Statute of limitations on fraud starts when the fraud is discovered
In Holmberg v. Armbrecht, 327 U.S. 392, 66 S. Ct. 582, 585, 90 L. Ed. 743, the Supreme Court said the rule adopted by it was that "where a plaintiff has been injured by fraud and 'remains in ignorance of it without any fault or want of diligence or care on his part, the bar of the statute does not begin to run until the fraud is discovered, though there be no special circumstances or efforts on the part of the party committing the fraud to conceal it from the knowledge of the other party.'"
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