Can a plaintiff obtain equitable estoppel to prevent a defendant from asserting the bar of the statute of limitations?

As these cases demonstrate, a plaintiff's representation by counsel may make it extremely difficult to establish facts sufficient to equitably estop the defendant from asserting the bar of the statute of limitations. In fact, in those instances in which the alleged misrepresentation relates solely to a legal matter, there is no estoppel "as a matter of law." (Romero v. County of Santa Clara (1970) 3 Cal.App.3d 700, 705.) But there simply is no general rule that, as a matter of law, a party represented by counsel may never prevail on a claim of equitable estoppel regardless of the factual context.