James v. Borough of Manhattan Community College City of University of New York  ·  2022-10-25  ·  S.D. New York  ·  pin 28 F.3d at 12

“[L]ack of due diligence on the part of plaintiff’s attorney is 3 Plaintiff did not detail exactly how long she waited to hear back from the pro se legal clinic. insufficient to justify application of an equitable toll.”

Pollock v. Chertoff  ·  2005-03-28  ·  W.D. New York  ·  pin 28 F.3d at 12

“a plaintiffs failure to act diligently is not a reason to invoke equitable tolling”