Continuous representation tolls the statute of limitations, and requires actual work, a mutual understanding between client and attorney of the need for the actual work along with a mutual relationship of trust and confidence.  In RJR Mech. Inc. v Ruvoldt  2019 NY Slip Op 01844
Decided on March 14, 2019 Appellate Division, First Department some of that was missing.

“The statute of limitations on a cause of action for legal malpractice is three years (see CPLR 214[6]). Contrary to plaintiff’s assertions, the claim was not tolled by the continuous representation doctrine. Generally, tolling under the continuous representation doctrine “end[s] once the client is informed or otherwise put on notice of the attorney’s withdrawal from representation” (Shumsky v Eisenstein, 96 NY2d 164, 171 [2001]).

Moreover, there was not a “mutual understanding of the need for further representation on the specific subject matter underlying the malpractice claim” (McCoy v Feinman, 99 NY2d 295, 306 [2002]).”