Does a Letter Sent by a Lawyer Sufficient to Toll the Statute of Limitations In a Claim Against An Estate ?

In In re: Estate of Dr. Ronald G. Livingston, 531 Pa. 308, 612 A.2d 976 (1992), the Court held that a letter sent by an attorney for a claimant outlining the claim against the estate to the attorney for the estate within six years of the decedent's death was sufficient to toll the six-year statute of limitations found at Section 5527(b) of the Judicial Code, 42 Pa. C.S. 5527(b). Section 5527(b) provides that "any civil action or proceeding which is neither subject to another limitation specified in this subchapter nor excluded from the application of a period of limitation by section 5531 (relating to no limitation) must be commenced within six years."