When does continuous representation end?  Sometimes there is a specific event (a judgment, a verdict, a motion decision) and sometimes there is a specific event plus a specific period of time (the date of the injury + three years) and sometimes continuous representation ends when the parties believe it ends.  So it is in Hadda v Lissner & Lissner LLP ; 2011 NY Slip Op 32519(U)
September 19, 2011; Sup Ct, NY County; Docket Number: 109329/10; Judge: Emily Jane Goodman.

"The continuous legal representation doctrine recognizes that the statute of limitations for  ommencing a malpractice action may be tolled, if the continuing representation "pertains specifically to the matter in which the attorney committed the alleged malpractice." Shumsky, 96 NY2d at 168. In other words, the doctrine permits the tolling of the statute of limitations "until
the ongoing representation is completed." Id. at 167-168. The plaintiff bears the burden to prove that the doctrine applies. See Corless v Mazza, 295 AD2d 848 (3d Dept 2002). The doctrine
requires a clear indicia of an ongoing, continuous, developing and personal relationship between the attorney and client or a mutual understanding of the need for further representation on
the specific subject matter underlying the malpractice claim.  See Matter of Merker, 18 AD3d 332 (1st Dept: 2 0 0 5 ) ."

"Defendants have not demonstrated, by conclusive documentary evidence, when the legal  alpractice action accrued (i.e, defendants rely on April 2006 as the date, which was when the
firm participated in a conference call, but did not bill for the work)’ and have not demonstrated that the continuous representation doctrine does not apply. Although it is true that the relationship may have ended prior to the time that plaintiffs’ terminated the relationship by l e t t e r , no conclusive
proof has been submitted regarding when the relationship ended.  Defendants note that the doctrine applies until the client is on notice that the attorney is no longer addressing their needs,
which need not be in the form of a motion to withdraw, but only needs to be reasonably sufficient to advise the client that the attorney w i l l no longer pursue the matter. However, contrary to defendants’ argument, that ”[pllaintiffs were surely on notice that the Law Firm w a s no longer addressing their legal needs” (Reply Affirm at 4), the affidavits of the husband of Ceri Hadda,
(who is himself an attorney), and Ceri herself, paint a different picture.  because he ‘is not a plaintiff in this action and his surname is not ‘Hadda”‘ and, because he was not party to the retainer (Id.at 16). While it is true that the doctrine depends upon the relationship between the attorney and the client (see Grlffen v Anslow, 17 AD3d 889 (3d Dept 2005) (retainer agreement and other documents conclusively established that the legal malpractice action should be dismissed because they indicated that the attorney-client relationship was not between plaintiff and
defendant, but was between plaintiff‘s corporations and defendant), nothing has been cited to support defendants’ contention that the client cannot act through her attorney husband. Here, apparently the f i r m itself recognized the husband’s authority to act on behalf of plaintiffs."