Does the "last overt act" rule apply to civil wrongs?

The most fundamental difficulty with the "last overt act" rule, of course, is its fortuitous and random inequity. Where a Single defendant is involved, plaintiff may clearly not avoid the statute of limitations on an earlier tort by waiting to commence suit until further tortious acts of the defendant have produced even greater damage. (Davies v. Krasna, supra, 14 Cal.3d at pp. 512-515, 121 Cal.Rptr. 705, 535 P.2d 1161.) There appears absolutely no reason why a different rule should apply simply because two or more persons "conspired" to commit the identical wrongs. On policy grounds plaintiffs should be encouraged to nip "conspiracies" in the bud. The "last overt act" rule applied to civil wrongs, on the other hand, encourages injured parties to sit by until the conspiratorial scheme has operated with full force and has run its extended ultimate course. The statute of limitations on each of the precedent causes of action which have fully accrued is meanwhile suspended in midair, as it were. Such a rule makes no sense, and defeats the purposes of the statute of limitations while serving no legitimate needs of injured plaintiffs.