EFTA00595354.pdf

Case 9:08-cv-80736-KAM Document 315 Entered on FLSD Docket 02/27/2015 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES UNOPPOSED MOTION BY THE VICTIMS FOR EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF PROTECTIVE MOTION PURSUANT TO RULE 15 TO AMEND THEIR PETITION TO CONFORM TO EXISTING EVIDENCE AND TO ADD JANE DOE NO. 3 AND JANE DOE NO. 4 AS PETITIONERS COME NOW Jane Doe No. 1 and Jane Doe No. 2 (also referred to as "the current victims"), by and through undersigned counsel, to file this unopposed motion for a short extension of time to file their reply in support of their motion to amend their petition to conform to existing evidence and to add two new victims, Jane Doe No. 3 and Jane Doe No. 4 (the "new victims") as petitioners. On February 6, 2015, the current victims filed a Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners (DE 311). On February 23, 2015, the Government filed an opposition to the current victims' motion (DE 312). The opposition was 25 pages long and raised several complicated issues, including issues surrounding the interplay of the Federal Rules of Criminal Procedure and Civil Procedure and case decisions interpreting statutes of limitation relevant to the motion. Counsel for the victims wish to carefully research issues related to these issues and fully address the points raised by the Government. Counsel for the victims also have several 1 EFTA00595354 Case 9:08-cv-80736-KAM Document 315 Entered on FLSD Docket 02/27/2015 Page 2 of 3 other significant matters that require their full attention in the next two weeks. Given counsel's schedule, concluding this research and preparing the reply will require additional time. Accordingly, the new victims seek a ten-day extension of time to file their reply until Thursday, March 19, 2015. Jane Doe No. 1 and Jane Doe No. 2 support this motion. The Government does not oppose this request. Accordingly, the Court should grant the new victims an extension of time to prepare their reply. DATED: February 27, 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, M. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: 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: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu Attorneys for Jane Does Nos. 1, 2, 3, and 4 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 2 EFTA00595355 Case 9:08-cv-80736-KAM Document 315 Entered on FLSD Docket 02/27/2015 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on February 27, 2015, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee@usdoj.gov E-mail: ann.marie.c.villafana@usdoj.gov Attorneys for the Government /s/ Bradley J. Edwards 3 EFTA00595356