EFTA00602299.pdf

Case 9:08-cv-80736-KAM Document 349 Entered on FLSD Docket 01/04/2016 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE NO. 1 AND JANE DOE NO. 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO PETITIONERS' MOTION FOR DEPOSITIONS OF GOVERNMENT WITNESSES Respondent United States of America, by and through its undersigned counsel, files its Unopposed Motion for Enlargement of Time to File Response to Petitioners' Motion for Depositions of Government Witnesses, and states: I. On December 17, 2015, petitioners filed their motion for depositions of government witnesses. D.E. 344. A response is due on January 4, 2016. 2. Respondent's undersigned counsel commenced his annual leave on December 22, 2015, and has not had sufficient time to complete the response to petitioners' motion. Respondents' respectfully request an enlargement of time of seven (7) days, up to and including January 11, 2016, to file its response to the motion for depositions of government witnesses. 3. On January 4, 2016, respondent requested petitioners' position on the instant motion. Petitioners' counsel graciously did not oppose the instant motion. WHEREFORE, respondent respectfully requests an enlargement of time of seven (7) days, up to and including January 11, 2016, to file their response to the petitioners' motion for EFTA00602299 Case 9:08-cv-80736-KAM Document 349 Entered on FLSD Docket 01/04/2016 Page 2 of 3 depositions of government witnesses. DATED: January 4, 2016 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street, Suite 300 Miami, Florida 33132 ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 4, 2016, 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 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., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. 2 EFTA00602300 Case 9:08-cv-80736-KAM Document 349 Entered on FLSD Docket 01/04/2016 Page 3 of 3 Salt Lake City, Utah 84112 Attorneys for Jane Doe # I and Jane Doe # 2 3 EFTA00602301