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Legal Memorandum: Accrual of Fraud Claims in NY

Issue: Where do fraud claims accrue in New York?

Area of Law: Business Organizations & Contracts, Litigation & Procedure
Keywords: Fraud claims; Accrual of claim
Jurisdiction: New York
Cited Cases: 582 F. Supp. 1421; 71 A.D.2d 587; 418 N.Y.S.2d 432
Cited Statutes: None
Date: 04/01/2013 

 
Lang v. Paine Webber, Jackson & Curtis, 582 F. Supp. 1421 (S.D.N.Y. 1984) (fraud claim accrues where the harm was felt, normally where plaintiff resides, but court can consider all relevant factors to determine where loss is felt)
Prefabco, Inc. v. Olin Corp., 71 A.D.2d 587, 418 N.Y.S.2d 432 (1979) (fraud claim accrues where resulting loss was sustained, not where misrepresentations were made)

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