Chief Judge Lisi of Rhode Island federal district court has held under Rhode Island law that neither the "discovery rule" nor the doctrine of "continuing tort" applies to stay or extend the three year statute of limitations for conversion of negotiable instruments. Plaintff alleged that his brother converted more than $1 million of checks from his medical practice and the movant-bank should have prevented the conversions. The court adopted a magistrate judge's R&R that the statute bars claims for conversions that occurred more than 3 years before suit. The district court's order is Marano v. RBS Citizens Financial Group, 2013 WL 639155 (D.R.I. Feb. 20, 2013). The R&R is at 2012 WL 7170421 (D.R.I. Dec. 27, 2012).