Mays filed her complaint on January 27, 2012, while
she was still employed by the hospital, her claims were allowed to go forward based on
that filing date.


                                               7
II.    American Pipe tolling.
       Falk’s employment ended on August 25, 2006. Assuming that four years is the
outermost limitations period applicable to her claims,12 her complaint had to be filed by
August 25, 2010 to state a claim. Her complaint was not filed until December 3, 2012.
Falk, however, contendswith a denial
21
      Falk’s last day of work was August 25, 2006. Absent tolling, she therefore had to
August 25, 2007 to file one-year claims; to August 25, 2009 to file three-year claims; and
to August 25, 2010 to file four-year claims.


                                            15
of class certification. (See generally Jolly, supra, 44 Cal.3d at p. 1119 [American Pipe
held that “under limited circumstances, if class certification is denied, the statute of
limitations is tolled from the time of commencement of the suit to the time of