dereliction of counsel was an insufficient reason to invoke equitable tolling. The law is clear that courts must be sparing in their use of equitable tolling. There are, however, narrow circumstances in which the misbehavior of an attorney may merit such equitable relief. See, e.g., Cantrell v. Knoxville Community Dev. Corp., 60 F.3d 1177, 1180 (6th Cir.1995) (equitable tolling may be appropriate where attorney has abandoned client). As a preliminary matter, we note that it is settled that the ninety-day time limit in which a plaintiff must file a Title VII action is akin to a statute of limitations rather than a jurisdictional bar. Therefore, the time limit is subject to tolling. See, e.g., Zipes v. Trans World Airlines, Inc., 455 U.S. 385, 393, 102 S.Ct. 1127, 71 L.Ed.2d 234 (1982) (<HOLDING>); Oshiver v. Levin, Fishbein, Sedran & Berman,
holding that the time limits in the equal access to justice act are jurisdictional holding that the filing deadline under title vii is not a jurisdictional prerequisite to suit in federal court but a requirement that like a statute of limitations is subject to waiver estoppel and equitable tolling holding that time limits in title vii are not jurisdictional but are instead like statutes of limitations holding that criminal statutes of limitations are not jurisdictional but are a bar to prosecution which can be waived by a knowing and voluntary guilty plea holding that individual employees are not liable under title vii