The analytical issue in John Doe cases flows from the historical purpose of the statute of limitations. The Supreme Court explained:

Statutes of limitations... represent a pervasive legislative judgment that it is unjust to fail to put the adversary on notice to defend within a specified period of time.... [T]hey protect defendants and the courts from having to deal with cases in which the search for truth may be seriously impaired by the loss of evidence, whether by death or disappearance of witnesses, fading memories, disappearance of documents, or otherwise.

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