In Kotlyarsky v. New York Post (195 Misc. 2d 150 [Sup Ct, Kings County 2003]) it was noted that, although both the doctrines of equitable estoppel and equitable tolling have a common origin, they are applied in different circumstances. Equitable estoppel has been held to be applicable where the plaintiff knew of the existence of the cause of action, but the defendant's misconduct caused the plaintiff to delay in bringing suit. Equitable tolling, on the other hand, has been held to be applicable where the defendant wrongfully deceived or misled the plaintiff in order to conceal the existence of a cause of action. Whether equitable tolling may be applied in the absence of wrongful conduct on the part of a defendant appears to be an open question.