For our purposes, the words mentioned in Havkin's book are appropriate:
More than once, the courts have ruled that the right to invoke a statute of limitations is subject to the obligation to use a procedural right in good faith. In our opinion, section 19 of the Statute of Limitations is an individual norm that can be applied according to the doctrine of estoppel by virtue of representation. This refers to a situation in which the defendant created a representation anchored in written evidence that would not claim a statute of limitations, the plaintiff relied on this representation according to a reasonable standard and changed his situation for the worse. In such a situation, there is no impediment to determining that the defendant is prevented from invoking the statute of limitations. This is even when the written requirement set out in section 19 - a separate written contract - has not been fully complied with.
(See: Havkin, p. 392. See also with regard to the subordination of the statute of limitations claim to the duty of procedural good faith: Civil Appeal 3496/15 in Balfour v. Givat Marom Ltd., paragraph 9 [published in Nevo] (January 17, 2017); Civil Appeal Authority 4705/22 Eliyahu v. Israel-Pour (Eliyahu), para. 10 [published in Nevo] (September 29, 2022)).
And docu, with its unqualified consent, Kost created a representation before the liquidators as if it agreed not to raise claims of limitation in relation to the entire claim, including with respect to a claim to be filed on behalf of the creditors. Had it not been for this representation, it is reasonable to assume that the liquidators would have acted to obtain an assignment of rights from the creditors and to file a claim on their behalf at an earlier stage, as they did in practice after the unsuccessful negotiations with Kost. Therefore, unlike the trial court, I am of the opinion that there was room to apply Kost's consent not to raise a claim of limitation in relation to the creditors' claim as well. As a result, the creditors' claim should be regarded as having been filed on January 3, 2018 - before the expiration of the limitation period (which began, as aforesaid, on August 25, 2011)."