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Khodayari v Mashburn 200 Cal.App.4th 1184 (2/4) (2011) Khodayari’s legal malpractice claim against criminal defense lawyer Mashburn who handled probation violation matter. San-Diego-Auto-Accident-lawyer Demurrer sustained, affirmed. [1] Criminal defendant must both show actual innocence and obtain post-conviction exoneration before bringing malpractice claim. Same rule applies to probation violations, even if not to motions to return property seized from convicted defendant (Brooks 144 CA4th 434) San Diego personal injury attorney