XE Partners brought an action for legal malpractice against a law firm arising from legal advice the firm provided to XE in 2008 regarding the withdrawal of certain LLC members.  XE Partners, LLC v. Skadden Arps, Slate Meagher & Flom LLP, No. 152994/2013 (N.Y. Sup. Ct. Mar. 6, 2014).  In 2008, the withdrawing members filed an arbitration against XE Partners seeking a larger buyout.  In November 2010, the arbitration panel ruled against XE Partners.  In March 2013, XE Partners filed suit against the law firm, alleging that the firm’s advice in 2008 led to the conduct cited by the arbitration panel as the basis for its decision.  The law firm moved to dismiss the complaint as time-barred under New York’s three-year statute of limitations for legal malpractice claims.  XE Partners countered that its malpractice claim was timely because it accrued when XE suffered an injury:  the arbitration award against it in 2010.  The court rejected this argument and held that XE Partners’ complaint was time-barred because the claim accrued in 2008 when the allegedly negligent work product was received by XE Partners.  The court held that collateral adjudication like the arbitration was not a prerequisite to the existence of an actionable injury.