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tims' all agree. Given entirely reasonable. Indeed, any other course would have been foolhardy. 4 The Government's concession readily distinguishes Center for Biological Diversity. Hamilton, 453 F.3d 1331 (11th Cir. 2006), which is clearly not an "ancillary criminal proceeding," but rather a civil enforcement action of the En
ed by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"
98 Case 9:08-cv-80736-KAM Document 290 Entered on FLSD Docket 01/20/2015 Page 6 of 14 limitations, no period of limitations applies, is refuted by Center for Biological Diversity.' That case dealt with the interpretation of the Endangered Species Act, and in particular, 16 U.S.C. § 1540(g)(1)(C). 453 F.3d at 1334. The Eleven
s period in section 2401(a) "applies to all civil actions whether legal, equitable, or mixed." Spannaus U.S. Department of Justice 824 F.2d 52, 55 (D.C. Cir. I987)(citations omitted). Moreover, the Eleventh Circuit has recognized that, "[u]nlike an ordinary statute of limitations, § 2401(a) is a jurisdi
tims' all agree. Given entirely reasonable. Indeed, any other course would have been foolhardy. 4 The Government's concession readily distinguishes Center for Biological Diversity v. Hamilton, 453 F.3d 1331 (11th Cir. 2006), which is clearly not an "ancillary criminal proceeding," but rather a civil enforcement action of the
by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey I. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"
Entities connected to both Center for Biological Diversity and D.C. Cir

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LOCATIONLeon Black
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Scarlett Johansson
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Kenneth Marra
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