What is the test for equitable tolling of the statute of limitations?

Statutes of limitations are tolled while prisoners exhaust their administrative remedies. Brown v. Valoff, 422 F.3d 926, 942-43 (9th Cir. 2005) ("[T]he applicable statute of limitations must be tolled while a prisoner completes the mandatory exhaustion process."). Thus, time Plaintiff spent exhausting his administrative remedies does not count against him.

4. Pleading Standards for Equitable Tolling

Equitable tolling need not be explicitly pleaded. Rather, a complaint must provide

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