What is the test for equitable tolling in a personal injury action brought by a plaintiff against a non-profit organization's attorneys?

Petitioner argues the conduct of the organization's attorneys resulted in more than a "garden variety claim" of professional negligence as was present in Holland v. Florida, 130 S.Ct. 2549. In Holland, equitable tolling was granted after the petitioner repeatedly asked his attorney to file his federal petition in a timely manner, wrote several letters to the state bar indicating that his attorney had abandoned him, and that the attorney had grossly miscalculated the limitations deadline. Id. at 2564. Here, neither the organization nor current counsel acted deceptively and a two-day miscalculation is not an egregious error. Rather, the miscalculation is preciously the type of garden-variety mistake for which no equitable tolling is warranted.