EFTA00591687.pdf

Case 9:08-cv-80736-KAM Document 409 Entered on FLSD Docket 07/20/2017 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-S0736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO GOVERNMENT'S RESPONSE AND OPPOSITION TO VICTIMS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND RESPONSE TO GOVERNMENT'S CROSS-MOTION FOR SUMMARY JUDGMENT Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, now file this unopposed motion for an extension of time to file a reply/response to the Government's Response and Opposition to the Victims' Motion for Partial Summary Judgment and the Government's Cross-Motion for Summary Judgment (DE 401-2). As the Court is aware, this is a complex case. Following the filing of the Victims' Statement of Undisputed Materials Facts and Motion for Partial Summary Judgment (DE 361), the Government obtained several extension of time and then, on June 2, 2017, the Government filed a 33-page response to the victims' motion for partial summary judgment and its own cross- motion for summary judgment (DE 401-2). The cross-motion raises nine separate arguments as to why the Government believes it is entitled to summary judgment in this case. In conjunction 1 EFTA00591687 Case 9:08-cv-80736-KAM Document 409 Entered on FLSD Docket 07/20/2017 Page 2 of 4 with these motions, the Government also filed a 22-page response to the victims' statement of undisputed materials facts (DE 407). The victims' response is currently due on July 21, 2017. Victims' counsel has been working diligently to prepare the victims' response. In researching and working on the response to the Government's motion, the victims have encountered several new issues that were more complicated than initially anticipated. Some of these issues pertain to legislative history associated with the Crime Victims' Rights Act and related subjects that require extensive research. Counsel for the victims also have several other cases that have recently required their attention. As a result of these facts, victims' counsel are not able to complete a fully adequate response under the current deadline. Accordingly, the victims seek an extension until August 11, 2017, to fully research and brief the important issues raised in the Government's response and motion. This request is not interposed for purposes of delay, but rather to allow full and careful briefing on this potentially dispositive motions. The Government does not oppose the motion and requests that the Court set a date September 15, 2017, for its reply in support of its motion for summary judgment. For the foregoing reasons, the victims respectfully request that the Court grant a twenty- one day extension to August 11, 2017, to respond to the Government's brief and to reply in support of their motion for summary judgment. DATED: July 20, 2017 Respectfully Submitted, /s/ natal f. Edoeva4 Bradley J. Edwards 1 EFTA00591688 Case 9:08-cv-80736-KAM Document 409 Entered on FLSD Docket 07/20/2017 Page 3 of 4 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telepho Facsimil , E-mail: brad@pathtojustice.com And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake City, UT 84112 Telephone Facsimile: E-Maikcassellp@law.utah.edu Attorneys for Jane Does 1 and 2 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah. 3 EFTA00591689 Case 9:08-cv-80736-KAM Document 409 Entered on FLSD Docket 07/20/2017 Page 4 of 4 CERTIFICATE OF SERVICE I certify that the foregoing document was served on July 20, 2017, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villainla 500 S. Australian Ave., Suite 400 401 E-mail: Dexter.Lee@usdoj.gov E-mail: ann.marie.c.villafana@usdoj.gov Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: pleadingeroyblack.com Attorneys for Jeffrey Epstein Is/ Sway/ p. Seitualua 4 EFTA00591690