This court has located only one case that directly supports plaintiff's argument for extended tolling under Section 352.1(a). In McCovey v. Del Norte County, 2014 U.S. Dist. LEXIS 93582, at *6-7, ___WL ___ (N.D. Cal. July 9, 2014), the magistrate judge dismissed plaintiff's pro se prisoner civil rights action as time-barred despite finding (without analysis) that plaintiff's 33-day period of custody in a residential treatment program following his release from jail tolled the limitations period due to "the disability of incarceration" under Section 352.1(a).