In Von Rott v. Johnson (1983) 148 Cal.App.3d 608, a woman brought an action against the attorney who drafted the legal documents relating to the sale and purchase of her business and who became a pledgeholder for the stock involved in the transaction.
In declining to apply the tolling provision of section 340.6 to the claims, the court explained:
"Section 340.6 by its terms applies only to actions arising out of the performance of professional services by attorneys. Defendant's role as a pledgeholder was separate and distinct from his role as attorney. In his role as pledgeholder, defendant acted simply as an escrow, holding shares of the corporation for the benefit of plaintiff . . . . One need not be an attorney to act as pledgeholder, and it is clear that one acting as a pledgeholder is not performing legal services." (Von Rott, supra, 148 Cal.App.3d at pp. 612-613.)
The court thus concluded that "defendant's status as pledgeholder was only tangentially related to the legal representation he provided plaintiff and thus did not operate to toll the statute of limitations." (Id. at p. 613.)