There would be no statute limiting the time to seek such recourse.
Another novel approach would be to seek intervention of the Treasury Department as against the offending church to strip its 501(C)(3) tax exempt status due to its involvement in an alleged crime committed under the RICO statutes, which would deprive it of its rights as a "religion.
Since the writer was targeted as an individual by the RICO aspect of the Mormon Church some 31 years ago, he has commenced the preliminary civil prosecutorial function of RICO by writing a letter to Doug Shulman, Commissioner of the IRS for an investigation into allegations contained in that letter which would deprive the Mormon Church of its prized tax exempt status. See public diary posted on Opednews November 3, 2009. http://www.opednews.com/populum/diarymanage.php?submit=view&did=14836
In that letter I suggested that I would abide the event until January 1, 2010 at which time I would likely seek legal recourse. So I await the results of the letter.
(Note: You can view every article as one long page if you sign up as an Advocate Member, or higher).