What is the statute of limitations for an action brought by a plaintiff who was injured in a motor vehicle accident?

In tort actions, the statute of limitations commences upon the occurrence of the last element essential to a cause of action. (Leaf v. City of San Mateo (1980) 104 Cal.App.3d 398, 406, 163 Cal.Rptr. 711.) If the last element to occur is the element of damage, the statute of limitations begins to run upon the occurrence of "appreciable and actual harm, however uncertain in amount," that consists of more than nominal damages. (Davies v. Krasna (1975) 14 Cal.3d 502, 514, 121 Cal.Rptr. 705, 535 P.2d 1161.) [30 Cal.App.4th 583] "[O]nce plaintiff has suffered actual and appreciable harm, neither the speculative nor uncertain character of damages nor the difficulty of proof will toll the period of limitation." (Ibid.; Oakes v. McCarthy Co. (1968) 267 Cal.App.2d 231, 255, 73 Cal.Rptr. 127--statute of limitations commences with damages appreciable to a reasonable person.)