What is the test for equitable tolling in motor vehicle accidents?

Federal courts have applied the doctrine of equitable tolling in two generally distinct kinds of situations. In the first, the plaintiffs were prevented from asserting their claims by some kind of wrongful conduct on the part of the defendant. In the second, extraordinary circumstances beyond plaintiffs' control made it impossible to file the claims on time. An excellent discussion of the application of these principles of equitable tolling can be found in Forti v. Suarez-Mason, 672 F.Supp. 1531, 1549-50 (N.D.Cal.1987).