the point at which a client suffers an adverse judgment or order. . . . "In the civil action brought by Juknavorian's wife, judgment was entered July 14, 2003, the remittitur was filed on July 1, 2004, and acknowledgement of satisfaction of judgment was filed on September 23, 2004. The alleged actual injury occurred, and Juknavorian's cause of action accrued, no later than July 14, 2003 . . . .. . . "Juknavorian filed this action on June 27, 2007. His claim for legal malpractice is time-barred under Code of Civil Procedure section 340.6, subdivision (a). "Juknavorian also contends that his complaint was timely as to the dispute over attorney's fees. He acknowledges that pursuant to . . . section 6201, he had 30 days from the arbitration award to file an action. As stated above, the arbitrator's decision was served by mail on May 27, 2007, and allowing five days for service by mail . . . , Juknavorian claims his complaint filed on June 27, 2007 was timely. "As the trial court noted, however, Juknavorian's complaint filed on June 27, 2007 was for legal malpractice, not for a dispute over attorney's fees. He did not add the allegations regarding the dispute over attorney's fees until December 7, 2007, when he filed his first amended complaint, after the 30 days permitted by . . . section 6201. "As the firm points out, the trial court impliedly found the allegations of the first amended complaint did not relate back to the original complaint. "Juknavorian argues that his complaint must be liberally construed, and he should have been granted permission to amend his complaint. . . . Even liberally construed, the original complaint is not an action over attorney's fees. There could have been no abuse of discretion in denying leave to amend, in that there is no reasonable possibility the defect in the complaint could have been cured by amendment -- the 30-day limitations period had long since expired at the time of the hearing on the demurrer." (Juknavorian v. Sands & Associates, supra, B207759)