With no explanation, chose the best option from "A", "B", "C" or "D". Is Left? {¶ 46} Under Ohio law, a legal-malpractice case subsumes within it any of the issues that can arise from the attorney-client relationship. These may include alleged billing errors by the lawyer. Byrd v. Peden (1999), 10th Dist. No. 99AP-111, 2000 WL 192571. All claims in tort, fraud, or contract against a lawyer are, essentially, considered to be malpractice. Gullatte v. Rion (2d Dist.2000), 145 Ohio App.3d 620, 626, 763 N.E.2d 1215. “Malpractice by any other name still constitutes malpractice.” Muir v. Hadler Real Estate Mgmt. Co. (10th Dist.1982), 4 Ohio App.3d 89, 90, 4 OBR 170, 446 N.E.2d 820; Dingus v. Kirwan, 6th Dist. No. E-05-082, 2006-Ohio-4295, 2006 WL 2384070, at ¶ 10; see, also, Kester v. Brakel, 10th Dist. No. 06AP-253, 2007-Ohio-495, 2007 WL 353098, at ¶ 20-24 (<HOLDING>); Andrianos v. Community Traction Co. (1951),

A: recognizing that that dcfmlas theories of recovery parallel the fmlas
B: holding that separate theories of recovery all constituted a medicalmalpractice claim
C: holding that the avoidance powers provide for recovery only if the recovery is for the benefit of the estate
D: recognizing authority stating that a plaintiff in a cercla action is allowed to plead alternative theories even if it cannot ultimately seek duplicate recovery
B.