Can a defendant whose conduct induces delay in filing a lawsuit be estopped to assert the statute of limitations?

While it is true that a defendant whose conduct induces delay in filing suit may be estopped to assert the statute of limitations (see, e.g., Ginns v. Savage (1964) 61 Cal.2d 520, 524-525, 39 Cal.Rptr. 377, 393 P.2d 689), the usual context for an estoppel argument is a history of negotiations between the parties that lead one side to believe that claims will be settled. Basing an estoppel on threats appears to be a novel but plausible application of the estoppel rule. ⁹ The question is whether DeRose comes within the rule she purports to identify.