One example is that quest where you're supposed to kill three ogres coming at you in order to rescue a noble's daughter. One already is tough, but three?
Or the Oblivion gates at higher levels. You often will find yourself surrounded by three dremoras, or maybe one xivilai and two daedroth. Facing four of them isn't too uncommon either.
Or just generally any situation where there are too many strong enemies attacking you at the same time.