Also there are subtle questions around what discovery means here. Usually it is some sort of "could be discovered with reasonable effort". If I had proof of your wrongdoing in a letter sent to me, I am unlikely to get away with saying, "Oh, I didn't read the letter when I got it." If that proof was buried in a computer file with a million pages, I probably can reasonably say, "That was a needle in a haystack, and I didn't even know what to look for." For situations between those extremes, there will be case law that likely varies by state.
Huge arrow pointing to “varies by state” on all of this.
1030 (which is, of course, federal law) actually has a specific discovery/statute of limitations in the text of the statute, and so may not be affected by state discovery rule law.
