In the Ninth Circuit, counsel can argue the habeas statute of limitations has been extended by equitable tolling due to extraordinary circumstances. Ineffective assistance of counsel is one of these circumstances. Strickland v. Washington, 466 U.S. 668, 687 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984); Castillo-Perez v. INS, 212 F.3d 518, 524-28 (9th Cir. 2000); Barraza-Rivera v. INS, 913 F.2d 1443, 1448 (9th Cir. 1990). Deadlines for motions to reopen due to extraordinary circumstances can be equitably tolled where extraordinary circumstances are concealed by attorney or notary public fraud or mistake. Iturribarria v. INS, 321 F.3d 889, 897-98 (9th Cir. 2003); Fajardo v. INS, 300 F.3d 1018 (9th Cir. 2002) (attorney imposter failed to notify noncitizen of the obligation to appear within removal proceedings); Rodriguez-Lariz v. INS, 282 F.3d 1218, 1227 (9th Cir. 2000), (attorneys failure to apply for discretionary relief from deportation ruled exceptional circumstances); Castillo-Perez v. INS, supra, (same). Thanks to Claude Piller.