However real plaintiff's psychological and emotional barriers were to confrontation of psychotherapist, who allegedly abused patient, they could not toll statute of limitations for psychotherapeutic malpractice action when plaintiff knew or should have known that he had been harmed by psychiatrist's wrongful conduct. Riley v. Presnell (1991) 565 N.E.2d 780, 409 Mass. 239. Limitation Of Actions  74(1); Limitation Of Actions  95(12)

There are fiduciary aspects to psychotherapist-patient relationship; failure of psychotherapist to reveal facts relevant to potential malpractice action will toll statute of limitations until plaintiff discovers cause of action. Riley v. Presnell (1991) 565 N.E.2d 780, 409 Mass. 239. Limitation Of Actions  95(12)

Limitations period applicable to medical malpractice claims was not tolled due to physician's out-of-state residence where there was no evidence to indicate that timing of malpractice complaint's filing was in any way affected by a lack of knowledge of physician's whereabouts. Doyle v. Shubs, D.Mass.1989, 717 F.Supp. 946, amendment denied 729 F.Supp. 918, affirmed 905 F.2d 1. Limitation Of Actions  85(2)