Does the statute of limitations apply to a claim that a would-be renter who falsely identified as a renter to a landlord in order to get an apartment?

¹⁴ In support of this proposition defendant cites People v. Bell (2010) 197 Cal.App.4th 822, 128 Cal.Rptr.3d 588. That case involved no issue of the statute of limitations. The question was whether a would-be renter who falsely identified herself to a landlord in order to get an apartment had thereby committed theft by false pretenses. Defendant quotes testimony by the landlord's manager that the defendant's delinquency in rent " right off the bat " was a " red flag. " (Id. at p. 825, 128 Cal.Rptr.3d 588.) That decision appears irrelevant here.