California conspiracy - the last overt act begins the statute of limitations.

The Case:   Wyatt v. Union Mortgage 24 Cal.3d 773 (1979)

Held:  when a civil conspiracy is properly alleged and proved, the statute of limitations does not begin to run on any part of a plaintiff's claims until the "last overt act" pursuant to the conspiracy has been completed... it is imperative for the plaintiff to allege when the last overt act took place (Agnew v. Parks (1959) 172 Cal. App.2d 756

See also The Case: Maheu v. CBS, INC., 201 Cal. App. 3d 662 (1988)

Cal: Court of Appeals, 2nd Dist., Div. 4

"[w]hile the conspiracy exists, the statute of limitations does not commence to run until the "cessation of the wrongful acts committed in furtherance of the conspiracy. [Citation.]" (Schessler v. Keck (1954) 125 Cal. App.2d 827, 832 [271 P.2d 588].) The cause of action based on conspiracy "`accrues on the date of the commission of the last overt act in pursuance of the conspiracy,'" a date which must be alleged. (Wyatt v. Union Mortgage Co. (1979) 24 Cal.3d 773, 789 [157 Cal. Rptr. 392, 598 P.2d 45].)"...