Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE NO. 3 AND JANE DOE NO. 4'S REPLY IN SUPPORT OF MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doe No. 3 and Jane Doe No. 4 (also referred to as "the new victims"), by and through undersigned counsel, to file this reply in support of their motion pursuant to Federal Rule of Civil Procedure 21 to join this action (DE 280), on the condition that they not re- litigate any issues already litigated by Jane Doe No. 1 and Jane Doe No. 2 (also referred to as "the current victims"). The Government's response (DE 290) fails to contest the new victims' specific argument that good cause exists for allowing them to join. Instead, the Government raises technical arguments about allegedly applicable statutes of limitations found in the CVRA or in 28 U.S.C. § 2401(a). But the CVRA does not contain the time limit that the Government reads into the Act. And § 2401(a) does not bar the action here. The Court should accordingly allow joinder of the new victims.' I. THE GOVERNMENT HAS NOT CONTESTED THE VICTIMS' POSITION THAT GOOD CAUSE EXISTS FOR ALLOWING THEM TO JOIN THIS ACTION UNDER RULE 21. To be clear, this motion is brought on behalf of all four victims — Jane Does No. I, 2, 3 and 4. As indicated throughout their pleadings, the victims do not seek to duplicate effort but rather (represented through the same legal counsel) to pursue a single, consolidated approach. EFTA01081439