EFTA00600170.pdf

Case 9:08-cv-80736-KAM Document 143 Entered on FLSD Docket 01/26/2012 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, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE MEMORANDUM OF LAW IN EXCESS OF TEN PAGES Respondent, United States, by and through its undersigned counsel, files its Motion for Leave of Court to File Memorandum of Law in Excess of Ten Pages, and states: I. Under S.D.Fla.L.R. 7.1(c)(2), no party shall file any reply legal memorandum that exceeds ten (10) pages in length, absent prior permission of the Court. 2. Respondent has filed its Sealed Reply In Support of its Motion to Dismiss for Lack of Jurisdiction, which numbers thirty-five (35) pages. The additional length of the Reply was necessary to adequately respond to the Petitioners Response and Supplemental Response. 3. Petitioners' co-counsel, Brad Edwards, Esq., does not object to the relief requested herein. WHEREFORE, respondent respectfully requests leave of the Court to file its Sealed Reply In Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, numbering thirty-five (35) pages. EFTA00600170 Case 9:08-cv-80736-KAM Document 143 Entered on FLSD Docket 01/26/2012 Page 2 of 3 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. Llth Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexter.lee@usdoj.gov Attorney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 26, 2012, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney 2 EFTA00600171 Case 9:08-cv-80736-KAM Document 143 Entered on FLSD Docket 01/26/2012 Page 3 of 3 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad@pathtojustice.com Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: casselp@law.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 3 EFTA00600172