Epstein Secrets

curred, and the running of the limitations period, if applicable, did not begin until she returned to Florida about 16 months ago, in October 2013. Jane Doe 3 has therefore filed her action within the three-year time period specified by § 2401(a) for persons returning to this country from beyond the seas.

ach, Florida, to Sydney, Australia, is 9,364 miles — and that travel between the two points would involve passing over the Pacific Ocean. Therefore, Jane Doe 3 was plainly "beyond the seas" when the events giving rise to her claim occurred, and the running of the limitations period, if applicable, did not b

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

ening discovery (See Dkt 310 at 5), then the civil SOL should apply. The criminal SOL has nothing to do with the CVRA. Under the Petitioners theory, Jane Doe 3 could wait until she is 60 or 70 years old to bring the CVRA complaint (Dkt 311 at 9). 2 EFTA00188610 EFTA00188611 8. Jane Doe 3's residing i

ners theory, Jane Doe 3 could wait until she is 60 or 70 years old to bring the CVRA complaint (Dkt 311 at 9). 2 EFTA00188610 EFTA00188611 8. Jane Doe 3's residing in did not prevent her from joining the CVRA case. The case was widely reported in the media as was the NPA (DKT 290 at 7 fn 7 where Govt

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

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lleged by petitioners, then there is no good explanation for why they waited two years to attempt to add her to this lawsuit. III. THE ADDITION OF JANE DOE #3 AND JANE DOE #4 WILL PREJUDICE THE GOVERNMENT The Government disagrees with petitioners' assertion that the addition of the two new victims will n

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

alleged by petitioners, then there is no good explanation for why they waited two years to attempt to add her to this lawsuit. IV. THE ADDITION OF JANE DOE #3 AND JANE DOE #4 WILL PREJUDICE THE GOVERNMENT The Government disagrees with petitioners' assertion that the addition of the two new victims will n

F.2d at 55. Also, petitioners' contention that, because the CVRA contains no statute of 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 Elevent