In Elkins v. Derby (1974) 12 Cal.3d 410, the California Supreme Court held that the doctrine of equitable tolling may apply to toll the statute of limitations on a claim during the period in which a plaintiff pursues another remedy for the harm that the plaintiff suffered. The Elkins court adopted a line of cases in which courts had concluded that "if the defendant is not prejudiced thereby, the running of the limitations period is tolled 'when an injured person has several legal remedies and, reasonably and in good faith, pursues one.'" (Id. at p. 414, quoting Myers v. County of Orange (1970) 6 Cal.App.3d 626, 634.) In Elkins, the plaintiff suffered an injury in September 1969 while working on the defendants' premises. (Elkins, supra, 12 Cal.3d at p. 413.) Approximately 10 months after the injury, the plaintiff filed an application for workers' compensation benefits against the defendants. (Ibid.) A workers' compensation referee determined that the plaintiff was not an "employee" of the defendants under the applicable Labor Code provisions at the time of his injury and concluded that he was therefore ineligible for workers' compensation benefits. (Ibid.) The referee's decision became final in mid-December 1970, approximately 15 months after the plaintiff's injury. (Ibid.) Approximately a month after the referee's decision became final, the plaintiff filed a personal injury action seeking recovery for the same injury that served as the basis of his workers' compensation claim. (Ibid.) The trial court sustained the defendants' demurrer on the ground that the action was barred by the applicable one-year statute of limitations. (Ibid.) On appeal, the Elkins court reversed, holding that the statute of limitations had been tolled for the period during which the plaintiff pursued his workers' compensation remedy. (Id. at p. 412.) The Elkins court reasoned that the primary purpose of a limitations statute is to "'(prevent) surprises through the revival of claims that have been allowed to slumber until evidence has been lost, memories have faded, and witnesses have disappeared.'" (Elkins, supra, 12 Cal.3d at p. 417, quoting Telegraphers v. Ry. Express Agency (1944) 321 U.S. 342, 348-349 88 L.Ed. 788, 64 S.Ct. 582.) According to the Elkins court, that purpose is "normally satisfied when the defendant receives timely notification of the first of two proceedings." (Elkins, supra, at p. 416, fn. 3.)