The following excerpt is from Honchariw v. Cnty. of Stanislaus & Bd. of Supervisors of Cnty. of Stanislaus, 1:16-cv-1183-LJO-BAM (E.D. Cal. 2016):
Plaintiff correctly notes that he potentially could have tolled the statute of limitations pending his state court proceedings. "[I]t is well established in California that the statute of limitations is equitably tolled on claims in a second-filed action only during the pendency of identical claims in a first-filed action that was pursued in a different forum." Mitchell v. Snowden, No. 2:15-cv-1167-TLN-AC P, 2016
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