EFTA00600007.pdf

Case 9:08-cv-80736-KAM Document 65 Entered on FLSD Docket 04)13.2011 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 JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR TWO WEEK EXTENSION OF TIME AND FOR PERMISSION TO FILE AN OVERLENGTH REPLY TO GOVERNMENT RESPONSES TO THEIR MOTIONS COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move this Court for an extra two weeks of time to reply to the Government's responses to their recently filed motions and for permission to file an overlength reply brief to the Government's 53-page response to their motion for "summary judgment." As the Court is aware, on March 21, 2011, the victims filed four motions in this case, including a substantial motion for "summary judgment" regarding violations of their rights under the Crime Victims' Rights Act (DEs #48, 49, 50, 51). On April 7, 2011, the Government responded to all four motions (DEs #58, 59, 60, 62). The responses total 85 pages, including a 53-page reply to the victim's Motion for Finding of Violations of the Crime Victims' Rights Act.' Counsel for the victims is diligently preparing to reply to all four of these responses. Given the total number of filings made by the Government, it will be difficult to prepare replies within the ordinarily allotted time. One counsel for the victims (Professor Cassell) is also in the To facilitate the Government's response to their motion, counsel for the victims provided a draft of their initial motion to the Government in October 2010. 1 EFTA00600007 Case 9:08-cv-80736-KAM Document 65 Entered on FLSD Docket 04/13/2011 Page 2 of 3 midst of the final week of his law school classes at the University of Utah College of Law, and needs to draft final exams and read student papers. The victims accordingly request an additional two-weeks to file a reply, up to and including May 2. The victims also request that they receive 50% of the number of pages that the Government used to respond to their summary judgment motion, a total of 27 pages. For the convenience of the Court, a proposed motion to that effect is attached. The Government does not oppose the motion. DATED: April 13. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 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: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 2 EFTA00600008 Case 9:08-cv-80736-KAM Document 65 Entered on FLSD Docket 04/13/2011 Page 3 of 3 CERTIFICATE OF SERVICE The foregoing document was served on April 13, 2011, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia Assistant U.S. Attorneys 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 Joseph L. Ackerman, Jr. Fowler White Burnett PA 777 S. Flagler Drive, West Tower, Suite 901 West Palm Beach, FL 33401 Criminal Defense Counsel for Jeffrey Epstein (courtesy copy of pleading via U.S. mail) 3 EFTA00600009